There’s an increasing trend for national aviation authorities (NAAs) in some states to subject organisations to ‘re-certification’. This can affect any organisation approved or certified by the NAA but particularly AOC holders (airlines and charter companies) and ATOs (pilot training organisations).
Why is this happening?
The requirement for ‘re-certification’ usually follows an external audit of the NAA by ICAO or EASA. During the external audit the NAA will have been asked to show how it has established that an operator is compliant with the applicable requirements, and won’t have been able to. This might be because the original certification wasn’t conducted properly or because proper records weren’t kept. It might also be because there are no proper records of ‘continued oversight’. In some jurisdictions the regulations may have changed and there isn’t evidence that certified organisations have adapted to the new rules.
The organisation to be ‘re-certified’ will be required to go through the complete application process as if they were applying for an AOC or ATO for the first time. The detail of this process will vary from one state to another. Most NAAs will ask the organisation to submit a compliance statement, showing how they comply with all of the applicable rules. In order to produce this compliance statement the organisation will need to produce a checklist of all the applicable regulations and record how they comply with every one of them. This checklist will probably include a thousand or more individual items. The NAA will then check the compliance statement against the organisation’s documents (operations manuals etc.) before moving onto a ‘demonstration phase’ where they will conduct on-site audits and inspections as well as observing actual flights and training events.
The good news is that the organisation will be allowed to continue operating while the re-certification takes place; the bad news is that there’ll almost certainly be a time limit by which the re-certification needs to be completed if the approval (AOC or ATO certificate) is to be renewed.
Having to go through re-certification will incur extra work and extra expense for any organisation. Unless you already have an excellent compliance monitoring process (quality system) in place then putting together a compliance checklist and preparing for the inspection phase will involve hundreds of ‘person-hours’ of extra work. The end result will only be that your organisation holds the same approvals that it had at the beginning of the process.
What’s the benefit?
The benefit is enormous. If your NAA is taking this action then it’s because there have been serious non-conformities within the Authority. If these aren’t corrected then it could affect whether other states accept certificates and licences issued by your NAA. For an airline this could mean an increased frequency of ramp inspections or even restrictions on where you fly. For a pilot training company this could affect where pilots that you have trained can use their licences and how potential customers view your organisation.
The benefits aren’t only external. If your organisation is subject to re-certification then you should treat the process as a ‘reboot’ for your compliance monitoring system. You’ll discover some issues along the way, which should help the organisation to improve, and by the end of the process you’ll have established that every aspect of your operation is compliant. This gives you the tools to put in place a long-term process that reviews every part of the operation over a period of time and ensures continued compliance. This same compliance monitoring can be used to ensure that company policies and procedures are implemented as well as the external regulations.
If your organisation is expecting to go through re-certification then get in touch with McKechnie Aviation. Our consultants have been through the process from the point of view of both regulators and industry. We can take some of the burden off your management team by helping with the compliance check or by ‘project managing’ the whole process. Most importantly we’ll ensure that the process helps your organisation and leaves you with a better management system.