The process of getting approval as a pilot training organisation (ATO) from EASA (or another European Competent Authority) involves much more than filling out an application form. To be successful in achieving and maintaining an approval you will need to demonstrate that your organisation is compliant with all of the regulatory requirements including the way in which it is organised and managed. The best way to approach this is to have a detailed project plan to implement the requirements in parallel with your ATO application.
Amending documents and procedures is an important aspect of implementing the organisational requirements of the aircrew regulation, but it is only a small part of the whole project. Before new documentation can be developed it’s necessary to understand where your present operation already complies with the requirements and where changes are needed. Equally important is ensuring that everyone involved understands the requirements and that any changed procedures are implemented effectively.
McKechnie Aviation has developed a plan for implementing the organisational requirements of the aircrew regulation and can assist with the required change management. There are four main phases:
- Briefing on the requirements: to ensure that key stakeholders understand the regulatory requirements and the objectives of the project;
- Analysis: Determine the changes required to be compliant with the aircrew regulation;
- Development: Amend processes, procedures and documentation in accordance with the outcome of the analysis phase;
- Implementation: Implement the required changes;
- Follow-up: Post-implementation review and remedial action as required.
The following table shows a breakdown of the tasks involved in each stage of the project.
|Briefing on requirements||Training programme to explain regulatory requirements to key stakeholders (i.e. management and staff).|
|Analysis||Documentation review (approvals, manuals, job descriptions etc.).|
On-site audit including inspection of facilities; interviews with staff and management; observation of training; review of safety, training and compliance monitoring records.
Preparation of gap analysis report.
Completion of ‘compliance matrix’.
Determinations of changes required to comply with aircrew regulation.
|Development||Revision of job descriptions (duties and responsibilities) for management and staff.|
Revision of manuals including:
a. Organisation management manual (or equivalent);
b. Operations manual in four parts, A – D;
c. Training manual with details of each of the courses
Develop local procedures / work instructions to describe processes used to comply with requirements.
Update compliance matrix.
|Implementation||Selection / recruitment of managers and staff (as required).|
Acquisition of any additional facilities required (e.g. premises, aircraft FSTDs).
Qualification of instructors and examiners.
Staff training on new documentation and procedures.
Implementation of revised procedures including all safety management, compliance monitoring and operational control functions.
Internal audit to confirm effective implementation.
|Follow-up||Follow-up audit conducted six months after the implementation of changes.|
Implementation of remedial action (as required).
In order to develop a project plan for your organisation ‘deliverables’ and timescales would be developed for each of these tasks. The tasks would be assigned to named individuals and a project manager appointed to oversee the whole project. A Gantt chart would be used to show the dependencies and a communication strategy developed to ensure that managers and staff are kept informed about progress. This implementation project could be run in parallel to an ATO application.
Perhaps your organisation has senior managers with enough time on their hands to get to grips with the European requirements and run this project, if so then that’s great.
On the other hand if your (expensive) managers are already fully occupied running your business then you could call in some expert help. McKechnie Aviation can assist with any part of the project, or can act as project manager to coordinate your team throughout. Contact us for more information.