ARGH.MGM.200 Management system

ORGANISATIONAL STRUCTURE

(a)The competent authority should consider all the following elements when deciding on the required organisational structure for GH oversight:

(1)the number of declared GH organisations, including self-handling organisations;

(2)the number of aerodromes where the GH organisations operate;

(3)the possible use of qualified entities and the resources needed to fulfil the continuing oversight obligations;

(4)the size and complexity of the Member State’s aviation industry;

(5)the economic trends indicating growth or decline of GH activities.

(b)The set-up of the organisational structure should ensure that the various tasks and obligations of the competent authority do not rely solely on individuals. The continuing and undisturbed fulfilment of the tasks and obligations of the competent authority should also be guaranteed in the event of illness, accident or leave of individual employees.

(c)The competent authority should take appropriate steps to ensure that the general policy on activities to implement the applicable requirements of Regulation (EU) 2018/1139 and its implementing and delegated acts is:

(1)disseminated to and understood by all personnel involved, and

(2)implemented and maintained.

ORGANISATION AND GENERAL POLICY

(a)It is recommended that the competent authority be organised in such a way that:

(1)there is specific and effective management authority in the conduct of all relevant activities;

(2)the functions and processes described in the applicable requirements of Regulation (EU) 2018/1139 and its implementing and delegated acts, AMC and GM can be properly implemented;

(3)the competent authority’s organisational and operating procedures for the implementation of the applicable requirements of Regulation (EU) 2018/1139 and its implementing and delegated acts are properly documented and applied;

(4)specific and effective provision is made for communication and coordination, as necessary, with the Agency and the competent authorities of other Member States; and

(5)all functions related to implementing the applicable requirements are adequately described.

(b)The competent authority’s general policy on activities to implement the applicable requirements of Regulation (EU) 2018/1139 and its implementing and delegated acts, while satisfying additional national regulatory responsibilities, takes into account in particular:

(1)the provisions of Regulation (EU) 2018/1139,

(2)the provisions of the applicable implementing and delegated acts and their AMC and GM,

(3)the needs of the industry, and

(4)the needs of the Agency and of the competent authority.

(c)The policy defines specific objectives for key elements of the organisation and processes for implementing related activities, including the corresponding control procedures and the measurement of the standard achieved.

DOCUMENTED POLICIES AND PROCEDURES

(a)The various elements of the organisation involved in the activities related to Regulation (EU) 2018/1139 and its implementing and delegated acts should be documented in order to establish a reference for the establishment and maintenance of this organisation.

(b)The documented policies and procedures should be established in a way that facilitates their use. They should be clearly identifiable, kept up to date and made readily available to all personnel involved in the related activities.

(c)The documented policies and procedures should cover, as a minimum, the following aspects:

(1)policy and objectives,

(2)organisational structure,

(3)responsibilities and associated authority,

(4)procedures and processes,

(5)coordination and communication internally and externally with relevant units or entities,

(6)internal control procedures,

(7)training of personnel,

(8)cross-references to associated documents,

(9)assistance from other competent authorities or the Agency, where required,

(10)ethics, personal conduct and the avoidance of actual or perceived conflicts of interest in the performance of official duties.

(d)If the information is held in more than one document or series of documents, suitable crossreferencing should be conducted, and the referenced documentation should be readily available upon request.

CONTENT OF PROCEDURES

(a)The Agency should have access, for standardisation purposes, to the competent authority procedures related to the management system and their amendments before conducting an inspection. Those procedures should provide at least the following information.

(1)The competent authority’s organisational structure, with a description of the main processes related to the oversight, including continuing oversight, and functions. This information should demonstrate the allocation of responsibilities within the competent authority and that the competent authority is capable of carrying out the full range of tasks in line with the size and complexity of the Member State’s GH industry. It should also consider the overall proficiency and scope of authorisation of the competent authority’s personnel.

(2)How changes that significantly affect the competent authority’s oversight capabilities are identified and dealt with.

