The use of a risk-based approach, including the risk profile of the operators, maintenance control organizations, and maintenance organizations to determine which organizations are of greater risk or concerns and prioritize the resources and on-site inspection/surveillance required for such organizations should be considered. In determining the risk profile, States may consider the following:
- the organization's current level of risk given the changing landscape of aviation operations.
- changes in activity and/or capability during the COVID-19 contingency.
- the robustness of the organization's quality system.
In the event that States have difficulties in performing high priority on-site inspection/surveillance activities, the alternatives adopted should ensure continued compliance with appropriate requirements by the operator, maintenance control organization with continuing airworthiness responsibilities, or maintenance organizations. The alternatives could comprise:
Desktop audits to assess the effectiveness of the procedures contained in the accepted Maintenance Control Manual (MCM) or the approved Maintenance Organization Procedures Manual (MOPM), and to ensure the availability of adequate systems for the planning of maintenance as applicable.
Other systems/tools to remotely review documentation (e.g. maintenance programmes, records and certifications, maintenance and personnel training records, maintenance certification, etc.) and address issues, which require interaction between the operator, maintenance control organization with continuing airworthiness responsibilities, or the maintenance organization and the CAA.
- Other interactive means such as remote interviews and inspections to assess the adequacy of the facilities, equipment and the structure of the applicant's maintenance control organization, tools and materials, etc.
For a person or group of persons within the maintenance control organization with continuing airworthiness responsibilities located outside the State issuing the approval, the State's ability to make on-site visits may be significantly lower than that of the State in which the maintenance control organization with continuing airworthiness responsibilities is based.
For a maintenance organization approved by the State of Registration (SoR) and located in a State other than the SoR, the State's ability to make on-site visits may be significantly lower than that of the State in which the organization is based.
In these cases, it is recommended that before adopting the alternatives above, the approving State considers alternative arrangements between States to reduce duplication of on-site inspection/surveillance by:
giving credit and/or recognize the on-site inspection/surveillance activity performed by the State where the maintenance control organization is based, which benefits from proximity and easier access to the maintenance control organization; or
delegating the on-site inspection/surveillance activity to the State the maintenance control organization is based.
The use of such alternatives to on-site inspection/surveillance activities is not recommended when a person or group of persons within the operator or maintenance control organization with continuing airworthiness responsibilities, AMOs or organizations performing maintenance under an accepted equivalent system approval is subject to relevant enforcement, or any suspension, revocation or cancellation action.
The timeframe in which this guidance is used should be limited to a period needed to continue operation and should be revoked once compliance with the standard can be achieved through normal inspection/surveillance activities. It is important that States consider the management of the change to re-establish normal on-site inspection/surveillance activities in an orderly way post-COVID-19 contingencies.
ICAO's Risk-Based Surveillance Tool (RBST) allows for the building of risk-based inspection schedules for air operators.
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