GM1 ATM/ANS.OR.A.045(a) Changes to a functional system

ED Decision 2020/008/R

NOTIFICATION

(a)     A change should be notified as soon as the data defined in AMC1 ATM/ANS.OR.A.045(a) is available. The decision to review a change by the competent authority will be based, in most circumstances, on the notification data. Exceptions to this are cases where the competent authority is not familiar with the type of change or the complexity of the change requires a more thorough consideration.

(b)     Early and accurate notification facilitates the interactions between the provider and the competent authority and, thus, maximises the likelihood of introducing a change into service in due time and according to the service provider’s initial schedule when the competent authority has decided to review an assurance case. Therefore, it is advisable that the change description identified in AMC1 ATM/ANS.OR.A.045(a) is completed as soon as possible and contains the following data:

(1)     Purpose of the change;

(2)     Reasons for the change;

(3)     Place of implementation;

(4)     New/modified functions/services brought about by the change;

(5)     High-level identification of the constituents of the functional system being changed, and what is modified in their functionality;

(6)     Consequence of the change, i.e. the harmful effects of the hazards associated with the change — see (f) below and also the definition of ‘risk’ in Annex I (85).

(c)      The information provided in (b) may expedite the decision whether to review or not the proposed change, because it will allow the competent authority to gain complete knowledge of the change and, consequently, reduces the need for additional information. However, lack of some of this data should not delay the service provider’s submission of the notification if to do so is likely to impede the introduction of the change. It should be noted that early interaction with its competent authority may help to complete the missing data.

(d)     The service provider should take into account that an early, clear and accurate change notification will assist the competent authority in making the decision to review or not the change and may prevent any inconvenience such as:

(1)     the competent authority having to ask for more information about the change in order to make its decision as required in ATM/ANS.OR.A.045(a)(2);

(2)     the competent authority deciding to review a change unnecessarily because the notification is not clear enough; or

(3)     the delay in the competent authority deciding whether to review a change, caused by the lack of information, having an impact on the proposed date of entry into service.

(e)     It is recognised that the understanding of the change will improve as the change process progresses and the interaction between the competent authority and the service provider strengthens. The service provider should notify the competent authority when the information provided in the previous notification is no longer valid or when the information previously missing becomes available. When additional information — other than the data specified in AMC1 ATM/ANS.OR.A.045(a) — is supplied at the competent authority’s request, then no update of the notification is required.

(f)      For air traffic services (ATS) providers, the consequences of the change specified in (b)(6), should be expressed in terms of the harmful effects of the change, i.e. the effects of the hazards associated with safety risks. These could be the result of a preliminary safety assessment, if available, or an early hazard analysis that concentrates on the service level effects. For service providers other than air traffic services providers, the consequences should be expressed in terms of what aspects of the performance of the service are impacted by the change.

(g)     The point of contact, as required in point (j) in AMC1 ATM/ANS.OR.A.045(a), provides a focal point for the competent authority to contact when seeking complementary information about the change when required. The aim is to improve communications between the provider and the competent authority about the change.

(h)     All notified changes should be unambiguously identified. The service provider and its competent authority should agree on a means of referencing so as to associate a unique identifier to a given notified change.

(i)      For routine changes, the notification to the competent authority may be done in a simpler manner, e.g. using forms less detailed than those specified in AMC1 ATM/ANS.OR.A.045(a) or notifying these changes collectively after being implemented at regular periods of times agreed between the provider and the competent authority. A service provider and its competent authority should coordinate so as to reach a common agreement on these types of changes that may not be reviewed by the competent authority. The list of such changes should be documented and formalised. The formalised agreement becomes part of the change management procedures identified in ATM/ANS.OR.B.010. Consequently, the list will be reviewed by the competent authority as part of the audits it performs that are described in ATM/ANS.AR.C.010(a). The relevant audit activity is detailed in AMC1 ATM/ANS.AR.C.010(a)(a)(2).