Non-complex Approved Training Organisation

Guidance for Compliance Monitoring Audits, Findings

and Audit Scheduling

The attached information has been written with the purpose of being complementary to the CAA
ATO Template Manual. They provide an example of a Compliance Monitoring checklist / audit report
that could be utilised by a small ‘non-complex’ ATO offering training for the LAPL, PPL and associated
ratings. Also included is a sample Findings form which also enables corrective and preventative
actions to be tracked and, finally, a sample audit schedule.

It should be noted that the audit checklist / report has been designed around the regulatory
requirements laid down in Part ORA and the content of the CAA ATO Template Manual. Whilst ATOs
may adopt the checklist in part or as a whole it is the Organisations responsibility to ensure that all
content is appropriate for their own purposes. Furthermore, it is envisaged that the individual items
and audit questions should be enhanced and further developed over time to adapt the audit more
specifically to the activity of the ATO in question. If the ATO employs any Flight Synthetic Training
Devices during it’s training courses, the checklist / report should be enhanced to include items on
such devices. The Authority can provide further guidance if required.

The Audit finding form has been designed to provide not only a notification of any issues found
during the audit, but also the agreed action to correct the issue and prevent a re-occurence. It also
enables the ATO to show that the effectiveness of corrective / preventative actions has been
verified. The categories of findings on this form should be based upon the EASA standard definitions
as per Part ARA, as follows:-

A level 1 finding shall be issued by the competent authority when any significant non-compliance is
detected with the applicable requirements of Regulation (EC) No 216/2008 and its Implementing
Rules, with the organisation’s procedures and manuals or with the terms of an approval or certificate
which lowers safety or seriously hazards flight safety.
The level 1 findings shall include:
(1) failure to give the competent authority access to the organisation’s facilities as defined in
ORA.GEN.140 during normal operating hours and after two written requests;
(2) obtaining or maintaining the validity of the organisation certificate by falsification of submitted
documentary evidence;
(3) evidence of malpractice or fraudulent use of the organisation certificate; and
(4) the lack of an accountable manager.

A level 2 finding shall be issued by the competent authority when any non-compliance is detected with
the applicable requirements of Regulation (EC) No 216/2008 and its Implementing Rules, with the
organisation’s procedures and manuals or with the terms of an approval or certificate which could
lower safety or hazard flight safety.

The sample Compliance Monitoring program schedule gives an example of how the different
elements of the audit may be split over the calendar year. However, it is entirely acceptable for all
elements to be conducted in a single audit. It is recommended that a single audit in conducted well in
advance of the Authority conducting ATO Oversight visits as it will enable the ATO to deal with any internal
findings, thus proving the effectiveness of their own system.
 COMPLIANCE MONITIORING AUDIT CHECKLISTS –
MANAGEMENT & ADMINISTRATION

