ORA.FSTD.100 General

Regulation (EU) No 1178/2011

(a) The applicant for an FSTD qualification certificate shall demonstrate to the competent authority that it has established a management system in accordance with ORA.GEN Section II. This demonstration shall ensure that the applicant has, directly or through contract, the capability to maintain the performance, functions and other characteristics specified for the FSTD’s qualification level and to control the installation of the FSTD.

(b) If the applicant is the holder of a qualification certificate issued in accordance with this Part, the FSTD specifications shall be detailed:

(1) in the terms of the ATO certificate; or

(2) in the case of an AOC holder, in the training manual.

AMC1 ORA.FSTD.100 General

ED Decision 2012/007/R

COMPLIANCE MONITORING PROGRAMME – ORGANISATIONs OPERATING FSTDs

(a) Introduction.

(1) The purpose of this AMC is to provide additional and specific information to an organisation operating FSTDs on how to establish a compliance monitoring programme (CMP) that enables compliance with the applicable requirements.

(b) Compliance monitoring programme

(1) Typical subject areas for inspections are the following:

(i) actual FSTD operation;

(ii) maintenance;

(iii) technical standards

(iv) FSTD safety features.

(c) Audit scope

(1) Organisations operating FSTDs are required to monitor compliance with the procedures they have designed to ensure specified performance and functions. In doing so they should as a minimum, and where appropriate, monitor the following:

(i) organisation;

(ii) plans and objectives;

(iii) maintenance procedures;

(iv) FSTD qualification level;

(v) supervision;

(vi) FSTD technical status;

(vii) manuals, logs and records;

(viii) defect deferral;

(ix) personnel training; 

(x) aircraft modifications; 

(xi) FSTD configuration management.

AMC2 ORA.FSTD.100 General

ED Decision 2012/007/R

COMPLIANCE MONITORING PROGRAMME – ORGANISATIONs OPERATING FSTDs

One acceptable means of measuring FSTD performance is contained in ARINC report 433-1 (December 14th, 2007 or as amended) Standard Measurements for Flight Simulation Quality.

AMC3 ORA.FSTD.100 General

ED Decision 2012/007/R

COMPLIANCE MONITORING PROGRAMME – ORGANISATIONS OPERATING BASIC INSTRUMENT TRAINING DEVICES (BITDs)

(a) The compliance monitoring programme together with a statement acknowledging completion of a periodic review by the accountable manager should include the following:

(1) a maintenance facility that provides suitable BITD hardware and software test and maintenance capability;

(2) a recording system in the form of a technical log in which defects, deferred defects and development work are listed, interpreted, actioned and reviewed within a specified time scale; and

(3) planned routine maintenance of the BITD and periodic running of the qualification test guide (QTG) with adequate manning to cover BITD operating periods and routine maintenance work.

(b) A planned audit schedule and a periodic review should be used to verify that corrective action was carried out and that it was effective. The auditor should have adequate knowledge of BITDs.

GM1 ORA.FSTD.100 General

ED Decision 2012/007/R

COMPLIANCE MONITORING – ORGANISATIONs OPERATING FSTDs – GENERAL

(a) The concept of compliance monitoring (CM) is a fundamental requirement for organisations operating FSTDs. An effective CM function is vitally important in supporting operation of the devices, in a structured way, to ensure they remain in compliance with the technical standards of CS-FSTD(A) and CS-FSTD(H) and continue to be effective training tools. An effective CM function is also essential to support any level of extended recurrent evaluation period as permitted by ORA.FSTD.225(b).

(b) The following guidance has been developed to provide additional material to help both organisations operating FSTDs and competent authorities in developing effective CM that satisfy the applicable requirements and ensure the highest standards of training are maintained.

