SPECIALIZED COMMERCIAL OPERATIONS - SPO (aerial work)
"Specialized operation" means any operation, other than commercial air transport, in which the aircraft is used for specialized activities in areas such as agriculture, construction, photography, surveillance, observation and patrol, aerial advertising or other operations as defined in CT- OPS Annex VIII, SPO.GEN.005, AMC1 SPO.GEN.005 and GM1 SPO.GEN.005.
The conduct of the declaration of specialized commercial air operations and the inclusion of the air operator in the surveillance program is described in PIAC - OPS (Part SPO / LA)
A. CAA information
The air operator intending to carry out specialized commercial operations may request a meeting with CAA representatives in order to obtain the necessary information by submitting to the CAA information (Annex 2.2 PIAC-OPS) on the intention to carry out these types of operations.
The meeting takes place between a team established internally in the CAA and the responsible manager of the operator.
At this meeting, the operator shall receive information on the regulations, directives, circulars and procedures that he must know and apply. At the request of the applicant, the CAA shall provide him with a package of information necessary to be implemented for the safe conduct of specialized operations.
B. Declaration of specialized commercial operations
In accordance with Art. ORO.DEC.100 of HGRM 831 of 20.08.2018, the air operator must submit to the CAA a declaration regarding the conduct of specialized commercial operations, the model of the Declaration being Annex 5.1 PIAC-OPS.
The CAA shall verify that the declaration contains all mandatory information and shall, within 10 days of receipt of the declaration, issue information attesting to the air operator's intention to conduct specialized commercial operations.
Before starting specialized commercial operations, the operator must ensure the implementation and compliance with all requirements applicable to the operations he intends to carry out (example: Part ORO, Part SPO of HGRM 831 of 20.08.2018
The air operator must appoint responsible persons according to ORO.SPO.100 and implement a management system appropriate to the size of the operator, the nature and complexity of its activities, which can be described in the Operations Manual or in a separate document.
The air operator must also develop an Operations Manual in accordance with ORO.MLR.100 and the Minimum Equipment List for the aircraft it intends to operate.
The air operator is required to inform the CAA of any changes to the declaration and / or means of compliance initially submitted by completing a new declaration.
C. Continuous surveillance
After confirming the declaration regarding the development of specialized commercial operations, CAA continuously evaluates and monitors the air operators through inspections / surveillance audits, in order to carry out the operations in safe conditions according to the provisions of the applicable legislation.
For CAA oversight organizations, the oversight program is developed taking into account the specific nature of the organization, the complexity of its activities, the results of previous certification and / or oversight activities and is based on the associated risk assessment.
The CAA is not limited to the objectives of an audit / inspection mission within the meaning of the provisions of this procedure, may extend the audit / inspection period, may change the frequency and timing of scheduled audits / inspections according to the information and elements available in the ongoing surveillance process. the safety they perform or depending on the nature and / or extent of the air operator's operations and changes thereto.
If, during supervisory inspections, deficiencies with multiple implications are found between the air operator's departments, the inspections may turn into an audit of the air operator's entire system.
The CAA will apply a planning cycle for the supervision of air operators that carry out specialized operations at least once every 12 months.
If the CAA finds that the safety performance of the air operator has decreased or if regulations / amendments have been issued to the applicable regulations that need to be implemented, audits / inspections may be carried out on the air operators concerned whenever it is considered necessary in which case the respective audits / inspections will be unplanned.
More details regarding the way of supervising the air operators that have declared their activity are described here.
D. Findings and corrective actions
The CAA has a system for analyzing findings in terms of their safety significance, as follows:
• a Level 1 finding is issued when any significant non-compliance with the applicable requirements, the organization’s procedures and manuals or the conditions of an approval or certificate is found, which reduces the level of safety or seriously endangers the safety of the flight.
• a level 2 finding is issued when any non-compliance with applicable requirements, the organization’s procedures and manuals or the conditions of an approval or certificate is detected, which could reduce the level of safety or endanger the safety of the flight.
When a non-compliance is issued, the CAA communicates that finding in writing to the organization and requests corrective actions to resolve the identified non-compliance (s). The corrective action plan must be formulated in such a way as to allow the identification of the cause of the non-compliance, its correction and the corrective action as well as the time period necessary for the implementation of the proposed corrective action.
In the case of Level 1 findings, the CAA shall take immediate and appropriate measures to prohibit or restrict activities and, where appropriate, take measures to revoke the certificate or specific approval or to limit or suspend it in whole or in part, in depending on the extent of the level 1 finding, until the organization has successfully taken corrective action.
In the case of level 2 findings, the CAA:
• gives the organization a deadline for the implementation of corrective actions corresponding to the nature of the finding, which, in principle, does not exceed in any case three months. At the end of this period and depending on the nature of the finding, the CAA may extend the period of three months subject to the existence of a satisfactory plan of corrective action, previously accepted; and
• evaluates the corrective actions and the implementation plan proposed by the organization and, if the evaluation concludes that they are sufficient to resolve the non-compliance (s), accepts them.
If an organization does not submit an acceptable corrective action plan or does not execute the corrective action within the period accepted or extended by the CAA, the finding becomes a Level 1 finding and action is taken on this type of non-compliance.