GM1 21.B.25(a)(2) Management system

SUFFICIENT PERSONNEL

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

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

(1) Quantitative elements

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

(ii) the number of organisations to be certified by the competent authority;

(iii) the estimated number of subcontracted organisations used by certified organisations.

(2) Qualitative elements

(i) the size, nature, and complexity of the activities of certified organisations, taking into account:

(A) the privileges of each organisation;

(B) the types of approval and the scopes of approval;

(C) possible certification to industry standards;

(D) the number of personnel; and

(E) the organisational structure and the 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) the number and the levels of findings;

(B) the time frame for the implementation of corrective actions;

(C) the maturity of the management systems implemented by organisations, and their ability to effectively manage safety risks; and

(iv) the size and complexity of the Member States’ 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 changes to existing certificates 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 applications for new certificates, approvals, authorisations or letters of agreement;

(2) the number of new certificates, approvals, authorisations or letters of agreement to be issued for each planning period; and

(3) the number of changes to existing certificates, approvals, authorisations or letters of agreement to be processed for each planning period.

(d) In line with the competent authority’s oversight policy, the following planning data should be determined:

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

(2) the standard duration of each audit;

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

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

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

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

(e) The 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 units (working hours or days).

(f) The use of a spreadsheet application is recommended to process the 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) 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 certification and oversight;

(2) training;

(3) participation in other projects;

(4) planned absences; 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, if applicable:

(1) the use of qualified entities;

(2) cooperation with other competent authorities for approvals that involve more than one Member State; and

(3) oversight activities under a bilateral aviation safety agreement.

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

(1) monitor the dates when audits and inspections are due, and when they were carried out;

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

(3) identify possible gaps between the number and the qualifications 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 a particular focus on risk-based oversight principles.