Tag: Part-NCC

Internal Auditing for Part-NCC Operators

EASA’s Part-NCC regulations and compliance need to be kept up-to-date continually. But what is the best way to make sure you are operating in accordance with what is defined in your manuals, policies and procedures? Recurring small internal audit tasks are an easy way to help keep your operation running smoothly and ensure you are ready when an auditor visits.

Why perform an internal audit?

Part-NCC, established by EASA, is a set of rules governing private aircraft operators of certain aircraft types. These rules outline requirements operators must meet including specifications for operations manuals, SMS, and compliance monitoring. For operators subject to Part-NCC, there is now the possibility of being audited by their respective national aviation authorities at any time. It is therefore critical to always stay up to date and compliant.

Performing internal audits will help ensure you are better prepared for an external audit by confirming that you are operating in accordance with regulations and what you have defined at all times. The audit tasks will check that you are conforming to the latest regulatory guidance and that you are following the procedures defined in your manuals. Expanding the internal audit beyond regulations to include your operational authorizations, approvals, exemptions, and manuals will not only ensure you are following them, but also provide you with the opportunity to ensure they are still appropriate for your operation in their current form. Implementing smaller recurring checks will help you remain on top of things as changes occur, so you don’t have to worry about updating everything all at once with a backlog of revisions.

In essence, the point of internal audits is to discover what needs to be changed and then actually making those changes. It’s the perfect opportunity to improve your organization, without automatically having to rely on an external person coming in to help you.

How do you do an internal audit?

As a best practice, internal audits should be performed throughout the year with the participation of multiple parties so the program becomes an easily manageable part of your operation. Start by creating a book of audit tasks.

Each operation is different and your book of audit tasks should be customized to how your company operates. Using standards, policies, and procedures outlined in your manuals and documentation, write a task that asks the reviewer to assess whether there is any discrepancy between what’s written and what’s actually being executed. Be sure to include a list of relevant documents the person performing the task should have on hand, such as manuals, training records, flight logs, operational authorizations, exemptions, etc., to make the auditing process simpler.

Most tasks should be written so that anyone in the company can perform them. This allows the work to be divided among all of the team members so they feel part of the operation’s improvement efforts and thus also ensuring the work does not end up solely with the Safety Manager or Chief Pilot.

After you have created your book of audit tasks, create a manageable system by splitting the tasks up into bite-size clusters to be performed periodically (e.g., monthly, quarterly, etc.). It’s easier to create an ongoing process of minor course corrections throughout the year than perform one large annual review. As the scheduled audit task dates approach, assign one or two tasks to various team members. After each person completes their assigned task, they should document their findings.

What do you do after your internal audit?

Once you’ve completed your audit, hopefully, the results show that everything is running smoothly and that your operation is complying with the regulations and following your own defined policies and procedures. But sometimes an audit can uncover issues, such as a necessary procedural update or new training requirements, which could affect the operations manual or the safety management system.

If there are discrepancies found, be sure to investigate the root cause of the discrepancy so that you can determine and implement corrective actions. Set a reminder to re-evaluate the corrective actions at a later date to ensure they have had the desired effect. Keep in mind that in some cases you may find that it is not the operation that is at fault, it’s your documents that need to be changed. This may be especially true if you have recently gone through any significant operational changes.

If your operation is not compliant, you run the risk of being grounded. So, make those spot-checks a regular part of your operation.

Take a look at our Internal Audit Program to help make self-audits easier. We can also help with Part-NCC compliance questions. Don’t hesitate to get in touch!

Key Issues Facing International Flight Operators to and from Europe

With the 2018 European Business Aviation Conference and Exhibition (EBACE) taking place this month, all eyes in the business aviation industry will be focusing on Europe. We thus wanted to share the key issues flight operators need to keep in mind when traveling to and from Europe.