(3)For personnel involved in oversight activities, the minimum requirements for professional qualifications and experience, and principles guiding the appointment (e.g. assessment).

(4)How the following activities are carried out: verification of declarations, performance of continuing oversight, follow-up of findings and observations, enforcement measures and resolution of safety concerns.

(5)Processes in place for disseminating applicable safety information to enable timely responses to a safety problem.

(6)Criteria for planning continuing oversight (the oversight programme), including adequate management of interfaces when conducting continuing oversight (e.g. with aerodrome operations and air operations oversight, or ramp inspections).

(7)Outline of the initial training of newly recruited oversight personnel (taking future activities into account) and of the basic framework for continuing training of oversight personnel.

(b)The procedures in the competent authority’s management system should include any amendments to those procedures.

(c)As part of the continuing monitoring of a competent authority, in addition to the latest amendments of the elements listed in point (a), the Agency may request details of the working methods used, such as instructions or related guidance material used by the personnel conducting oversight.

INFORMATION SPREAD ACROSS SEVERAL DOCUMENTS Organisational structure and job descriptions can be found in different documents from the ones containing the detailed working procedures.

SUFFICIENT PERSONNEL

(a)This GM for the determination of the required personnel refers to the personnel of the competent authority required to fulfil oversight and enforcement responsibilities.

(b)The elements to be considered when determining the necessary personnel and planning their availability can be quantitative or qualitative:

(1)quantitative elements:

(i)the number of organisations providing GH services, which have declared their activity to the competent authority;

(ii)the number of Member States and number of stations where the GH organisation provides services; and

(iii)the number of planned audits and inspections;

(2)qualitative elements:

(i)the size and complexity of the organisations responsible for the provision of GH services, taking into account:

(A)the range of GH services provided by an organisation,

(B)whether a GH organisation provides services locally (at one or more aerodromes in the same Member State) or in more than one Member State,

(C)organisational structure, existence of subsidiaries and number of contracted activities,

(D)whether an organisation is an independent GH service provider, an aircraft operator performing self-handling or providing GH services as an independent GH organisation, or an aerodrome operator providing GH services,

(E)whether a GH organisation or a self-handling aircraft operator is part of a single GH organisation business grouping or a single air carrier business grouping;

(ii)complexity of the GH services provided; for example, the complexity of aircraft exterior cleaning services in comparison with aircraft turnaround coordination or aircraft ground de-icing/anti-icing;

(iii)the safety priorities identified;

(iv)the results of past oversight activities, including audits, inspections and reviews, in terms of risks and regulatory compliance, taking into account:

(A)number and level of findings,

(B)time frame for the implementation of corrective actions, and

(C)maturity of management systems implemented by organisations and their ability to effectively manage safety risks, taking into account information provided by other competent authorities related to activities in the territory of the Member States concerned; and

(v)the size and complexity of the Member State’s aviation industry and the potential increase in activities in the field of civil aviation, which may be an indication of the number of new declarations and changes to existing declarations to be expected.

(c)It is recommended gathering the following data to assess the required number of GH inspectors and their planning:

(1)standard number of audits to be performed to complete the full oversight scope;

(2)standard duration of an audit;

(3)standard working time for audit/inspection preparation, on-site audit, reporting and follow-up, per inspector;

(4)standard number of inspections and unannounced inspections to be performed;

(5)standard duration of inspections, including preparation, reporting and follow-up, per inspector;

(6)minimum number of inspectors and required qualifications for each audit/inspection.

(d)Standard working time could be expressed either in working hours per inspector or in working days per inspector. All planning calculations should then be based on the same unit (hours or working days).

(e)Spreadsheet software may be used to process data defined under points (c) and (d), to assist in determining the total number of working hours/days per oversight planning cycle required for oversight and enforcement activities. Such software could also serve as a basis for implementing a system for planning the availability of personnel.

(f)The following activities can be considered when determining the number of working hours/days per planning period for each qualified inspector:

(1)purely administrative tasks not directly related to oversight,

(2)training,

(3)participation in other projects or tasks, such as oversight in other aviation domains,

(4)planned absence, and

(5)a reserve for unplanned tasks or unforeseeable events.

