Handling
Inspections
Objective
The objective of the EASA inspections carried out to the assistance services from the Directorate of Civil Aviation Security and User Protection is the continuous improvement of operational safety. The inspections are therefore aimed at groundhandling services provided to aircraft that carry out commercial passenger, mail and cargo transport on a regular basis with a wide impact on operational safety, such as the services of Royal Decree 1161/1999 of categories 3 (luggage), 4 (cargo and mail), 5 (runway operations), 6 (cleaning), 7 (fuel supply) and 11 (majordomy).
When we inspect
- In 6-year cycles we inspect all groundhandling services provided to regular commercial passenger, mail and cargo aviation at all certified airports in Spain.
- During this 6-year cycle, at least one inspection of suppliers of groundhandling services is carried out at each certified airport and one of the central services of each agent.
- In addition, depending on the performance in operational safety of each agent, we can increase or decrease the number of inspections, in what is called performance based oversight.
Following the model of other areas of aviation activity, we have decided to implement a cyclical inspection system with the following characteristics:
What we inspect
- Inspections of central services: During this type of inspection we verify that the groundhandling provider’s management system clearly establishes the responsibilities and addresses, according to the technical instructions or where applicable with an equivalent level of security, all the activities and systems necessary for the provision of the service, including for example the quality system, security management system, communications and documentation recording system, and operating manuals and procedures.
- Inspections at bases (airports): During this type of inspection we verify how the above systems, manuals and procedures are applied at airports in day-to-day practice. For this we check the implementation of the management system (training, records, safety management system, operation, coordination with other organisations, maintenance of equipment...) the actual operation at the airport and the condition of facilities and equipment: the practical and physical implementation of the forms of action described in documentary form. This inspection in the bases is carried out in two ways: exclusively operational or complete (all aspects indicated) depending on operational safety performance or identified inspection needs.
According to Article 39.4 of Law 21/2003 on Aviation Safety, groundhandling services must be provided with a required level of safety, in the absence of regulations establishing this level, the technical instructions of AESA (APTO-15-ITC-104 and APTO-15-ITC-105) establish as guidance material and how to comply with this required level of safety based on international groundhandling standards.
In this sense, during inspections we check the level of safety requiring compliance with technical instructions or other applicable regulations, such as Order TMA/692/2020 approving technical standards applicable to the supply of fuel to civil aviation aircraft or Royal Decree 1161/1999 regulating the provision of airport groundhandling services
For this supervision we carry out different types of inspections aimed at different areas of activity, differentiating inspections directed at the central services of the providers of groundhandling services and inspections at the bases (airports) in which they provide services.
How we inspect
- We begin the inspection with a communication of initiation of inspection actions (CIAI) and designate (DES) the inspection team authorised to perform it in the generic action order (OAG), in addition to indicating the inspection actions that we will carry out. Generally in this first step we request documentation (CSD) that we need in order to carry out the inspection.
- The inspected person responds to the request for documentation within a maximum of 10 working days.
- We perform the inspection, may include displacement or not. However, we will always hold a physical meeting or using telematics.
- We notify the diligence of inspection actions (DAI) indicating the actions taken and the possible non-conformities and observations that we have detected.
- The inspected person makes or does not make any representations within a maximum of 10 working days. In the event of failure to do so, it is understood to be in conformity with the proceedings. This is the so-called hearing of the administrative procedure.
- We notify the inspection report, this is the document that legally ends the inspection procedure and legally the maximum time we have to issue this report is six months from the date of notification of the inspection communication. The minutes take into account the actions taken and any allegations made against them and definitively find non-conformities and observations. In addition, with this document we require the interested party to rectify the non-conformities if they exist in this report.
- The inspected person proposes his corrective action plan (PPAC) within a maximum of 20 working days. This proposal should identify the root cause of non-conformities and propose actions to prevent it from occurring again in the future.
- We notify the assessment of the proposal of the corrective action plan (IVPPAC), assessing whether the root cause of each non-compliance has been identified and corrective actions have been established to remedy it, as well as a manager and date for its implementation.
- The inspected party submits such assessments if he deems it necessary within a maximum of 10 working days. In case you do not claim we understand compliance with what is stated in the valuation. This is a new hearing procedure that we facilitate to the inspected due to the implications that the establishment of a corrective action plan may have.
- We notify the final corrective action plan document (CAP). In which we take into account the proposal of the inspected person, our assessment and the possible claims of the inspected person to that assessment. In this corrective action plan we definitively set out the actions aimed at remedying each non-conformity and require the inspected to implement it in a timely and formal manner.
- The inspected person implements the actions within the established deadlines.
- The inspected informs us of the implementation of the actions by providing us with the evidence of implantation.
- We notify our evaluation of the implementation of the actions, in case of positive completion of the whole process, in case of negative, requiring the implementation of corrective actions.
Always covered by the established regulations, our inspections comply with the legal requirements established in Law 21/2003 on Aviation Safety and Royal Decree 98/2009 approving the aeronautical inspection regulation based on the common administrative procedure established by Law 39/2015 on the Common Administrative Procedure of Public Administrations, in addition to our internal inspection procedures designed to guarantee the effectiveness, impartiality, objectivity and compliance with the above rules.
The legal process is a guarantee with the inspected, which is why clearly defined steps are followed:
Click on image to enlarge
To perform this procedure we have established a telematic process in which all notifications and communications with the inspected and vice versa must be done in a telematic way by accessing the following link with the certificates authorised for this purpose.
How we communicate
Law 39/2015 on the Common Administrative Procedure of Public Administrations (LPACAP) requires the use of a digital platform in AESA’s relationship with the inspected.
Due to this and to be able to carry out the inspections we have established a telematic process in which all notifications and communications with the inspected and vice versa must be done in a telematic way by accessing the following link of the electronic site with the digital certificates enabled for this purpose. Through the link above you can access the “Virtual Office” or “Telematic Transmitter” where you can provide documentation to the file (equivalent to the AESA entry register), see the evolution of the file and the stage in which it is located
The first time the inspected person or his representative accesses the website with a valid digital certificate, the system collects the necessary information and indicates some additional data for communications between AESA and the inspected. It is essential to indicate an e-mail address at this time in order to be able to receive notices of availability of new documents in an electronic site.
In addition, to be able to consult the notifications and communications issued by AESA, both of inspection of regulatory control, authorisations and any other procedure with AESA must access Notification by Appearance (https://sede.seguridadaerea.gob.es/comparece).
Finally, for the entire administration, the General Access Point (https://administracion.gob.es/), through which it also has an electronic record to provide documentation and a notification system. However, this system is shared with all public administrations, and unlike the previous ones it is not dedicated to EASA, so their submissions of documentation or applications could be delayed until they are received in EASA