GM1 ARA.GEN.200(a)(2) Management system

ED Decision 2018/009/R

SUFFICIENT PERSONNEL

(a)     This GM on the determination of the required personnel is limited to the performance of certification and oversight tasks, excluding personnel required to perform tasks subject to any national regulatory requirements.

(b)     The elements to be considered when determining required personnel and planning their availability may be divided into quantitative and qualitative elements:

(1)     Quantitative elements:

(i)      the estimated number of initial certificates to be issued and declarations to be received;

(ii)     the number of:

(A)     organisations certified by the competent authority; and

(B)     organisations having declared their activity to the competent authority;

(iii)     the number of persons to whom the competent authority has issued a licence, certificate, rating, authorisation or attestation;

(iv)     the estimated number of persons and organisations exercising their activity within the territory of the Member State and established or residing in another Member State.

(2)     Qualitative elements:

(i)      the size, nature and complexity of activities of certified and declared organisations as well as FSTD qualification certificate holders (cf. AMC1 ORA.GEN.200(b)), taking into account:

(A)     privileges of the organisation;

(B)     type and scope of approval or declared activities, multiple certification or declaration;

(C)     possible certification or declaration to industry standards;

(D)     types of aircraft / flight simulation training devices (FSTDs) operated;

(E)     number of personnel; and

(F)     organisational structure, existence of subsidiaries; 

(ii)     the safety priorities identified; 

(iii)     the results of past oversight activities, including audits, inspections and reviews, in terms of risks and regulatory compliance, taking into account:

(A)     number and level of findings;

(B)     timeframe for implementation of corrective actions; and

(C)     maturity of management systems implemented by organisations and their ability to effectively manage safety risks, taking into account also information provided by other competent authorities related to activities in the territory of the Member States concerned; and

(iv)     the size and complexity of the Member State’s aviation industry and the potential growth of activities in the field of civil aviation, which may be an indication of the number of new applications and declarations as well as changes to existing certificates and declarations to be expected.

(c)      Based on existing data from previous oversight planning cycles and taking into account the situation within the Member State’s aviation industry, the competent authority may estimate:

(1)     the standard working time required for processing:

(i)      applications for new certificates (for persons, organisations and FSTD qualification);

(ii)     new declarations;

(2)     for each planning period, the number of:

(i)      new certificates to be issued;

(ii)     declarations to be received; and

(iii)     changes to existing certificates and declarations to be processed;

(3)     the number of changes to existing certificates to be processed for each planning period.

(d)     In line with the competent authority’s oversight policy, the following planning data should be determined specifically for each type of organisation certified by the competent authority ining the AMC & GM to the implementing rules of Commission Regulation (EU) (approved training organisations (ATOs) and aero-medical centres (AeMCs)) and for FSTD qualification certificate holders as well as for declared training organisations:

(1)     standard number of audits to be performed per oversight planning cycle;

(2)     standard duration of each audit;

(3)     standard working time for audit preparation, on-site audit, reporting and follow-up, per inspector;

(4)     standard number of ramp and unannounced inspections to be performed;

(5)     standard duration of inspections, including preparation, reporting and follow-up, per inspector;

(6)     minimum number and required qualification of inspectors for each audit/inspection. 

(e)     Standard working time could be expressed either in working hours per inspector or in working days per inspector. All planning calculations should then be based on the same unit (hours or working days).

(f)      It is recommended to use a spreadsheet application to process data defined under (c) and (d), to assist in determining the total number of working hours / days per oversight planning cycle required for certification, oversight and enforcement activities. This application could also serve as a basis for implementing a system for planning the availability of personnel.

(g)     For each type of organisation certified by the competent authority, FSTD qualification certificate holders and declared training organisations, the number of working hours/days per planning period for each qualified inspector that may be allocated for certification, oversight and enforcement activities should be determined, taking into account:

(1)     purely administrative tasks not directly related to oversight and certification; 

(2)     training;

(3)     participation in other projects;

(4)     planned absence; and

(5)     the need to include a reserve for unplanned tasks or unforeseeable events.

(h)     The determination of working time available for certification, oversight and enforcement activities should also consider:

(1)     the possible use of qualified entities; and

(2)     possible cooperation with other competent authorities for approvals and declarations involving more than one Member State.

(i)      Based on the elements listed above, the competent authority should be able to:

(1)     monitor dates when audits and inspections are due and when they have been carried out;

(2)     implement a system to plan the availability of personnel; and

(3)     identify possible gaps between the number and qualification of personnel and the required volume of certification and oversight.

Care should be taken to keep planning data up-to-date in line with changes in the underlying planning assumptions, with particular focus on risk-based oversight principles.