(c) Additional GM provide a compliance checklist for organisations operating FSTDs (GM2 ORA.FSTD.100) and guidance detailing the preparation for an evaluation by the competent authority (GM3 ORA.FSTD.100). The compliance checklist should be used by the competent authorities as a standardised checklist for the elements that are expected in the CM function of an organisation operating FSTDs. The organisation should complete as a minimum the second column of the checklist by providing appropriate manual or procedure references for each of the identified elements of the CM function. Additional information can be provided in the third column to aid assessment of the checklist as appropriate. This would then be provided to the competent authority. Use of this checklist should assist in ensuring a consistent approach by the competent authorities and also provide organisations operating FSTDs with additional guidance on all the elements of a CM function that the competent authorities will expect. The guidance is provided to help organisations operating FSTDs to prepare for authority visits.

(d) The documentation of the CM may be electronic, provided the necessary controls can be demonstrated. This should include control of any paper copies that may be downloaded for use by individuals. It is recommended that any such copies are automatically designated as uncontrolled as part of the download process. Whilst electronic signatures on master documents may be accepted, with appropriate protections, a hardcopy master of the CM manual should be provided, with wet-ink signatures to be held by the applicant.

(e) It should be recognised that whatever CM is developed, it will not be effective unless it becomes an integral part of the way in which the organisation works. It includes both the necessary procedures for maintaining compliance with all the applicable requirements and a compliance monitoring programme (CMP) to monitor the execution of these procedures. A successful CM will ensure that the highest training tool is available at all times. If the CM is viewed as an addon to existing processes it will become a burden and it will never be wholly effective. It should also be noted that compliance control or inspection is only a small part of a CM. If the CM is working effectively, inspections such as fly-outs should become routine revealing little beyond day-to-day unserviceabilities. Systematic defects should be captured by the CMP.

(f) The competent authority should be satisfied that the accountable manager is able to adequately provide the required level of resources to properly support the FSTD. Detailed knowledge of FSTD requirement standards are not necessary, only sufficient to understand his/her responsibility for ensuring the FSTD is properly supported. The assessment of the compliance monitoring manager should concentrate on establishing that the nominee has sufficient knowledge and experience of both CM management and FSTD operations to operate a compliance monitoring system (CMS) within an organisation operating FSTDs. This is likely to require experience of working in the compliance monitoring field and sufficient knowledge of FSTDs and the technical standards with which they should comply.

(g) If an organisation operating FSTDs is certified under any international quality standard it should assure that it fully covers the applicable organisation requirements of Part-ORA and the qualification basis.

(h) For small organisations, it is perfectly acceptable to combine the roles of compliance monitoring manager and accountable manager. For other organisations that hold multiple certificates and may cover multiple sites, it is advantageous to have a common CM function with an overall compliance monitoring manager. However, it is essential, particularly where sites may be significantly separated geographically, that there is a nominated representative at each site and possibly for each certificate. These representatives should hold the delegated responsibility of the CM manager for the day-to-day CM role at their site and in their function and have the necessary direct reporting line to the overall CM manager. It will also be necessary to ensure that local representatives are also acceptable to the local competent authority. In many cases the local representatives may perform other functions in addition to this role. This is acceptable provided the necessary independence of any compliance monitoring activity is maintained.

(i) CM, as a whole, begins with the requirements with which the system seeks to comply. These include both the technical standards, in this case the relevant parts of CS-FSTD(A)/(H) plus any other specific standards, for example health and safety regulations, and the compliance monitoring objectives, such as defect rates and rectification intervals and FSTD reliability targets. The CM should define the process by which these standards are made available to those who require them.

(j) The next part of CM is that part which defines the day-to-day procedures or working practices by which the standards will be achieved. These procedures should include as a minimum defect reporting systems, defect rectification processes, tracking mechanisms, preventative maintenance programmes, spares handling, equipment calibration and configuration management of the device. They should include checks to assess the compliance of the performed actions. These procedures and standards should be made readily available to anybody involved in the maintenance and day-to-day operation of the FSTD.

(k) The third part of CM is the method by which the organisation operating an FSTD confirms the device is maintained in compliance with the defined standards and is being operated in accordance with the defined procedures. This is the compliance monitoring programme (CMP) and includes the audit methods, reporting and corrective action procedures and feedback, management reviews and schedules for audits of all aspects of the FSTD operation.