# SUBJECT  / X REMARKS
MANAGEMENT AND ADMINISTRATION
1 Does the management structure accord
with the ATO Operations Manual?
(insert OM reference here)
2 Is the Head of Training suitably approved
by the Authority?
AMC 2 ORA.ATO.210 (a)
3 Is the Chief Flying Instructor properly
qualified?
AMC 2 ORA.ATO.210 (b)
4 Does the Accountable Manager have
overall responsibility for the ATO, is he
qualified and approved.?
ORA.GEN.200 (a)
5 Is the Safety Manager qualified / trained
and approved.?
AMC 1 ORA.GEN.200 (c) Management system
6 Are sufficient Flight and Ground
Instructors employed to maintain
satisfactory student instructor ratios?
7 Is the Safety Management System
promoted among the staff?
AMC 1 ORA.GEN.200 (a) (2) (3) Management
system
8 Are the Flight Instructors properly
qualified and current?
9 Have the senior management and staff
received SMS training?
AMC1 ORA.GEN.200 (a) (4)
Management system
SMS Manual reference?
10 Are the safety management meetings
documented in accordance with the SMS
manual?.
SMS Manual reference?
12 Are the Training Manuals up to date,
pertinent and in the correct format?
AMC1 ORA.ATO 230 (a) Training manual.
13 Is the training programme to the correct
format and freely available to staff and
trainees?
AMC1 ORA.ATO.125
14 Is the Operations Manual up to date and
pertinent to the ATO operation?
AMC1 ORA.ATO 230 (b) Training manual.
16 Is there an effective system for checking
that students fulfil all requirements before
entering training?
AMC1 ORA.ATO.145 Pre-requisites for
training
17 Is there an effective Management System
within the ATO?
AMC1 ORA.GEN.200 (a) (4) Management
system
18 Are the instructors duty and training hours
in accordance with the operations
manual?
Operations manual reference?
19 Are the trainee duty and training hours in
accordance with the operations manual?
Operations manual reference?
20 Are the Operations and Training Manuals
made available to all staff and trainees
and is there a system to ensure that both
groups are familiar with the contents?
Management System 1.2.12
FACILITIES AND ACCOMODATION
1 Is there adequate and properly equipped
Flight Operations accommodation?
AMC” ORA.GEN.215 (a) Facility requirements
2 Are there adequate numbers of briefing
and lecture facilities available for the
number of students?
AMC” ORA.GEN.215 (a) (2)
3 Do trainees have free access to flight
planning information. (AIP, AICs,
NOTAMS, Weather, etc.)
AMC” ORA.GEN.215 (a) Facility requirements.
4 Do trainees have free access to ATO
publications (Operations Manual and
Training Manuals)?
AMC” ORA.GEN.215 (a) Facility requirements
5 Are all operations, training and planning
documents up to date and pertinent to the
courses provided?
AMC” ORA.GEN.215 (a) Facility requirements.
6 Does the aerodrome meet the published
requirements and is suitable to
accommodate flight training?
AMC1 ORA ATO140
AIRCRAFT AND EQUIPMENT
1 Are the aircraft used for training equipped
and maintained to a suitable standard
(Record registration of those aircraft
which were checked)?
AMC1 ORA.ATO.135 Training aircraft.
2 Are the aircraft documents correctly
maintained and available to the PIC for
inspection?
Operations manual reference
3 Are aircraft defects recorded and in
accordance with the operations manual?
Operations Manual reference?
4 Are there suitable RT training and testing
facilities within the ATO?
AMC1 ORA.GEN.215 Facilities
5 Does a process exist whereby the Head
of Training ensures that new training
aircraft are suitable for the intended
training course?
6 Does the process ensure that the CAA
are notified of new training aircraft?
7 Are Tech Logs / Flight Authorisation
sheets completed fully and accurately?
Operations Manual Reference?
8 Do all aircraft contain the relevant
documentation
Operations Manual 1.10.2
FLIGHT AND THEORY TRAINING
1 Was the published training programme
followed both as to total hours and order
of exercises? (Record names of those
trainees whose records were checked)
AMC ORA.ATO.120 (a) (b)
2 Were training records correctly and fully
completed? (Record names of those
trainees whose records were checked)
AMC1 ORA.GEN 220 (b) Record keeping.
3 Are the training records retained for the
required duration?
AMC1 ORA.ATO.120 (a) (b)
4 Were skill tests conducted by a qualified
examiner not connected with the
candidates training?
5 Were all trainees invited to complete a
customer feedback form/course critique?
Your reference?
6 Are the ground school hours recorded for
the LAPL/PPL?
AMC ORA.ATO.120 (a) (b)
7 Do all trainees records show evidence of
classroom instruction for the theory
training?
AMC1 FCL115; FCL120 LAPL
AltMoC1 FCL210; FCL215 PPL
Training Manual reference?
8 Do the training records comply with the
format specified in the Training Manual
appendices?
9 Are all trainees formally assessed as
having sufficient knowledge of the
relevant syllabus prior to entry to the
Theoretical Knowledge Examinations?
Training Manual reference?
10 Were minimum flight training hours
achieved for all trainees?
FCL110A or FCL210A
11 Where trainees were identified as
requiring further training was the
procedure followed as per the manual?
Training Manual reference?
12 Were all training flights authorised in
accordance with the company procedure?
Operations Manual 1.5
13 Is there evidence that emergency drill and
essential safety exercises are being
taught in accordance with the training
plan?
Training Manual Para 1.7
14 Did the student meet all specified
requirement before:-
1) First solo
2) First solo cross-country
Training Manual Paras 1.7.4 / 1.7.5
15 Was SRG Form 2128 completed,
recommending the trainee for the licence
skills test, prior to the event?
FCL.030b and Training Manual 1.8.3
INSTRUCTOR STANDARDISATION
1 Is there an effective method of assessing
and maintaining instructional standards?
Operations manual Section 4
2 Is there an effective standardisation and
staff training program in accordance with
the Operations manual?
Operations manual Section 4.
3 Are the instructors logbooks kept up to
date and in accordance with the
Operations manual?
AMC1 FCL 050 (a)
Operations manual reference?
4 Does the ATO submit to the CAA and
maintain a list of Examiners for the
conduct of the skill tests?
Training Manuals reference?
5 Is instructor initial, refresher and
standardisation training conducted in
accordance with the published
procedures?
Operations Manual Part 4
COMPLIANCE MONITORING SYSTEM
1 Are audits being completed in accordance
with the program specified in the
Compliance Monitoring System?
CMS reference?
2 Is the auditor independent of the area(s)
which are being audited?
AMC1 ORA GEN 200(a)(6) Para c6
3 Do the audits completed cover all aspects
of the ATO, specifically the Regulatory
requirements and internal procedures?
AMC1 ORA GEN 200(a)(6) Para b
4 Where previous audits identified non-
conformances, have these been resolved
in a timely manner?
5 Where corrective or preventative action
was identified on previous findings, has
this subsequently been checked and
found to be effective?
6 Where any changes requiring prior
approval of the Authority have been
identified, was approval sought?
Organisation Manual, Para 1.2.6
7 Is there an effective system for document
control in place?
AMC1 ORA.GEN.200 (b) (5)
8 Are document / version control
procedures being followed when manual
revisions are made?