Regulatory Compliance

2018 has ushered in some significant changes that impact the business aviation industry. For those operating to and from Europe, the two key regulatory issues to keep in mind are:

  • The 2018 IS-BAO standard. Released at the beginning of 2018 in beta version, the go-live date is scheduled for July 1, 2018. It is a code of best practices designed to help flight departments worldwide achieve a high level of safety. If your manual has not been updated to the latest IS-BAO standards, and you have an audit prior to July 1, 2019, you should consider updating your FOM at least two months prior to your audit. We can include best practices and any revisions that you may have as part of a standard reissue.
  • Part-NCC. The European Union’s Part-NCC (Non-Commercial Complex) is a regulation aimed at enhancing safety, training and record-keeping protocols within Europe for companies flying complex corporate aircraft privately. With Part-NCC, it’s not about where the aircraft is registered, but where the operator of the aircraft is established or, in the event of an individual owner, resides. So, if you are a UK-based operator with a Cayman Island registered aircraft, you should be Part-NCC compliant for instance.

Customs

Customs can be a challenge for flight operators traveling to multiple European destinations. Each country and airport may have unique customs requirements, and managing those requirements for flight operators is critical to quickly and efficiently clear customs. The US is currently working on a customs compliance guide for private operators with hopes it will be commonplace within the next few years.

A key factor to keep in mind is ensuring passports or visas for all flight crew are current, and making sure visas especially – which may vary from country to country – are approved well in advance.

Weather

On Atlantic crossings, weather and volcanic activity become a significant factor and one that flight operators need to be prepared for. Temperature conditions, for instance near Greenland, may also make it challenging to maintain altitudes in certain aircraft.

Security

Flight operators need to stay vigilant when it comes to personal and IT security. With recent system hackings, it is crucial to ensure that flight (and personal) devices stay within your control and that malware is not downloaded. Breached network issues also apply to onboard Wi-Fi systems, so it is important that operators equip aircraft broadband access with secure networks.

Finally, regarding personal security, flight operators should establish an emergency plan that is ready to be implemented if a situation arises. This should include, for instance, an evacuation plan coordinated with passengers designating and communicating a meeting place.

To learn more about how AviationManuals can help support your efforts to achieve trouble-free flights to and from Europe, contact us today.

Europe Trip Planning Best Practices

There are key elements items operators should ensure they have covered before taking off to Europe. Non-European Union (EU)-registered aircraft operators are subject to SAFA (Safety Assessment of Foreign Aircraft) ramp inspections when operating in the EU member states plus Iceland, Norway, Switzerland, along with any state with which the European Aviation Safety Administration (EASA) has a working arrangement on SAFA. The biggest issues generally occur when inspectors come to the plane and the crew is not prepared. To avoid unnecessary complications, we are highlighting some key items you should be prepared to be able to show:

International Operations Manual

Operators should have an up-to-date International Operations Manual (IOM) to ensure they are conforming to current required procedures and industry best practices when operating across the Atlantic and within Europe. An IOM should include procedures for North Atlantic (NAT HLA), RVSM, PBN (RNP/RNAV), and, if equipped, Data Link procedures. For operations within Europe, the IOM should also include procedures for P-RNAV and B-RNAV, which covers RNAV operations in the enroute and terminal areas within Europe.

Operators should be aware that LOAs for each of these Special Areas of Operation are required, regardless of where the aircraft is based. The LOA must be issued with the name of the entity with operational control of the aircraft. In a case where more than one entity has operational control, separate LOAs must be obtained

MEL Compliance

Even though there are still ongoing discussions between the Federal Aviation Administration (FAA) and the European authorities, it is critical to note that FAA approval does not ensure international compliance when it comes to Minimum Equipment Lists (MEL), so we recommend erring on the side of caution for your trip.

One of the most important clarifications that operators must understand today is that it is no longer acceptable to use your MMEL as your MEL. Because an MEL is developed specifically for your aircraft, your fleet and your company, many European inspectors have now made it clear that they require an MEL.

This is because the MMEL does not contain the specific procedures or regulations that crews must follow. Additionally, EASA’s focus on performance-based standards included in the International Civil Aviation Organization’s (ICAO) Annex 6, Part 2, Chapter 2.5 requires operators to have information relevant to the airplanes required communication, navigation or communication specification capabilities included in the MEL. This standard requires the operator to take a broader view of specific equipment and its relationship to other systems and performance requirements.

Part-NCC Must be a Part of Your Pre-flight Arsenal

If you are an operator that either has an operating base in Europe or one outside any EASA country, then you also need to strongly look how you may fall under Part-NCC requirements. If you operate an aircraft registered in an EASA member state, or if your aircraft is registered in another country but your principal trip or regular business is to an EASA member state, your operations will be subject to Part-NCC.