(l) Across all aspects of CM, and most important to it, are the people. CM includes the definition of the responsibilities of all staff and should include a declaration of the minimum levels of resource proposed for the direct support of the FSTD plus the levels of support and managerial staff proposed. The levels of resource can be affected by factors such as local health and safety regulations, existence of weekend and/or night usage of the device(s), etc. CM also includes definition of the skills and experience required for staff and leads to definition of any required training programmes. Training needs cover both technical training and audit training, including QTG running and checking and fly-out techniques for flight crew.

(m) The documentation of CM may be provided in any number of documents provided there are appropriate cross-references in all documents such that the system is fully traceable in both directions from end to end. For all but small organisations at least two documents would be expected:

(1) Firstly, a CM manual containing the policy, terminology, organisational charts and responsibilities, an overview of all processes, within the system, including those for maintaining regulatory compliance such as QTG running and fly-outs (function and subjective testing), CMP including the audit schedule and audit procedures including reporting and corrective action procedures. In addition, the CM manual should include, either directly or by reference, the identification of skills and experience and associated training.

(2) Secondly, a procedures manual containing, as a minimum, software and hardware control procedures, configuration control procedures including, for example, control of training loads, updates to visual models, navigation and instructor operation station (IOS) databases, QTG running and checking procedures, fly-out procedures, maintenance procedures including both defect rectification and preventative maintenance processes. Any standard forms and checklists should also be included.

(n) The CM documentation also includes all records such as technical logs, QTG runs, fly-out reports and maintenance job cards.

(o) For organisations with several certificates, separate and modular procedures manuals with a single CM manual covering all approvals, may be acceptable.

(p) It is important to understand the difference between compliance assurance and compliance control. An effective CM will contain elements of both. Compliance control is normally done by inspection of the product; it provides confirmation at the time of the inspection that the product conforms to a defined standard.

(q) The compliance assurance element is essential to ensure the standard is maintained throughout the periods between product (FSTD) inspections. Within a CMP, the processes are defined that are necessary to provide confidence that the FSTD(s) is/are being supported and maintained to the highest possible standard and in compliance with the relevant requirements. A programme of internal audits is then set in place to confirm that the processes are being followed and are effective. The competent authority would normally oversee a certified organisation by process and system audit, however, in the case of FSTDs, authority oversight includes an inspection element in the form of the recurrent FSTD evaluation.

(r) In addition to the normal process and system audits, the compliance assurance audit schedule should include the schedule for each FSTD for fly-outs and QTG running through the audit year.

(s) The audit procedure should include, at least, the following: statement of scope, planning, initiation of audit, collection of evidence, analysis, reporting of findings, identification and agreement of corrective actions and feedback, including reporting significant findings to the competent authority, where appropriate. The review of published material could include, in addition to the CM and procedures manuals, QTG records, fly-out reports, technical log sheets, maintenance records and configuration control records.

(t) In addition to basic knowledge of FSTD requirements and operation, it is expected that auditors have received training in CM and audit techniques.

(u) The routine fly-outs of the device are a specialised part of the audit programme. It is essential that the pilots tasked with carrying out these fly-outs are adequately experienced. They would be expected to be type rating instructor/examiner (TRI/TRE) qualified on the type, and should have experience of simulator evaluations carried out by the competent authority. The assignment of such pilots can present difficulties, particularly for the independent organisation operating FSTDs not directly associated with an airline. It is vital for the organisation to ensure their users are aware of the importance of the fly-outs as part of the continued qualification of the device and the need to assist in the provision of suitably qualified pilots to carry them out. It is worth noting that simulator users are required to satisfy themselves that the training devices they use are assessed for continued suitability, as part of their own CMP. Involvement in fly-outs assists in meeting this need.

(v) Whilst it is accepted that the number of audits required in an organisation with a single device will be significantly less than those in larger organisations with multiple devices, the CMP should still meet the same criteria, and cover all aspects of the operation within a 12 month period. The independence of the audit personnel should be maintained at all times. The audit programme, whether by full audit or by using a checklist system should still be sufficiently comprehensive to provide the necessary level of confidence that the device is maintained and operated to the highest possible standard. This includes monitoring and review of corrective actions and feedback processes.

