GM1 ARGH.MGM.200(a)(2) Management system

SUFFICIENT PERSONNEL

(a) This GM for the determination of the required personnel refers to the personnel of the competent authority required to fulfil oversight and enforcement responsibilities.

(b) The elements to be considered when determining the necessary personnel and planning their availability can be quantitative or qualitative:

(1) quantitative elements:

(i) the number of organisations providing GH services, which have declared their activity to the competent authority;

(ii) the number of Member States and number of stations where the GH organisation provides services; and

(iii) the number of planned audits and inspections;

(2) qualitative elements:

(i) the size and complexity of the organisations responsible for the provision of GH services, taking into account:

(A) the range of GH services provided by an organisation,

(B) whether a GH organisation provides services locally (at one or more aerodromes in the same Member State) or in more than one Member State,

(C) organisational structure, existence of subsidiaries and number of contracted activities,

(D) whether an organisation is an independent GH service provider, an aircraft operator performing self-handling or providing GH services as an independent GH organisation, or an aerodrome operator providing GH services,

(E) whether a GH organisation or a self-handling aircraft operator is part of a single GH organisation business grouping or a single air carrier business grouping;

(ii) complexity of the GH services provided; for example, the complexity of aircraft exterior cleaning services in comparison with aircraft turnaround coordination or aircraft ground de-icing/anti-icing;

(iii) the safety priorities identified;

(iv) 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) time frame for the implementation of corrective actions, and

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

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

(c) It is recommended gathering the following data to assess the required number of GH inspectors and their planning:

(1) standard number of audits to be performed to complete the full oversight scope;

(2) standard duration of an audit;

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

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

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

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

(d) 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).

(e) Spreadsheet software may be used to process data defined under points (c) and (d), to assist in determining the total number of working hours/days per oversight planning cycle required for oversight and enforcement activities. Such software could also serve as a basis for implementing a system for planning the availability of personnel.

(f) The following activities can be considered when determining the number of working hours/days per planning period for each qualified inspector:

(1) purely administrative tasks not directly related to oversight,

(2) training,

(3) participation in other projects or tasks, such as oversight in other aviation domains,

(4) planned absence, and

(5) a reserve for unplanned tasks or unforeseeable events.

(g) The elements listed above will enable the competent authority 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 qualifications of personnel and the required extent of oversight activities.