(g)The elements listed above will enable the competent authority to:

(1)monitor dates when audits and inspections are due and when they have been carried out;

(2)implement a system to plan the availability of personnel; and

(3)identify possible gaps between the number and qualifications of personnel and the required extent of oversight activities.

FACILITIES AND OFFICE ACCOMMODATION Facilities and office accommodation include but are not limited to:

(a)adequate offices;

(b)a technical library available to personnel of the competent authority, or another method to ensure receipt, control and distribution of the necessary technical documentation;

(c)office equipment, including computers and other means of communication;

(d)means of transportation; and

(e)personal protective equipment.

COMPLIANCE MONITORING PROCESS The formal process for monitoring the compliance of the management system with the relevant requirements and the adequacy of the procedures should be the responsibility of a person or group of persons who:

(a)have functional independence from the units/departments they oversee;

(b)report to the senior management of the competent authority; and

(c)have direct access to the senior management of the competent authority and to appropriate management personnel for safety matters.

PREREQUISITES FOR GH INSPECTORS The persons appointed as GH inspectors, who have tasks related to oversight of GH organisations, should meet either of the following criteria:

(a)have operational experience in any GH operations or another aviation domain, appropriate to the assigned tasks, as established by the competent authority; or

(b)have auditing experience in GH or another aviation domain, which is relevant for the oversight of GH activities and organisations performing them, as established by the competent authority; or

(c)if the person has no auditing or GH operational experience, the additional on-the-job training conditions in point (c) of AMC4 ARGH.MGM.200(b) should be complied with.

TRAINING PROGRAMME

(a)The competent authority should establish a training programme including the assessment of its GH inspectors and a plan for its implementation.

(b)The training programme should cover knowledge, skills and attitudes (KSAs) and should address specific needs of personnel and the competent authority.

(c)For each inspector, the competent authority should:

(1)define the competencies required to perform the oversight tasks;

(2)conduct a training gap analysis before enrolling the inspector in the training programme, to ensure easy recognition of any prior experience, training and qualifications relevant to their function;

(3)establish initial and recurrent training programmes in order to maintain and enhance inspectors’ competency to enable them to achieve the level necessary to perform the allocated tasks; and

(4)ensure that the training meets the established objectives and is reviewed and updated whenever necessary.

(d)The competent authority should have a process for enabling the recognition of an inspector’s previous qualifications and experience in other aviation domains, when relevant to their future tasks and should apply only the necessary additional training to complete the inspector qualifications.

PROVISION OF TRAINING

(e)The training may be provided either by the competent authority’s own qualified trainers or by another suitable training source, which may be a training organisation or adequately qualified individuals.

(f)The trainers should meet the competency and qualification criteria established by the competent authority and described in its documentation. Those criteria should include:

(1)relevant experience in GH operations, as established by the competent authority;

(2)relevant experience or competence in delivery of training (applying training techniques);

(3)communication skills;

(4)safety awareness skills;

(5)behavioural traits indicating professionalism, maturity, judgment, integrity and high personal performance standards.

INITIAL TRAINING FOR AUTHORITY INSPECTORS

(a)Initial training should cover the KSA components as follows:

(1)The knowledge component should cover the content of this AMC.

(2)The skills component should cover audit/inspection techniques in specific areas of inspection.

(3)The attitude component should be developed throughout the training process, by monitoring the trainee inspectors’ behaviours and attitudes during their assigned tasks and practical exercises and by adjusting the behaviours through discussions and feedback from the instructor throughout the training process.

(b)The competent authority should ensure that the trainee inspectors have successfully completed the first phase of their initial training by passing an assessment with an appropriately qualified assessor.

(c)After having successfully passed the first phase of the initial KSA training, the trainee inspector should undergo on-the-job training. The objectives are as follows:

(1)to familiarise the trainee inspector with the particularities of performing a GH audit/inspection in a real, operational environment, which should be done in accordance with AMC4 ARGH.MGM.200(b); and

(2)to monitor the KSA components in a real-life environment and provide final feedback and guidance.

