Operations Manuals for aircraft operators
Commercial aircraft operators and non-commercial operators flying complex motor-powered aircraft must have an Operations Manual (OM).
Commercial air transport operators must submit this manual to the competent authority and show that it complies with all applicable regulations before being issued with an air operator’s certificate (AOC). Non-commercial and specialised operators (aerial work) do not need to have their manuals approved before starting operations but have the same responsibility to maintain an accurate and up-to-date OM.
The OM is not a single document; it usually consists of a suite of several large volumes.
Purpose of an Operations Manual
The OM should contain “all necessary instructions, information and procedures for all aircraft operated and for operations personnel to perform their duties”. A good OM will give clear instructions for company personnel to follow, including, where necessary, detailed step-by-step procedures. The regulations say, “the content of the OM shall be presented in a form that can be used without difficulty”.
The OM must be aligned with the regulations. Personnel following the procedures in the OM need to know that they won’t break any regulations. A difference between the OM and regulations does not provide an excuse to deviate from the regulations, even if the competent authority has accepted the OM.
The OM needs to do more than reproduce the regulations; it needs to include instructions for personnel. A good OM will describe what to do and how to do it.
The OM must be submitted to the competent authority, and parts must be approved, but the manual is not for the authority. It’s for operator personnel so that they know how to do their jobs.
Content of an Operations Manual
An OM includes instructions and information for pilots to fly aircraft and the other information necessary to operate the aircraft. This means everything from flight planning, passenger handling and ground operations to security procedures, health precautions, and flight time limitations.
As well as describing how aircraft are operated the OM also describes the aircraft operator’s organisation. This includes the corporate structure, duties and responsibilities of personnel, safety policy, risk management, compliance monitoring and emergency response.
Each operator’s OM should be specific to their operation. The OM should provide all the instructions that personnel need. For example, a section on aeroplane de-icing procedures should describe which fluids can be used, how they should be applied and how long the protection is expected to last. The OM should not include information that’s not relevant to the operation. If an operator is not approved for CAT III approach operations, then CAT III procedures should not be in the OM (there might be a statement that “CAT III operations are not permitted”).
Structure of an Operations Manual
The regulations for commercial air transport require that an OM includes four parts (A, B, C, D) and includes information about safety management and compliance monitoring. Non-commercial and specialised operations are allowed more flexibility for the structure of the OM.
OM-A contains policies, procedures and operating instructions that are not specific to a particular aircraft type. Some of this information is about the organisation, such as the corporate structure and duties and responsibilities of personnel, whereas other information is about flying the aircraft, such as how much fuel should be carried on a flight.
Most of the information in OM-A is relevant to the flight crew and other operational personnel. Parts of OM-A are only applicable to management personnel, for example, policies and procedures for aircraft leasing.
OM-B contains detailed operating procedures for aircraft, including type-specific procedures. An operator that has several aircraft types will publish a separate OM-B for each type.
OM-B is used by the pilots (normal and abnormal/emergency procedures). It will also be used by operations personnel involved in preparing a flight (flight planning and aircraft loading). Cabin crew procedures should be in OM-B, but cabin crew may be issued with an abbreviated version.
The minimum equipment list (MEL) is part of the OM-B, but this is usually published as a separate volume.
OM-C contains route and aerodrome information. Most operators use a commercial flight guide (e.g., Jeppesen, Lido) for at least part of OM-C. Pilots refer to these for operating procedures for different routes, airports or areas.
The OM-C should also contain a list of aerodrome categorisations (A, B or C).
OM-D is the training manual. It describes the various training programmes for flight crew, cabin crew, instructors and other operational personnel. OM-D is primarily used by instructors and other people who deliver training.
An operator is required to include information about safety management in the suite of manuals. This might be in OM-A but, since some of the information is specialised, many operators prefer to publish a separate SMS manual. The safety management documentation should include policies and procedures for safety risk management, safety performance measurement, and safety promotion. There should also be an emergency response plan (ERP).
The SMS manual is primarily used by management personnel responsible for the safety of various aspects of the operation (e.g., the ‘nominated persons’). Some information, such as the safety policy and reporting procedures, should be available to all personnel, so these are often included in OM-A.
COMPLIANCE MONITORING MANUAL
Aircraft operators must have a programme of internal audits and inspections to verify that the operation complies with all the applicable regulations and requirements. This programme and the associated procedures are often described in a separate compliance monitoring manual (or quality manual).
ORGANISATION MANAGEMENT MANUAL
Some operators have adopted an organisation management manual (OMM). This is usually a combination of the SMS manual and compliance monitoring manual. Sometimes the OMM also includes organisational information from OM-A, such as the organigram and description of duties and responsibilities of management personnel. OMM is not mentioned in regulations, but it can be an acceptable way to present the required information. The primary users of an OMM are managers.