(w) The successful use of sub-contractors who play a significant role in the provision of services, such as maintenance or engineering services, to an organisation operating FSTDs is reliant on the sub-contractor operating under the CM of the organisation. All requirements that an organisation is expected to meet are equally applicable to his/her sub-contractor. It is the organisation’s responsibility to ensure that the sub-contractor complies with its CM.

(x) It is essential that a proper understanding of the CM and how it applies to each and every staff member is provided by appropriate training to all, not just those directly involved in operating the CM, such as the accountable manager, the CM manager, representatives and the auditors. The training given to those directly involved in CM should cover the CM, audit techniques and applicable technical standards. CM familiarisation training should be an integral part of any induction training and recurrent training. Update training on technical standards for audit personnel, is also of particular importance.

(y) Any effective CM will include measurement of its effectiveness. The organisation should develop performance measures that can be monitored against objectives. Such measures, often referred to as metrics, should be reviewed by the competent authority as part of its oversight of the CM within the organisation and during recurrent evaluations. In addition they should form part of the data reviewed during scheduled management reviews as part of the CM.

(z) ARINC 433 provides good guidance on FSTD compliance measurement. Metrics should monitor not only individual FSTD performance but, for larger organisations, how each FSTD is performing within the fleet. It is also recommended that metrics data be shared, regularly, with the FSTD manufacturers to allow monitoring for generic problems such as design issues, which may be best addressed with a fleet-wide solution.

GM2 ORA.FSTD.100 General

ED Decision 2012/007/R

COMPLIANCE MONITORING – ASSESSMENT FOR ORGANISATIONS OPERATING FSTDs

COMPLIANCE MONITORING ASSESSMENT

FOR ORGANISATIONS OPERATING FSTDs

Organisation:

 

Site Assessed:

 

Date of Assessment:

 

Accountable Manager:

 

Compliance Monitoring Manager:

 

Number and Type of FSTDs:

 

CM Manual Reference:

 

Audit Area

CM/Proc Ref

Comments

Satisfactory

Y/N

1. ACCOUNTABLE MANAGER

Has an accountable manager (AM) with overall responsibility for compliance monitoring (CM) been nominated?

 

 

 

Does the accountable manager have corporate authority to ensure all necessary activities can be financed and carried out to the standard required by the competent authority?

 

 

 

Has a formal written compliance policy statement been established, included in the CM manual and signed by the accountable manager?

 

 

 

2. COMPLIANCE MONITORING MANAGER

Has a compliance monitoring manager (CM manager) been nominated?

 

 

 

Are the posts of CM manager and AM combined? If so, is the independence of compliance audits assured?

 

 

 

Does the CM manager have overall responsibility and authority to:

a) verify that standards are met; and

b) ensure that the compliance monitoring programme is established, implemented and maintained?

 

 

 

Does the CM manager have direct access to the AM?

 

 

 

Does the CM manager have access to all parts of the organisation operating an FSTD and as necessary any sub-contractor’s organisation?

 

 

 

3. COMPLIANCE MONITORING (CM)

Has CM been established by the operator?

 

 

 

Is CM properly documented? (see Section 4)

 

 

 

Is the CM structured according to the size and complexity of the operator?

 

 

 

Does the CM include the following as a minimum:

a) monitoring of compliance with required technical standards;

b) identification of corrective actions and person responsible for rectification;

c) a feedback system to accountable manager to ensure corrective action are promptly addressed;

d) reporting of significant noncompliances to the competent authority;

e) a compliance monitoring programme to verify continued compliance with applicable requirements, standards and procedures.

 

 

 

a)

 

b)

 

c)

 

d)

 

 

e)

 

Is the CM structured according to the size and complexity of the operator?

 

 

 

Are the responsibilities of the CM manager defined to include, as a minimum:

a) monitoring of corrective action programme;

b) ensuring that the corrective actions contain the necessary elements;

c) providing management with an independent assessment of corrective action, implementation and completion;

d) evaluation of the effectiveness of the corrective action programme.

 

 

 

a)

 

b)

 

c)

 

 

 

d)

 

Are adequate financial, material and human resources in place to support CM?

