The latest FSTDs should have a primary reference document of CS FSTD (A).
The issue of Danish qualifications within the UK is somewhat interesting and of course clearly identifies the foreign operator in question.
ARA.GEN.105 20 “Principal place of business” is being abused by a certain foreign operator and is not being correctly enforced allowing non EU operations to operate within the EU and in this case the UK with apparent impunity and without any UK CAA oversight.
ARA.GEN.105 20 states that the “Principal place of business” means the head office or registered office of the organisation which the principal financial functions and operation control of the activities referred to in this Regulation are exercised. Clearly not!
Poorly maintained of poorly operating FSTDs are the sole responsibility of the FSTD operator. Their approved CMS determines maintenance and deferred defect practices as it is unrealistic for the TRE/TRI/SFI to know the contents of the applicable primary reference document and the relevant elements of Part-ORA. Additionally, today any Safety Hazards identified in training should be recorded and a means to record these be readily available to the instructor.
In theory, should an FSTD have a defect that takes its operational level below its qualification level, the operator should remove it from service. All defects must be recorded and deferred defect logs available for review by the instructor before commencing any training or checking as he/she is the only person that can determine whether the defect is detrimental to the particular training/checking detail.
The annual CMS audit by the NAA/EASA should test the robustness of these (and all other CMS/SMS) processes.
If this regulatory oversight is failing then the user does have recourse. Apart from raising tech log entries, refusing to use the device if it doesn’t meet training needs and raising Hazard reports, there is the IORS system.
This should at set alarm bells ringing somewhere.