Distribution of an Operations Manual
All personnel need to have access to the parts of the OM that are relevant to their jobs. This includes sub-contracted personnel involved in the operation such as ground handlers and instructors. Crew members should also be issued with personal copies of the OM.
Electronic distribution makes it straightforward to ensure that everyone who needs it has access to the OM. Specialised software is available for this purpose but simple IT tools using ‘cloud’ services can be equally effective. Whatever system is used there must be procedures to ensure that a current version of every part of the OM is available. Crewmembers, and other personnel, must have the discipline to update their copies of the OM and review any changes before each duty.
Aircraft manufacturers' documents in an Operations Manual
Aircraft manufacturers have to produce an ‘Aircraft Flight Manual’ (AFM) for every aircraft. The AFM describes the capabilities of the aircraft, operating limitations and procedures. The AFM is approved as part of the process of issuing a ‘type certificate’. An aircraft is only approved to fly if the limitations and procedures in the AFM are respected. An OM must be fully compatible with the AFM.
Most aircraft manufacturers do not write the AFM in a style intended for daily use by the flight crew and operational personnel, so they also produce additional documents describing how to operate the aircraft. These documents may include a Flight Crew Operating Manual (FCOM), Pilots Operating Handbook (POH) and supplementary documents such as a load and balance manual or performance manual. If an aircraft operator wants to follow the aircraft manufacturer’s operating procedures, these documents can be incorporated into the OM. Unlike the AFM, these documents (FCOM, POH etc.) are not approved by any authority; the aircraft operator is responsible for operating procedures. An operator who wants to use operating procedures developed by the aircraft manufacturer can issue the FCOM to the pilots. The FCOM then forms part of OM Part B, specifically the limitations, normal, and non-normal operating procedures (OM-B chapters 1, 2 and 3). The operator remains responsible for these procedures so, whenever the manufacturer makes amendments to the FCOM, the operator reviews the changes, decides if they are still suitable for their operation, and, if they are, issues the amended manual to the flight crew.
It’s a bad idea to have information about one topic spread over different volumes of the manual. If you expect pilots to use the FCOM for normal procedures, it’s not helpful to also have a section about engine start in a separate OM-B or ask the pilot to refer to the AFM for engine starting limitations.
The FCOM doesn’t usually contain all the information that should be in OM-B. For example, each operator has its systems for performance calculations, flight planning and mass and balance, so the OM needs to describe the use of these systems.
Proprietary manuals in an Operations Manual (e.g., flight guides etc.)
Part C of the OM has route and airport information, including departure and arrival procedures, aerodrome facilities and operating minima. In the past, the large airlines collated and published this information themselves, but, in the 21st century, this is not practical or necessary. Companies such as Jeppesen or Lufthansa Systems (Lido) collate and publish all this information in commercially available flight guides. These flight guides are available either as printed documents or in electronic formats such as apps that can be used directly in the pilots’ ‘electronic flight bag’.
Most operators use these flight guides as an integral part of the OM. Regardless of who collates and publishes the information, the aircraft operator is responsible for the content, so there should be procedures to ensure that the information is accurate, reliable and up-to-date.
Updates and amendments
An OM needs to be regularly updated. The need for updates is driven by external changes such as amendments to regulation or aircraft manufacturer’s procedures or internal changes such as new destinations, updates to training programmes, or revised operating procedures.
The process for amending the OM should be described in the OM. The process should allow changes to be made quickly. This will usually involve a temporary amendment by the publication of a notice. Personnel check for new notices whenever they commence a duty, and these notices may override specific sections of the OM. The various volumes of the OM should be amended on a regular schedule, say once every six months. Any notices issued since the last amendment are incorporated into the scheduled amendment. For commercial air transport operators, the competent authority will review each amendment.
Aircraft operators must have an OM that reflects the requirements of the regulations, but it isn’t easy to do this in practice. The fact that the competent authority has reviewed an OM is not a guarantee of compliance.
When reviewing an OM, many competent authorities require the aircraft operator to submit a statement of compliance. This is typically a list of the applicable requirements and a reference to where, in the OM, each requirement is reflected. Such a compliance statement helps the inspector check that all required information is included, but it has limitations. Most regulatory requirements do not map neatly onto one section of the OM (if they did, there would be less need for an OM).
An OM that is fully compliant with regulations will quickly become outdated as regulations are changed, or new rules are introduced. Somebody within an operator’s organisation needs to monitor every change to regulation, determine whether the change necessitates an update to the OM, and then make the change to the correct sections(s) of the OM.
McKechnie Aviation LTD can assist with the production of a complete set of documentation for your operation including the OM.
Andrew made a valuable contribution to drafting new rules for all weather operations.Francisco Arenas Alvarino, Rulemaking Officer European Aviation Safety Agency (EASA)