Audit conducted by (print name) Position held

Signature Date
Audit Ref: Non-Conformance / finding Date:
Insert reference for the audit No.(unique # for this finding) (date audit took place)

Non-Conformance / finding Ref (EASA /OM / TM / MS.): (what is it a finding against?)

Nature of Non-Conformance / finding
(describe what was founf and why it is a non-conformance)

Category of non- One Two Suggestion for

conformance/ finding improvement

Area of non-conformance / finding

Aircraft Publications

Accommodation Synthetic Training Devices

Course Material Training Programmes

Compliance Monitoring System Training Record

Document Control

Signed: (signature of person raising the Accepted: (HT should sign to agree / acknowledge
finding) finding)
Auditor Head of Training

Agreed Corrective Action

(What is intended to be done to fix the problem and prevent a re-occurence)

Agreed Completion Date: (when by) Person responsible: (who will do it?)
Corrective Action Verified as effective
(ideally the person who raised the finding should go back oafter the completion date and re-audit to see if the
problem has been fixed (the action was effective) and whether it has re-occured subsequently. This means the
auditor cannot have the issue assigned to him/her to actually fix the problem)

Date: (date re-auditted) CMM / Auditor: (by auditor)

Signed: Head of Training

SAMPLE COMPLIANCE MONITORING PROGRAM SCHEDULE

JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Management and X
Administration
Aircraft / X
Equipment
Facilities X
(classrooms /
airfield etc)
Training X
Programs and
records
Instructor X
Standardisation
Compliance X
Monitoring
System

The above is an example of how audits may be split across a calendar year. If the Organisation is very simple, with few employees, aircraft and facilities it is
acceptable to conduct the audit once annually, with all aspects of the operation checked on the same audit. If the organisation uses the services of 5+
instructors, has a number of aircraft, classrooms and has a high throughput of students it may be more appropriate to spread the various facets of the audit
schedule over several events per year.

However the audits are conducted it is recommended that it would be good practice to conduct audits several months before the Authority conducts
oversight audits. By doing so, the Organisation will have time to undertake corrective actions on any findings raised internally and re-audit to ensure no re-
occurence.