Over the last ten years both ANSPs and NSAs have worked on a systematic implementation of a safety framework. The legal framework for service providers has been a safety management system in accordance with ESARR 3 (as transposed into national legislation) and the Commission Regulation 2906/2005. NSAs on the other hand have been guided by ESARR 1 and Commission Regulation (EC) No 1315/2007 to implement their own requirements for a systematic and structured safety oversight function.
Harmonised approaches and best practices for SMS implementation for ANSPs have been developed by appropriate communication between ANSPs. In a similar way, NSAs have been harmonising their approaches to safety oversight via the EUROCONTROL Safety Regulation Commission. It is therefore important to analyse whether best practices on the interface between ANSP and NSA exist, and if so, whether they can be disseminated for application to the Europe-wide ANSP and NSA community.
In line with the recommendations made by EUROCONTROL Safety Team and Safety Regulation Commission a study was launched with the following objectives:
- to describe present situation;
- to collect a series of practices which have been put in place;
- to identify those practices which would improve the interface and promote a more mature relationship between ANSPs and NSAs.
Summary of Findings
The study focused onto the following five areas:
- The type of interaction between ANSP and NSA (e.g. joint formal bodies, focal points established, coordination where required, etc.)
- Existing practices and processes in auditing (e.g. frequency, level of detail, coordination on preparation, conducting and follow-up actions)
- Interaction between national stakeholders (AAIB, NSA, NAA, ANSP) and arrangements/processes for occurrence reporting and investigation
- Processes for notification, acceptance and oversight of changes with potential impact on safety
- Level of involvement of the NSA in ATCO and ATSEP competency (processes and arrangements)
The study was carried out by interviewing a number of European ANSPs and NSAs.
Interaction between ANSP and NSA
Institutional arrangements vary significantly, but functional separation between ANSP and NSA has been achieved in all states which participated in this study. NSAs, sometimes understaffed, have been looking at various ways to increase their level of competency. Sharing of staff between states, or seconding ATM safety experts from ANSP to NSA, under controlled conditions, are some of the solutions found.
Most ANSP and NSA interviewees have developed ways of meeting each other in a structured way. This is done via formal and regular meetings, or via focal points. The implementation of a quality management system by both the NSA and the ANSP has also been reported as a way to process the relationship between them. In some cases formal manuals are available on how such dialogue is managed. Safety may be the sole point on the agenda, but other regulatory matters e.g. economic regulation, civil-military coordination, etc.) may also be discussed in combination with safety or in the interest of safety.
Practices and Processes for Auditing
Safety oversight is mostly conducted through audits, although complementary methods exist. The way in which audits are conducted varies, but most follow an agreed annual or multi-annual structured and transparent plan. The NSAs which were interviewed felt that there should be greater harmonisation between NSA processes leading to alignment of the certification process of ANSPs. This was considered especially important in the FAB context. The interviewees were also of the opinion that the principle of oversight should be to measure the effectiveness of regulation rather than its existence.
Occurrence Reporting and Investigation
The way in which mandatory occurrence reporting is organised varies between Member States. Although every state has a reporting flow from ANSP to NSA in various formats), the process for follow-up differs. Some NSAs do their own incident investigation while others only check that the ANSP has an adequate process in place to carry out internal investigations. Some NSAs check whether the ANSPs follow up the corrective actions to prevent recurrence of incidents.
Notification, Acceptance and Oversight of Changes
All States which participated in the study apply Commission Regulation (EC) No 1315/2007 on safety assessment but there is a wide degree of interpretation on how to meet its requirements. This is reflected in the processes addressing changes, and specifically the notification of changes. Additionally, the level of documentation which is required by the NSA from the ANSP varies. In some cases, the NSA is involved (sometimes actively in a coordinating role) together with the ANSP from the beginning of the project, particularly in the case of large changes. Checklists are in use, as are various methods of notification and follow-up procedures (some of them highly automated).
ATCO and ATSEP Competency
Competence assessment of ATCOs is one of the areas with the least variation between states and does not seem to cause many difficulties. Various ATCO competency assessment schemes are in place in ANSPs, which must surely have an impact on the oversight of FABs. The situation with respect to ATSEPs is different, because there is no harmonised interpretation of the requirement.