Welcome

What do the various abbreviations mean, i.e. NA, C, RI ,U and IC?

Hi Vasileios, I think that a more details should be provided about the relationship between the Sensitive Data, managed by an ATO, and the Flight Safety. Furthermore, an ISMS Manual Template will be useful to start the document preparation.

This tool is prepared to Part IS - Regulation (EU) 2023/203, all the requirements refer to IS.I.OR.XXX, may it use for the compliance assessment of Regulation (EU) 2022/1645 - IS.D.OR.XXX?

Dear Marcia,
A few years later but hopefully these insights are still helpful.

As a best practice, we initially applied the ORO.FTL framework within our ATO. However, as you and Luca rightly pointed out, it quickly became clear that its relevance is quite limited in this environment. While a line pilot might perform 3 - 4 landings per day, a FI can easily conduct 10 or more in a single training session.

Although ORO.FTL provides a structured framework, it's designed specifically for CAT under an AOC, and the nature of instructional operations within an ATO is quite different. In practice, applying FTL to ATO operations does not bring significant benefits.

To clarify the regulatory picture, we looked into the applicable rules and determined the following:

- For airline crews operating under an AOC, the EASA FTL rules (Regulation (EU) 965/2012) take precedence over national labor laws when it comes to duty and rest time.

- This does not apply to flight instructors working in an ATO, since they are not operating under an AOC. Therefore, FTL rules do not govern their duty time.

- Instead, national labor law applies — covering working hours, rest periods, and employment conditions for instructors.

While EASA regulations like Part-FCL and Part-ORA define the qualifications and oversight requirements for instructors and ATOs, they do not include any provisions on working or rest time.

As a result, any limitations on instructor duty time should come from:
1) Internal company policy,
2) Sector-specific regulations, or
3) Collective labor agreements.

All of which must comply with the respective national labor legislation and may be enforced by local labor authorities.

You mentioned Portugal in your earlier message - and speaking from experience here in Spain, I would expect a similar legal setup applies. It may be worthwhile to check your national labor code or any relevant agreements specific to aviation training.

Hope this is useful for others in the community as well!

However, please note: my post reflects our internal understanding and experience. It does not constitute legal advice, and I advice to refer to consult and conclude with legal or regulatory experts for authoritative guidance.

Best
Keno

Is there a transcript available for the Workshop videos please? I'd like to know more about the Derogation element.

Yes, the AM of each AOC can delegate authority to the global CRP. Just have to ensure all your backend documentation is updated to reflect this.

A truly inspiring tribute to Richard’s impact on aviation safety. His ability to connect both technically and emotionally with pilots and engineers is rare, and deeply effective. I’ve always found his “Tea and Biscuits” lessons both insightful and practical. Looking forward to reading this book and sharing it with colleagues. Fly safe!

Some good reminders and links. A nice refresher.
Thanks Michel.

Thanks Michel for the inspiring read ... let's get ready for the new season!

What a great analogy to have used. This was thought provoking, in all the right ways. 👏