 

 

 

Are management evaluations/reviews of CM held at least quarterly?

 

 

 

 

Does the management evaluation ensure that the CMS is working effectively and is it comprehensive and well documented?

 

 

 

Does the compliance monitoring programme identify the processes necessary and the persons within the organisation who have the training, experience, responsibility and authority to carry out the following:

a)  schedule and perform quality inspections and audits, including unscheduled audits when required;

b) identify and record any concerns or findings, and the evidence necessary to substantiate such concerns or findings;

c) initiate or recommend solutions to concerns or findings through designated reporting channels;

d) verify the implementation of solutions within specific timescales.

 

 

 

 

 

 

a)

 

 

b)

 

 

 

c)

 

 

d)

 

Is there sufficient auditor resource available and can their required level of independence be demonstrated?

 

 

 

Do the auditors report directly to the compliance monitoring manager?

 

 

 

Does the defined audit schedule cover the following areas, within each 12 month period?

a) organisation

b) plans and objectives

c) maintenance procedures

d) FSTD qualification level;

e) supervision

f) FSTD technical status

g) manuals, logs and records

h) defect deferral

i) personnel training

j) aircraft and simulator configuration management, including Airworthiness Directives

 

 

 

 

a)

b)

c)

d)

e)

f)

g)

h)

i)

j)

 

How are audit noncompliances recorded?

 

 

 

Are procedures in place to ensure that corrective actions are taken in response to findings?

 

 

 

Are records of the compliance monitoring programme:

a) accurate

b) complete and

c) readily accessible?

 

 

 

a)

b)

c)

 

Is there an acceptable and effective procedure for providing a briefing on the CM to all personnel?

 

 

 

Is there an acceptable and effective procedure for ensuring that all those responsible for managing the CM receive training covering:

a) an introduction to the concept of the CM;

b) compliance management;

c) the concept of compliance assurance;

d) CM manuals;

e) audit techniques;

f) reporting and recording;

g) how the CM supports continuous improvement within the organisation.

 

 

 

 

 

a)

 

b)

c)

d)

e)

f)

g)

 

Are suitable training records maintained?

 

 

 

Are activities within the CM sub-contracted out to external agencies?

 

 

 

Do written agreements exist between the organisation and the sub-contractor clearly defining the services and standard to be provided?

 

 

 

Are the procedures in place to ensure that the necessary authorisations/ approval when required are held by a sub-contractor?

 

 

 

Are the procedures in place to establish that the subcontractor has the necessary technical competence?

 

 

 

4. CM MANUAL

What is the current status of the CM manual – amendment and issue date?

 

 

 

Is there a procedure in place to control copies and the distribution of the CM manual?

 

 

 

Is the CM manual signed by the accountable manager and the compliance monitoring manager?

 

 

 

Does the CM manual include, either directly or by reference to other documents, the following:

a) a description of the organisation;

b) reference to appropriate FSTD technical standards;

c) allocation of duties and responsibilities;

d) audit procedures;

e) reporting procedures;

f) follow-up and corrective action procedures;

g) document retention policy;

h) training records

 

 

 

 

a)

b)

 

c)

 

d)

e)

f)

 

g)

h)

 

Is there a document retention policy covering:

a) audit schedules;

b) inspection and audit reports;

c) responses to findings;

d) corrective action reports;

e) follow-up and closure reports;

f) management evaluation reports.

 

 

 

a)

b)

c)

d)

e)

f)

 

Does the CM manual

include, either directly or by reference to other documents, the following procedures for day to day operation of the FSTD:

a) defect reporting systems;

b) defect rectification processes;

c) tracking mechanisms;

d) preventative maintenance programmes;

e) spares handling;

f) equipment calibration;

g) configuration management of the device including visual, IOS and navigation databases;

h) configuration control system to ensure the continued integrity of the hardware and software qualified;

i) QTG running and function and subjective tests.

 

 

 

 

 

a)

b)

c)

d)

 

e)

f)

g)

 

 

h)

 

 

i)

 

Does the CM manual

include, either directly or by reference to other documents, procedures for notification of the competent authorities of the following:

a) any change in the organisation including company name, location, management;

b) major changes to a qualified device;

c) deactivation or relocation of a qualified device;

d) major failures of a qualified device;

e) major safety issue associated with the installation.