As a business jet operator executing flight activities to Europe, you should prior to your trip verify at a minimum:

  • If you are subject to Part-NCC and, if in doubt, get a ruling from the competent authorities.
  • If you are subject to Part-NCC, determine which entity will be the operator under Part-NCC.
  • Start the compliance process with Part-NCC and apply for the specific approvals by the competent authority.
  • Declare the new activity and submit relevant documentations to the competent authority.

An SMS Program is Critical for Your Travel

You should also be prepared to demonstrate you have a Safety Management Systems (SMS) program in place and that it clearly outlines the Standard Operating Procedure (SOP) your flight crew executes. An SOP or a proper operations manual provides crews with the step-by-step guide to effectively and safely carry out operations. Many accidents occur because of the operating environments and individual operator behavior – the “Human Factor” – in the aviation community. Such causal factors of accidents aren’t common to all operators, but they must be examined with methods that are specific to the individual operator’s situation.

Specifically, one of the defining characteristics of an SMS is its emphasis on risk management within an operation. It provides inspectors with the ability to better see the relation between the common risk factors that are addressed by traditional aviation regulations and those that are more situational. ICAO Introduced requirements related to SMS back in 2009. It is important to note that EASA compliance is set to strengthen traditional risk control practices and ensure safety risks are managed in a systematic way – so be prepared prior to your trip.

AviationManuals Support

All of the documentation and procedures discussed are critical elements for any flight plan, but essential for travel to the EU. Flight operators should be able to demonstrate all of these are in place in the event of a ramp check. Contact AviationManuals if you have any questions or if you would like additional information.

Part-NCC is here – Are You Compliant?

The European Union’s Part-NCC (Non-Commercial Complex) is a regulation aimed at enhancing safety, training and record-keeping protocols within Europe for companies flying complex corporate aircraft privately. Yet, even though the regulation went into effect on August 25 2016, there remains considerable confusion within the industry.

Let’s try to shed some light on this complex issue.

First, let’s clarify who exactly is affected by Part-NCC. The answer to this comes down to who is the operator and where they are geographically located.

As to the first, although you would be forgiven for thinking that the operator is the owner, it’s not always that easy, since Part-NCC uses a much broader definition. According to the regulation, the operator is the person or entity that effectively manages and oversees the operation of the aircraft and who has the responsibility to commence, terminate or deviate the aircraft’s flight.

Once you determine who the operator is, the next step is to look at the geographic location of the operator. With Part-NCC, it’s not about where the aircraft is registered, but where the operator of the aircraft is established or, in the event of an individual owner, resides. So, if you are a UK-based operator with a Cayman Island registered aircraft, you should be Part-NCC compliant.

Isn’t IS-BAO Good Enough?

IS-BAO is a good starting point, but it only covers around 90% of what Part-NCC is looking for. So, while it’s certainly better than nothing, IS-BAO certification itself cannot be used to show full compliance with Part-NCC.

What About that Last 10%?

The challenge with becoming Part-NCC compliant is that it’s a complex regulation, and many small operators don’t know where to begin – let alone understand what’s required of them. This is a big reason why, nearly a year after coming into effect, compliance levels appear to remain low.

Though some aircraft management companies offer Part-NCC compliance plans, they aren’t usually the best fit for operators. Other solutions are simply software platforms that do not provide sufficient content, regulatory or editorial support. Most operators do not have the financial resources to afford the aircraft management company solutions or the personnel and editorial skills to simply subscribe to a software platform that does not provide any real guidance on regulatory content.

Many operators are thus seemingly taking a wait and see approach, potentially a risky bet.

A Part-NCC Service That Fits Your Operation

To help private aircraft operators comply with all new European regulations, including Part-NCC, AviationManuals has developed affordable, customized solutions. An operator needs to do little more than participate in online development sessions. We take care of providing, managing and editing all Part NCC requirements and more. Our packages include ICAO (International Civil Aviation Organization) Annex 6 Part II content, EASA Part NCC Compliance Content, IS-BAO Standards and Protocols, industry Best Practices, Policies and Procedures and input from literally hundreds of operators and auditors.  It is a simple and affordable process for all operators regardless of size and resources.

Learn more about our Part-NCC service.