What’s an NCC Audit?
Since 2016 private aircraft operators in Europe have had to comply with regulations for the ‘non-commercial operation of complex motor-powered aircraft’. As well as ramp checks the European Aviation Authorities are now conducting inspections and audits of these operators at their operating bases.
Why are the authorities auditing private operators?
The regulations require Authorities to conduct inspections or audits of all operators who have submitted a declaration to them. Each operator should be audited at least once every four years, but inspections could be more frequent, depending on the Authority’s risk assessment.
What will the Authority be checking?
An NCC audit could check compliance with any aspect of the regulations, but the most likely topics are probably the following:
Manuals: The Authority will check that there is a complete set of Operations Manuals and they may check that the contents are in accordance with the regulations.
Training records: There should be records to show that Flight Crew and Cabin Crew (if applicable) have completed all the required training. These records should go back 3 years.
Flight records: Operational flight plans, loadsheets, and journey logs should be available for any flights conducted in the preceding three months.
Safety Management: The authority will need to see evidence that the operator has implemented a safety management system. They’ll be looking for a safety policy and records of hazard identification, risk assessments and actions taken.
Internal Audits: NCC operators are required to have a compliance monitoring programme including internal audits and audits of any sub-contractors. The Authorities will want to see the audit programme, records of audits carried out and any action taken as a result of the audits.
Specific Approvals: The Authority may take a particular interest in the procedures and records relating to any ‘specific approvals’ the operator holds, such as low visibility operations, dangerous goods or MNPS.
Will the Authority conduct check flights?
The Authorities have a programme of ramp inspections, where they’ll check aircraft, equipment and documentation before or after flights. At least one Authority has also conducted some ‘flight inspections’ on non-commercial operators but there is nothing in the regulations that requires non-commercial operators to allow Inspectors to fly on their aircraft. These inspections are ‘invitation only’.
What if we’re not ready?
If the Authority finds any non-compliances during an NCC audit, then the operator will be notified and given time to correct the issues. If a non-compliance ‘lowers safety or seriously hazards flight safety’, then the Authority could prohibit an aircraft from flying. The best defence is to have an effective compliance monitoring programme so that any issues are identified and corrected before they come to the attention of the Authorities.
If your NCC operation doesn’t have compliance monitoring in place, then McKechnie Aviation can arrange this for you. For small operators a comprehensive audit programme would only require a few checks each year with much of the work being completed off-site. Contact us for more information.