(d)The competent authority may adapt the duration and depth of the individual training programme of an inspector based on the previous qualifications and experience and competence they achieve.

CONTENT OF THE INITIAL TRAINING FOR AUTHORITY INSPECTORS

(e)The initial training programme for inspectors should include the following content, to cover the KSA components, adjusted to their role, current knowledge, experience and skills.

(f)The training programme should be updated, as needed, to reflect the latest changes in aviation legislation and the aviation industry.

(g)AVIATION LEGISLATION

(1)the Chicago Convention and the relevant International Civil Aviation Organization (ICAO Annexes and Documents;

(2)the relevant requirements of Regulation (EU) 2018/1139, including the enforcement measures specified in Article 62 points (1)(e) and (9);

(3)Commission Implementing Regulation(EU) 2025/23, Commission Delegated Regulation (EU) 2025/20, the relevant parts of Regulations (EU) No 965/2012, (EU) No 139/2014, (EU) 2022/1645, and other applicable aviation regulations, as well as the AMC and GM associated with those regulations;

(4)Regulation (EU) No 376/2014 on occurrence reporting and analysis and follow-up of occurrences in civil aviation and the related Commission Implementing Regulation (EU) 2015/1018;

(5)any other relevant international or national aviation legislation.

(h)AUDITING TECHNIQUES

(1)theory of audits and inspections, auditing and reporting techniques, as well as quality and safety assurance, including aspects of performing remote inspections;

(2)competent authority procedures relevant to inspectors’ tasks;

(3)acceptability and auditing of management systems and the safety management system (SMS);

(4)methodology to assess AltMoC;

(5)rights and obligations of inspecting personnel of the competent authority.

(i)TECHNICAL TRAINING PER GH ACTIVITY

(1)technical training on specific GH activities as listed in Article 2 of Commission Delegated Regulation (EU) 2025/20, appropriate to the role and tasks of the inspector;

(2)dangerous goods;

(3)operation of ground support equipment (GSE), as applicable;

(4)security;

(5)other suitable technical training appropriate to the role and tasks of inspectors, including familiarisation with the applicable industry standards.

(j)SMS TRAINING AND OTHER AREAS OF PARTICULAR INTEREST These include, but are not limited to:

(1)management systems;

(2)assessment of the effectiveness of the SMS, in particular hazard identification and safety risk assessment, safety assurance principles and root cause analysis;

(3)accident and incident investigation training, with a focus on root cause analysis;

(4)non-punitive reporting techniques in the context of the implementation of a ‘just culture’;

(5)management of change;

(6)human factors principles.

(k)AERODROME TRAINING FOR UNESCORTED ACCESS TO THE MOVEMENT AREA Unescorted access to the movement area and other operational areas of the aerodrome that are relevant to the oversight of GH activities, in accordance with the training for authority inspectors included in Regulation (EU) No 139/2014.

ON-THE-JOB TRAINING FOR INSPECTOR QUALIFICATION

(a)The competent authority should ensure that on-the-job training is undertaken by trainee inspectors as part of their initial training, after they have successfully completed the first phase of their initial KSA training. On-the-job training should be conducted by a competent person.

(b)The content and duration of the on-the-job training should be adapted to the particular training needs of every trainee inspector and should take into account the following aspects:

(1)the scope and complexity of the inspector’s tasks,

(2)the application of the KSA concepts developed in the first phase of the initial training,

(3)any prior experience as an inspector.

(c)The on-the-job training should focus on the oversight tasks that the inspector will perform. It should include a number of GH audits/inspections, which the competent authority may decide on a case-by-case basis, based on an evaluation of the trainee’s performance. If the trainee inspector has no auditing or GH operational experience before starting the initial training, they should perform GH inspector tasks, including audits and inspections, under supervision for a longer period — as determined by the competent authority — before being allowed to work as a qualified GH inspector.

