Change management and change notification process

All changes, detailed below, must be notified to the CAA and submitted to the CAA via e mail to asddocs@caa.co.uk.

All changes are to be notified to the CAA on change notification form SRG 1430.

Documents relevant to the notified change are to be submitted along with the SRG 1430.

Exceptions:

Where the change is a Supplementary Instruction (SI) to a MATS Pt2 or MAFIS document it is not necessary for the SI to be accompanied by a change notification form SRG 1430 provided the SI meets the requirements detailed in the ‘Supplementary Instructions’ section below.

Temporary Operating Instruction (TOI) do not need to be accompanied by a change notification form SRG 1430. More information on Temporary Operating Instructions is provided below.

Air Navigation Service Providers (ANSP)

Changes to the functional system will require prior approval before implementation and may be subject to review:

The functional system is defined as 'a combination of procedures, human resources and equipment including hardware and software organised to perform a function within the context of Air Traffic Management/Air Navigational Services (ATM/ANS) and other ATM network functions' and can be broken down as follows:

• changes to the way the components of the functional system are used.
• changes to equipment, either hardware or software.
• changes to roles and responsibilities of operational personnel.
• changes to operating procedures; Supplementary Instructions, (see more information on SIs below).
• changes to system configuration, excluding changes during maintenance, repair and alternative operations that are already part of the accepted operational envelope.
• changes that are necessary as a result of changing circumstances to the operational context under the managerial control of the provider that can impact the service, e.g., provision of service under new conditions.
• changes that are necessary as a result of changing circumstances to the local physical (operational) environment of the functional system; and
• changes to the working hours and/or shift patterns of key personnel which could impact on the safe delivery of services.

Training Organisations (TO) and Initial Training Organisations (ITO)

Changes to the types of training provided as follows:

• Where a training organisation intends to provide a new type of training e.g., INITIAL, UNIT, CONTINUATION (Conversion and Refresher), OJTI and ASSESSOR.
• Changes to training courses as follows:
  • Changes to documentation that impact on the methodology, delivery and / or course structure.
  • Changes to the timetable which increases or decreases the course by more than a 10% of course duration.
  • Topics and subtopics removed from the plan which result in non-compliance of content.
  • Extraneous content which affects course length.
  • Change in simulator platform. (i.e., a new simulator or any changes to the criteria defined in regulation 2015/340 AMC1 ATCO.OR.C.15(b)).
  • Change in assessment process or examination style.
  • Change in summative exercises.

• Changes to the training facilities. (A new location or changes to classrooms and practical training areas).
• Changes to the Unit Training Plan and Unit Endorsement Courses.
• Changes to the Unit Competency Scheme and refresher training.
• Modifications to the approved change management procedure.

Air Navigation Service Providers (ANSP)

• Modifications to the approved change management procedure.

Air Navigation Service Providers (ANSP)

• A change to the service provider's management system and/or safety management system that does not impact on the functional system or the change management process.
• Change of accountable manager and the management personnel in charge of safety, quality, security, finance and human resources-related functions as applicable.

NOTE: Although the above changes do not require approval, they are to be notified to the CAA to ensure that the CAA maintains a current record of the ANSP documentation and management organisation.

Training Organisations (TO) and Initial Training Organisations (ITO)

Change of the accountable manager and/or the head of the training organisation.

The following changes must also be notified to the CAA as this type of change will require either the issue of a new certificate or the amendment of an existing certificate. 

• A change in the name of the service provider or training organisation.
• A change of legal entity i.e., a change of service provider or training organisation.
• A change in the service provider or training organisations principal place of operation.
• Providing air navigational services or training organisation services at a new or additional location.

The list below indicates the type of minor changes that do not require notification to the CAA. Such minor changes are to be implemented in accordance with local safety assurance procedures.

• Equipment faults that result in the changing of components that do not affect the operating parameters.
• Changes to maintenance routines, except those that impact on service provision.
• Equipment modifications/manufacture's upgrades that do not affect the operating parameters.
• Document changes, typos, formats etc that do not impact on the content of management systems, change management systems, training courses or service provision

SIs amending the MATS Pt 2 or MAFIS documents are changes to operating procedures and as such they are changes to the functional system.

SIs amending the MATS Pt 2 or MAFIS documents should be submitted to the CAA without an accompanying SRG 1430. The SI must include the following information

• A clear and relevant title
• A unique identifier, version/issue number
• Issue date

Where SIs are used to amend documents other than the MATS Pt 2 or MAFIS, these must be submitted to the CAA accompanied by an SRG 1430 change notification form.

The CAA will assess the submitted SI and decide if a review is required or not, informing the notifier if an SI is to be subjected to a review within 30 days of receipt

Due to the volume of SIs received the CAA will not provide the results of their assessment to the notifier unless it has been selected for review.

If the SI is not to be subject to review the CAA will take no further action and the SI may be implemented after the 30-day period.

In exceptional circumstances, where it may be necessary to implement the SI before the completion of the 30-day period, contact the relevant CAA Regional Office.

A TOI is an air traffic control instruction which imposes a temporary change to air traffic control operational procedures

TOIs should only be necessary when an activity or event imposes changes on the normal assured operation and therefore are not considered as changes to the functional system.

Some examples of activities or events that could necessitate the issue of a TOI are:

• Unusual aerial activity such as an air show or while waiting for an adaptation fix
• The temporary closure of a taxiway
• The planned temporary loss of air traffic equipment
• The test of proposed new operational procedures as part of a trial notified in accordance with CAP670 (ATS Safety Requirements), part B, section 4, GEN03.

The maximum period of TOI validity is six months and therefore TOIs should be dated. 

With documented justification, a TOI may be re-issued after it has expired to cover periods of greater than six months.

TOIs must be submitted to the CAA but do not need to be accompanied by an SRG 1430 change notification form.

The CAA will assess the change from the information provided on the SRG 1430 change notification form and decide which of the following options is applicable:

Changes to the functional system or changes that affect the functional system will be assessed to decide if a review is required and actioned as follows:

• Where a review is not required the CAA will advise the notifier of such and issue a ‘No Review’ approval. (Within 30 days of receipt of the notification). (Not applicable to Sis, see above)
• Where a review is required the CAA will inform the notifier, (Within 30 days of receipt of the notification), that the change cannot be implemented until the review is completed and the change approved
• Where there is insufficient information to allow a review decision to be made the CAA will ask for further information.

Modifications to change management procedures require mandatory prior approval and therefore subject to review and cannot be implemented until approval is received.

Changes notified by Training Organisations that require mandatory prior approval will be subject to review and cannot be implemented until approval is received.

It should be noted that when a change is selected for review or where it is mandatory to carry out a review there is no set time limit for the completion of the review. The time taken for the completion of a review will be dependent on the complexity of the notified change.

For changes that fall into the category of not requiring approval the CAA will record the notified change and normally take no further action and the change may be implemented.

Where the notified change is a major project such that it may contain multiple changes within the project implementation period, approval of the overall change will be based on the outcome of the review of the sampled submitted safety assurance documentation as requested by the CAA.

The sampling of the safety assurance documentation will be directed at the validity of the safety arguments. ANSPs should be aware that this is an oversight sampling process and that the risk of implementing the change ultimately remains with them.

Based on the size and complexity of the project the unit should be aware that submitting safety assurance documentation close to the proposed implementation date may not allow sufficient time to complete the review and could result in delayed operational dates.

To prevent delays occurring safety assurance documentation should be submitted as early as possible within the project.