CAA Standards Doc 36?

[Happy Wanderer]

Standards doc 36 (guidance criteria for the approval of FTOs offering modular courses CPL, IR etc) is shown as CANCELLED on the CAA website. Can someone please point me in the direction of a suitable substitute or replacement (EASA?) document and/or confirmation please as to whether JAR-FCL1 App 1a (FTOs for pilot licences and ratings) still applies in whole or in part. I'm particularly interesting in FTO staffing and approval requirements.

Many thanks.
HW

[S-Works]

You can only apply to be an ATO now. Ths means you have to meet all the new ATO standards. There is an AMC for the approval and staffing requirements. I can't link to it at the moment unfortunatly.

[Whopity]

Try Part ORA and the AMC (http://www.easa.europa.eu/agency-measures/docs/agency-decisions/2012/2012-007-R/Annex%20to%20ED%20Decision%202012-007-R.pdf)

[BillieBob]

It seems to have become UK CAA policy to refuse to provide any assistance to organisations in understanding the increasingly arcane requirements. Appeals for clarification are met with, "You tell us how you intend to comply and we'll tell you whether we'll accept it". This could have something to do with the new charging structure which means that the less the organisations understand, the longer it takes to gain approval and the more revenue flows to the Authority.

[S-Works]

Or it demonstrates a fundamental lack of understanding on how its supposed to be by the very people responsible. So they are hoping we will show them the way while paying for the privilege of educating them.

You only have to look at the industry they are making out of the SMS.

[BigEndBob]

Perhaps the problem is if 'they' provide what is required, and something bad happens, then 'they' get the blame. Whereas if we supply what we think the requirement is and 'they' approve it, they can wash their hands of the consequences or can they? Perhaps their solicitors are still trying to work that one out thats why we have no real guidance.

[Happy Wanderer]

Thanks guys for the input. Initial observations around the issue of ATO staffing requirements (the bit I'm particularly interested in) suggests there hasn't been a huge advance on what was originally laid out in SD36 and JAR-FCL1. A case of rearranging the words maybe! Thanks anyway.

HW

[Capot]

"....fundamental lack of understanding on how its supposed to be by the very people responsible. So they are hoping we will show them the way while paying for the privilege of educating them.

You only have to look at the industry they are making out of the SMS."

You got that right. Sometimes we need to pinch ourselves as a reminder that the ENTIRE requirement set out by EASA for Safety Management is contained in Part ORO.GEN.200 sub-paras 2 and 3 among the other requirements for a Management System, and does not include "setting up an SMS".

Here it is in full;

(a) The operator shall establish, implement and maintain a management system that includes:
....

(2) a description of the overall philosophies and principles of the operator with regard to safety, referred to as the safety policy;

(3) the identification of aviation safety hazards entailed by the activities of the operator, their evaluation and the management of associated risks, including taking actions to mitigate the risk and verify their effectiveness;
....


That's it. There is nothing else. Simple to do. But the CAA has, as you say, managed to turn it into an industry.