Information for organisations with Airworthiness Approvals and Licensed Engineers on COVID-19
Exemptions
The CAA has published the following exemptions to support the industry through the COVID-19 outbreak:
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ORS4 No 1352 - Part 147 Exemption for Basic Training Schools against the 90% Attendance Requirement
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ORS4 No 1354 - Extension of Validity Periods for Licences, Ratings and Certificates of Aircrew, Instructors, Examiners, Aircraft Maintenance Licence Holders and Air Traffic Controllers
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ORS4 No 1355 - Exemption in respect of the requirement to carry the original EASA Airworthiness Review Certificate onboard the aircraft during all flights
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ORS4 No 1356 - BCAR Section L Licence validity extension
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ORS4 No 1371 - Installation of a Temporary Separation Barrier between the Cockpit and Cabin area of Aircraft used to Transport Key Workers during the COVID-19 Pandemic
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ORS4 No 1372 - Exemption from the requirement for rigid outer packaging for biological substances, Category B, UN3373 samples
Details of all COVID-19 related exemptions.
Following the recent and unprecedented COVID-19 developments, this update details how our airworthiness team and the wider organisation are working under these circumstances. Given the measures recently announced by the Government, our airworthiness team is now working remotely until further notice. Our team in the Shared Service Centre are also working remotely, however we still have the ability to support the industry through the normal routes. During the period, we wish to advise we will be working in the following way:
Oversight and audits
It is our intention, where possible, to continue to maintain our onsite oversight activities as per our current scheduled programme. However, recognising guidelines for social distancing we will be utilising remote methods such as video conferencing and telephone calls. In advance of any planned audits, you will be contacted by your allocated surveyor who will advise you of the information required in advance of the audit. This will require the organisation to answer several questions and provide information. This will relate to the organisations Safety and Quality Management Systems.
Assessments of initial, renewal and variation applications
Our Shared Services Centre's (SSC) Airworthiness and Technical Standards teams will continue to process your applications in the usual way and you should not notice a difference in service. If for any reason our capacity and therefore time to process is impacted, we will let you all know.
We are presently working on the provision of providing electronic versions of certificates, that will be sent with an accompanying email that proves the validity. These certificates may not look like the normal versions you receive. Electronic versions of certificates will be recorded by our Shared Service Centre and will be replaced in the future once we re-establish our normal services.
C of A's, Export C of A's and Permits to Fly
Our team in Airworthiness and Shared Service Centre are available to support these activities and we would not expect there to be any impact with regard to the issuing of Permits to Fly. We expect an impact in our ability to conduct C of A's and Export C of A's due to the current travel restrictions and advice from Public Health England. Please contact your allocated surveyor in the case that these services are required, and we will advise of the preferred route to conduct the activity.
Licence applications, variations and renewals
Licence applications, renewals and the addition of type ratings will continue to be processed through our Shared Service Centre in the usual way. New licence applications may take longer to process due to our ability to access our office at Gatwick. We do not anticipate, currently, any impact on our renewal and variations (adding of type ratings).
Reporting of safety related events
During these unprecedented times, we would kindly request your support to our teams carrying out their oversight activities. This will be aided by the reporting of all safety significant events, as defined in EU.Reg 376 / 2014 via the Mandatory Reporting System (MOR).
Quality system independent auditing during COVID-19
To enable organisations flexibility with regard to their internal Quality Audit plan, the below listed guidance has been provided to enable organisations to understand the various scenarios which exist when delaying any internal audit; its possible ramifications and where required seek CAA agreement.
Regulations requiring audit plan acceptance by competent authority (Part M, Part 145, 147, BCAR )
Delaying an audit within the prescribed regulation time scales
Delaying an audit (or multiple audits) for a period of time but still completing the audit plan within the specified time periods as required by the regulation should be managed by the organisations internal Quality/SMS System with an updated Quality Audit plan provided to the CAA along with substantiation why the audits cannot be completed as scheduled. In this case the CAA will not issue any documentation but merely acknowledge the submission.
Unable to Complete the Audit Plan within the prescribed regulation time scales
Provided that there are no safety related findings or significant MORs in the last 12 months, the organisations independent audit time periods specified within the applicable regulation and associated AMC/GM material may be increased subject to agreement by the CAA. A revised audit plan should be submitted along with substantiation why the audits cannot be completed as scheduled and within the specified periods of the regulation. Once agreed the CAA will issue a Temporary Arrangement document where necessary confirming acceptance of such arrangements and any caveats which may be required in a specific instance.
Regulations not requiring audit plan acceptance by competent authority (Part 21G)
As Part 21 does not require audit plans to be submitted to the CAA, the organisation should use its procedure as identified in the Exposition for amending and controlling the internal audit and supplier audit plan including the approval of changes by appropriate management personnel.
When approving changes, management personnel for production organisations should consider the following:
While in the current situation it is understandable for an organisation to consider postponement of planned audits as part of a mitigation strategy to reduce contact between personnel, the level of audit should not be reduced below that needed to ensure continued production conformity (such as product audits or other evaluations such as First Time Pass Rate/other KPI reviews) or to a level that creates a backlog of QMS audits that cannot be anticipated to be recovered during the audit period. Consideration could also be given to alternative methods of oversight or evaluation, such as independent desktop evaluation of recorded operator self-audits or of supplier/subcontractor declarations.
When planning appropriate resource to maintain production, organisations should remember the need to plan for appropriate supervision and production conformity oversight (by inspection/evaluation/audit) as well as the direct production activity. Where reduced production volume or risk/performance based assessment of an internal area or supplier is used as a justification for reducing planned audit activity, this should be recorded as part of the approval of the amended audit plan.