AMC1 ORGH.MGM.200(b)(6) General requirements for the management system

COMPLIANCE MONITORING — INTERNAL AUDITS

(a) Compliance monitoring process

(1) The implementation of a compliance monitoring process should enable a GH organisation to monitor its compliance with the requirements of Annexes I and II to Commission Delegated Regulation (EU) 2025/20, as well as with any other applicable regulatory requirements and instructions and with procedures established by the aerodrome operator or the aircraft operator to which GH services are provided.

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

(3) Compliance monitoring should include a method of providing feedback on the findings to the accountable manager to ensure the effective implementation of corrective actions, as necessary.

(4) The GH organisation should monitor the consistent application of its operational procedures and their compliance with the applicable procedures of the aircraft operators to which it provides services and the aerodrome operator of the aerodromes where it operates. In doing so, the organisation will ensure that its activities are performed safely. The GH organisation should, as a minimum and where appropriate, monitor the compliance of the following elements with the applicable requirements:

(i) the declaration;

(ii) the SMS;

(iii) the training programmes;

(iv) the documents and records system, including the GH manual;

(v) the procedures for local operation contained in the aerodrome manual that are applicable to the GH organisation;

(vi) the GSE maintenance programme;

(vii) the GH activities of the organisation carried out under the supervision of the person(s) nominated in accordance with point ORGH.MGM.210(b)(3);

(viii) any activities outsourced in accordance with ORGH.MGM.205, for compliance with the contract.

(b) Organisational set‑up

(1) The accountable manager, as directly accountable for safety, should ensure, in accordance with point ORGH.MGM.210(a), that sufficient resources are allocated to compliance monitoring. When the person responsible for compliance monitoring also acts as the safety manager, the accountable manager should ensure that sufficient resources are allocated to both functions, taking into account the size of the GH organisation and the complexity of its activities.

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

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

(c) Compliance monitoring documentation

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

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

(i) terminology;

(ii) specified activity standards;

(iii) a description of the organisation;

(iv) the allocation of duties and responsibilities;

(v) procedures for ensuring regulatory compliance;

(vi) the compliance monitoring programme, reflecting:

(A) the schedule of the programme;

(B) audit and inspection procedures, including an audit plan that is implemented, maintained and continually reviewed and improved;

(C) reporting procedures;

(D) root cause analyses for findings identified during internal compliance monitoring activities;

(E) procedures for follow‑up and corrective action; and

(F) the recording system;

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

(viii) document control.

(d) Training

(1) To achieve optimum outcomes of training, the GH organisation should ensure that all personnel understand the training objectives, as set out in the organisation’s management system documentation.

(2) The persons responsible for the compliance monitoring function should receive training in this function. The training should cover the compliance monitoring requirements, the manuals and procedures related to the necessary tasks, auditing techniques, root cause analysis, reporting and recording.

(3) Time and resources should be allocated based on the volume and complexity of the activities concerned.

(e) Compliance monitoring — audit scheduling

(1) The GH organisation should establish audit schedules to be completed during a specified period, as well as a periodic review cycle for each audited area. The compliance monitoring itself should also be audited according to a defined audit schedule. Unscheduled audits should be possible to perform when non‑compliance data shows an increasing trend. The audits should follow up on corrective actions to ensure that they have been implemented, effective and completed, in accordance with the policies and procedures specified in the GH manual.

(2) The management system’s key processes and procedures and the operation of the GH organisation should be audited within the first 12 months from the date when the declaration was first registered.

(3) Following that, the GH organisation should consider the results of its safety risk assessments and past compliance monitoring activities in order to adapt the planning cycle for its compliance monitoring activities to cover its management system’s key processes, procedures, training and operations. This planning cycle should not exceed 36 months or the duration of the oversight planning cycle established by the competent authority for each organisation (whichever is shorter).