(d)The scope and elements to be covered during the on-the-job training are as follows:

(1)preparation for an audit/inspection:

(i)sources of information for the preparation for an audit/inspection,

(ii)areas of concern and/or open findings,

(iii)selection of GH organisation to be audited/inspected, and

(iv)task allocation among the members of the audit/inspection team;

(2)administrative issues of the inspection:

(i)GH inspector credentials, rights and obligations,

(ii)aerodrome access procedures,

(iii)airside safety and security procedures, and

(iv)briefing on the GH inspector toolkit (fluorescent vest, anti-electrostatic clothing, checklists, digital camera, torch, safety shoes, hearing protection, etc. depending on the case);

(3)audit/inspection:

(i)introduction (opening meeting),

(ii)on-site activities (audit/inspection according to the area of expertise of the trainee),

(iii)findings (identification, categorisation, evidencing, reporting), and

(iv)corrective actions (enforcement);

(4)closing meeting (debrief on the conclusions of the audit/inspection);

(5)preparation, completion and delivery of the audit/inspection report;

(6)human factors elements:

(i)cultural aspects,

(ii)resolution of disagreements and conflicts, and

(iii)auditee stress;

(7)team leading, if required;

(8)post-audit/-inspection procedures, such as monitoring the status of open audit findings, follow-up audits/inspections and closing the findings after appropriate action has been taken by the GH organisation.

(e)The trainee GH inspector should be assessed by the GH inspector who provides the training. A trainee GH inspector should be considered to have successfully completed their on-the-job training only after demonstrating to the GH inspector who provides the training that they possess the professional competence, knowledge, judgement and ability to perform GH inspections and audits in a real, operational environment, in accordance with the applicable requirements.

(f)The competent authority should ensure that the trainee GH inspector has achieved the required competence before they are authorised to perform their role without supervision.

QUALIFICATION OF INSPECTORS AFTER SUCCESSFUL COMPLETION OF INITIAL TRAINING

(a)Upon successful completion of the initial training, including on-the-job training, the competent authority should issue a formal qualification statement for each qualified GH inspector, listing their privileges.

(b)The competent authority should put in place a system that ensures that their inspectors meet at all times the qualification criteria for eligibility, training and recent experience.

CONTINUED COMPETENCE OF INSPECTORS

(a)Once an inspector is qualified, the competent authority should ensure that they maintain their qualification and remain competent to perform the allocated tasks. This should be done by developing and implementing a process for recurrent training and assessment. The recurrent training and assessment should take place at regular intervals, of no longer than 36 months.

(b)The recurrent training programme should address, as appropriate to the role of the inspector, at least the following aspects:

(1)changes in legislation, the operational environment and technologies in the field of aviation;

(2)competent authority procedures relevant to the inspector’s tasks;

(3)technical training, including training on GH-specific subjects, appropriate to the role and tasks of the inspector; and

(4)results from past oversight.

(c)Training courses with a fixed interval for recurrence established through another regulation (e.g. dangerous goods training) should be maintained as such.

(d)The training to ensure continued competence of inspectors may include, whenever possible, an exchange scheme for inspectors from different Member States, to enable the efficient implementation of cooperative oversight and the standardisation of the oversight process while improving or maintaining inspectors’ competence.

RECENT EXPERIENCE TO MAINTAIN QUALIFICATION OF GH INSPECTORS

(a)A GH inspector is considered to remain qualified if they have performed a minimum of two on-site GH audits/inspections or if they have assisted other competent authorities in performing a minimum of two GH audits/inspections in the previous 12 months.

(b)If a GH inspector loses their qualification as a result of not meeting any of the conditions mentioned in point (a), they may be requalified by completing the minimum number of audits/inspections under the supervision of a qualified inspector. The missed audits/inspections should take place within three months of the deadline for fulfilling the conditions in point (a).

(c)If a GH inspector loses their qualification because they have not performed any audits/inspections for a period between 12 and 24 months, they may be requalified by the competent authority only after successfully completing on-the-job training and any recurrent training required.

