• Regulation (EU) No 2017/373 as retained (and amended in UK domestic law) under the European Union (Withdrawal) Act 2018 lays down common requirements for providers of ATM/ANS and other air traffic management network functions and their oversight.  This Regulation may be cited as the ATM/ANS Implementing Rule (IR) and became applicable in law on 2nd January 2020.

    Services providers should use the compliance matrices as a checklist to indicate their current state of compliance and to identify where additional work needs to be done to achieve compliance.

    Newly completed or updated compliance matrices should be submitted to the CAA at ansp.certification@caa.co.uk

    Scope

    The scope of the ATM/ANS IR is broad and includes organisation requirements (OR) and technical requirements (TR) for providers of ATS, AIS, MET and CNS alongside air traffic flow management (ATFM), airspace management (ASM), data services (DAT) and flight procedure design (FPD).  The ATM/ANS IR also includes requirements for personnel training and competence assessment of air traffic safety electronic personnel (ATSEP).

    Specific requirements

    The ATM/ANS IR requires the CAA to approve two service provider procedures.

    A ‘change management procedure’, which is applicable to all service providers, and a procedure for the “detection of cases of problematic use of psychoactive substances by air traffic controllers”, which is only applicable to ATC service providers.

    Change Management

    The requirement for a change management procedure are detailed in ATM/ANS.OR.B.010 and included within the compliance matrix for Annex III Part-OR. In addition, a checklist is provided to assist service providers in demonstrating compliance with the requirements.

    When service providers are content that their change management procedure meets all items in the checklist, they are to submit them to the CAA for approval at ansp.certification@caa.co.uk.

    The Problematic use of Psychoactive Substances

    The responsibilities of ATC service providers with regard to the problematic use of psychoactive substances by air traffic controllers are detailed in ATS.OR.305 and included within the compliance matrix for Annex IV Part-ATS.  The CAA has developed specific policy and additional AMC and GM to guide and direct ATC service providers in complying with the requirements of ATS.OR.305.

    Using this policy, AMC and GM, ATC service providers should submit their procedure to the CAA for approval at ansp.certification@caa.co.uk by 7 March 2022.

    ICAO Doc 9654 ‘Manual on Prevention of Problematic Use of Substances in the Aviation Workplace’ provides additional guidance for the development and implementation of training and education programmes and policies relating to the problematic use of psychoactive substances; it is referenced within GM1 ATS.OR.305(a).

    Air Traffic Controllers’ Rostering System(s))

    For many years, the UK utilised the Scheme for the Regulation of Air Traffic Controllers’ Hours (SRATCOH) to provide the basis for a rostering system to manage the risks of occupational fatigue of air traffic controllers.  However, the ATM/ANS IR (Annex IV Part-ATS ATS.OR.320) requires ATC service providers to develop, implement and monitor a rostering system, with its structure and values based on scientific principles, data gathered by the ATC service provider and best practices.

    Whilst some UK ATC service providers can readily gain access to the appropriate resources to support this task, the CAA is cognisant that this may not be the case for all.  Consequently, The CAA has developed specific policy and additional AMC and GM to guide and direct ATC service providers in complying with the requirements of ATS.OR.320.

    In addition, ICAO Doc. 9966 ‘Manual for the Oversight of Fatigue Management Approaches’ and in particular The Fatigue Management Guide for Air Traffic Service Providers provides useful insights into the critical elements contributing to ATCO fatigue as well as guidance on fatigue management approaches supported by ICAO Standards and Recommended Practices.

    The AMC and GM are not materially different from the provisions contained within SRATCOH; consequently, the CAA believes that ATC service providers should already be compliant.  However, cognisant of industry’s need to incorporate the new policy, AMC and GM into their existing systems, they will become effective on 7 March 2022.  ATC service providers should assess their compliance with ATC.OR.320 using this policy, AMC and GM and consider what subsequent actions may be required.

    Where an ATC service provider identifies the need to operate in a way that differs to the AMC (for example, the structure of or values used within their rostering system), they may follow the process (ATM/ANS.OR.A.020(a)) to develop and propose alternative Means of Compliance (MOC) for consideration and approval by the CAA.

    Compliance matrices, guidance and checklist