AMC1 ATM/ANS.OR.B.005(c) Management system

ED Decision 2017/001/R

COMPLIANCE MONITORING — GENERAL FOR COMPLEX SERVICE PROVIDERS

(a)     Compliance monitoring

The implementation and use of a compliance monitoring function should enable the service provider to monitor compliance with the relevant requirements of this Part and other applicable Parts.

(1)     A service provider should specify the basic structure of the compliance monitoring function applicable to the activities conducted.

(2)     The compliance monitoring function should be structured according to the size of the service provider and the complexity of the activities to be monitored, including those which have been subcontracted.

(b)     A service provider should monitor compliance with the procedures they have designed to ensure that services are provided with the required safety levels and quality, as applicable. In doing so, they should as a minimum, and where appropriate, monitor:

(1)     manuals, logs, and records;

(2)     training standards; and

(3)     management system procedures.

(c)      Organisational set-up

(1)     A person should be responsible for compliance monitoring to ensure that the service provider continues to meet the requirements of this Part and other applicable Parts. The accountable manager should ensure that sufficient resources are allocated for compliance monitoring.

(2)     Personnel involved in the compliance monitoring should have access to all parts of service provider and, as necessary, any contracted organisation.

(3)     In the case the person responsible for compliance monitoring acts also as safety manager, the accountable manager, with regard to his or her direct accountability for safety, should ensure that sufficient resources are allocated to both functions, taking into account the size of the service provider and the nature and complexity of its activities.

(4)     The independence of the compliance monitoring function should be established by ensuring that audits and inspections are carried out by personnel not directly involved in the activity being audited.

(d)     Compliance monitoring documentation

(1)     Relevant documentation should include relevant part(s) of the service provider’s management system documentation.

(2)     In addition, relevant documentation should also include:

(i)      terminology;

(ii)     specified activity standards;

(iii)     a description of the service provider;

(iv)     allocation of duties and responsibilities;

(v)      procedures to ensure compliance;

(vi)     the compliance monitoring programme, reflecting:

(A)     the schedule of the monitoring programme;

(B)     audit procedures;

(C)     reporting procedures;

(D)     follow-up and corrective action procedures; and

(E)     the record-keeping system;

(vii)    the training syllabus referred to in (e)(2); and

(viii)   document control.

(e)     Training

(1)     Correct and thorough training is essential to optimise compliance in every service provider. In order to achieve significant outcomes of such training, the service provider should ensure that all personnel understand the objectives as laid down in the service provider’s management system documentation.

(2)     Those responsible for managing the compliance monitoring function should receive training on this task. Such training should cover the requirements of compliance monitoring, manuals and procedures related to the task, audit techniques, reporting and recording.

(3)     Time should be provided to train all personnel involved in compliance management and for briefing the remainder of the personnel.

(4)     The allocation of time and resources should be governed by the volume and complexity of the activities concerned.