(d)If more than 24 months passed since a GH inspector’s last audit/inspection, they may be requalified by the competent authority only after successfully completing initial training, including on-the-job training.

PRACTICAL TRAINING VERSUS ON-THE-JOB TRAINING Practical training, as part of the initial training that inspectors receive, refers to various methods used during training to encourage the trainee to apply their knowledge and skills and help them develop the appropriate attitudes. It involves exercises that simulate the real-life working environment. On-the-job training requires the participation of the trainee inspector in real audits/inspections, either as an observer or as a GH inspector under supervision.

DOCUMENTS RELEVANT TO THE TRAINING FOR GH INSPECTORS The following non-exhaustive list of ICAO Annexes and Documents, as well as industry standards and industry best practices, appropriate to the role of the GH inspector, are relevant to the training programme referred to in AMC3 ARGH.MGM.200(b):

(a)ICAO documentation:

(1)Annex 6 — Operation of Aircraft – relevant standards and recommended practices for GH,

(2)Annex 9 — Facilitation,

(3)Annex 14 — Aerodromes – relevant standards and recommended practices for GH,

(4)Annex 18 — The Safe Transport of Dangerous Goods by Air,

(5)Annex 19 — Safety Management,

(6)Doc 10121 — Manual on Ground Handling,

(7)Doc 9284 — Technical Instructions for the Safe Transport of Dangerous Goods,

(8)Doc 9640 — Manual of Aircraft Ground De-icing/Anti-icing Operations,

(9)Doc 9977 — Manual on Civil Aviation Jet Fuel Supply,

(10)Doc 10070 — Manual on the Competencies of Civil Aviation Safety Inspectors,

(11)Doc 10102 — Guidance for Safe Operations Involving Aeroplane Cargo Compartments,

(12)Doc 10147 — Guidance on a Competency-based Approach to Dangerous Goods Training and Assessment,

(13)Doc 10151 — Manual on Human Performance (HP) for Regulators;

(b)industry standards and best practices, as applicable:

(1)Joint Inspection Group (JIG) standards related to fuelling operations,

(2)Society of Automotive Engineers (SAE) standards related to de-icing and anti-icing operations,

(3)IATA Ground Operations Manual (IGOM), IATA Airport Handling Manual (AHM), and IATA Cargo Handling Manual (ICHM), Live Animals Regulations (LAR),

(4)EN standards for GSE (EN 12312-1 to 12312-20 and EN 1915-1 to 1915-4),

(5)International Business Aviation Council (IBAC) International Standard for Business Aircraft Handlers regarding GH for business aviation operations (IS-BAH).

QUALIFICATION OF INSPECTORS

(a)The term ‘qualification’ denotes adequacy for a purpose. Inspectors may become qualified by fulfilling the necessary conditions, such as completing the required training, holding a diploma or degree, or gaining suitable experience. Qualification also includes the ability, capacity, knowledge and skills that are required to perform a task or that make a person eligible for a duty, an office, a position, a privilege or a status.

(b)Certain posts may, by nature, be associated with the possession of certain qualifications in a specific field (e.g. civil or mechanical engineering, safety management, chemistry, environmental science, etc.). In such cases, the person occupying the post is expected to possess the necessary qualifications at a level that is in accordance with the applicable national or EU legislation.

RECURRENT ASSESSMENT OF AN INSPECTOR’S COMPETENCE A recurrent assessment is the equivalent of a proficiency check. It is recommended that the competent authority include recurrent assessment in the training process to ensure the maintenance of an inspector’s competence.

(a)The recurrent assessment consists of knowledge and skills checks during a real-time inspection or audit.

(b)The inspector’s performance is evaluated against the objectives (usually the tasks included in their job description) established for their role.

(c)Failure to achieve the expected outcome is addressed in a training session, to maintain the competence of the inspector at the expected level. (d It is recommended that recurrent assessments be conducted at intervals shorter than 36 months and that evidence of such assessments be kept in the form of checklists containing the objectives referred to in point (b).