AMC1 ADR.OR.D.005(b)(11) Management system

COMPLIANCE MONITORING

(a) Compliance monitoring

(1) The implementation and use of a compliance monitoring function should enable the aerodrome operator to monitor compliance with the relevant requirements of this Part, Part-ADR.OPS, as well as any other applicable regulatory requirements, or requirements established by the aerodrome operator.

The aerodrome operator should specify the basic structure of the compliance monitoring applicable to the activities conducted.

The compliance monitoring should be properly implemented, maintained and continually reviewed and improved as necessary.

Compliance monitoring should be structured according to the size of organisation and the complexity of the activities to be monitored, including those which have been subcontracted.

(2) An aerodrome operator should monitor compliance with the procedures it has designed, to ensure safe activities. In doing so, an aerodrome operator should as a minimum, and where appropriate, monitor compliance with:

(i) privileges of the aerodrome operator;

(ii) manuals, logs, and records;

(iii) training standards;

(iv) required resources; and

(v) management system procedures and manuals.

(b) Organisational set-up

(1) A person should be responsible for compliance monitoring.

The accountable manager, with regards to his/her direct accountability for safety, should ensure, in accordance with ADR.D.015(a), that sufficient resources are allocated for compliance monitoring. In the case the person responsible for the compliance monitoring acts also as safety manager, the accountable manager should ensure that sufficient resources are allocated to both functions, taking into account the size of the aerodrome operator, and the nature and complexity of its activities.

(2) The independence of the compliance monitoring should be established by ensuring that audits and inspections are carried out by personnel not responsible for the function, procedure, etc. being audited.

(3) Personnel involved in compliance monitoring should have access to any part of the aerodrome organisation, and any contracted organisation as required.

(c) Compliance monitoring documentation

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

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

(i) terminology;

(ii) specified activity standards;

(iii) a description of the organisation of the aerodrome operator;

(iv) the allocation of duties and responsibilities;

(v) procedures to ensure regulatory compliance;

(vi) the compliance monitoring programme, reflecting:

(A) schedule of the monitoring programme;

(B) audit procedures;

(C) reporting procedures;

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

(E) recording system;

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

(viii) document control.

(d) Training

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

(2) Those responsible for managing the compliance monitoring 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 the personnel involved in compliance management, and for briefing the remaining of the personnel.

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

(e) Compliance monitoring — audit scheduling

(1) A defined audit schedule to be completed during a specified calendar period and a periodic review cycle for each area should be established. The compliance monitoring itself should also be audited according to a defined audit schedule. The schedule should allow for unscheduled audits when trends are identified. Follow-up audits should be scheduled to verify that corrective action was carried out, and that it was effective and completed, in accordance with the policies and procedures specified in the aerodrome manual.

(2) The aerodrome, its management system key processes, procedures and its operation should be audited within the first 12 months since the date of the issuance of the certificate.

(3) After that, the aerodrome operator should consider the results of its safety (risk) assessments and of its past compliance monitoring activities, in order to adapt the calendar period within which an audit or a series of audits should be conducted, to cover the whole aerodrome, its management system key processes, procedures and its operation in a manner, and at intervals set out in the aerodrome manual. This calendar period, should be consistent with the relevant competent authority’s oversight planning cycle and may be increased, up to 36 months, in coordination with the competent authority, provided that there are no level 1 findings, and subject to the aerodrome operator having a good record of rectifying findings in a timely manner.