 

 

 

 

 

 

a)

 

 

b)

c)

 

d)

e)

 

Does the CM manual define acceptable and effective procedures to ensure compliance with applicable health and safety regulations, including:

a) safety briefings;

b) fire/smoke detection and suppression;

c) protection against electrical, mechanical, hydraulic and pneumatic hazards;

d) other items as defined in AMC1 ORA.FSTD.115

 

 

 

 

 

a)

b)

c)

 

 

d)

 

Does the CM manual include acceptable and effective procedures for regularly checking FSTD safety features such as emergency stops and emergency lighting, and are such tests recorded?

 

 

 

5. COMPLIANCE MEASURES

Have compliance monitoring objectives been developed from the policy statement, and included either directly or by reference in the CMS manual?

 

 

 

Does the CMS include processes to produce and review appropriate metrics data?

 

 

 

Do these compliance measures track the following:

a) FSTD availability;

b) numbers of defects;

c) open defects;

d) defect closure rates;

e) training session interrupt rates;

f) training session compliance rating.

 

 

 

a)

b)

c)

d)

e)

f)

 

Do the compliance measures support the compliance objectives?

 

 

 

Required actions/Comments

 

 

 

Signature:……………………………………………………….

 

Date:………………………………….

GM3 ORA.FSTD.100 General

ED Decision 2012/007/R

COMPLIANCE MONITORING SYSTEM – GUIDANCE FOR ORGANISATIONS OPERATING FSTDs TO PREPARE FOR A COMPETENT AUTHORITY EVALUATION

(a) Introduction

The following material provides guidance on what is expected by the competent authorities to support the discussion during the preliminary briefing, which is a first step of any initial or recurrent evaluation of an FSTD carried out by a competent authority.

This document has been developed as well to standardise working methods throughout Member States and to develop effective CM spot checks to satisfy the applicable requirements and therefore to ensure the highest standards of training are attained.

(b) Document form

Different document forms can be considered. Nevertheless, it appears that the best solution is a dossier, which includes all the information required by the competent authority to perform an evaluation.

(c) Contents of the dossier for an initial evaluation:

(1) type of FSTD and qualification level requested;

(2) evaluation agenda: including date of evaluation, name of people involved for the competent authority, contact details for the FSTD operator, schedules for the subjective flight profile, QTG rerun;

(3) FSTD identification and detailed technical specification including, type of FSTD, manufacturer, registration number, date of entry into service, host computer, visual system, motion system, type of IOS, simulated version(s), standards of all the aircraft computers, if applicable. Manuals needed for an evaluation (e.g. flight manuals, system manuals, acceptance test manual, IOS user manual etc. – if applicable) could already be provided as part of the dossier in an electronic format;

(4) planned modifications;

(5) subjective open defect(s);

(6) airport visual databases including for each visual scene, name of the airport, IATA and ICAO codes, type of visual scene (specific or generic), additional capabilities (e.g. snow model, WGS 84 compliance, enhanced ground proximity warning system (EGPWS)); and

(7) QTG status: the list should include for each QTG test available the status of the tests following the FSTD operator and competent authority reviews.

(d) Contents of the dossier for a recurrent evaluation:

(1) type of FSTD and qualification level requested;

(2) evaluation agenda, including date of evaluation, name of people involved for the competent authority, contact details for the operator, schedules for the subjective flight profile, QTG rerun and QTG review;

(3) FSTD identification, including type of FSTD, manufacturer, registration number, date of entry into service, host computer, visual system, motion system, type of IOS, simulated version(s), standards of all the aircraft computers, if applicable;

(4) status of items raised during the last evaluation and date of closure;

(5) reliability data: training hours month by month during the past year, numbers of complaints mentioned in the technical log, training hours lost, availability rate;

(6) operational data: a list of FSTD users over the previous 12 months should be provided, with number of training hours;

(7) failure tabulation including categorisation of failures (by ATA chapter and Pareto diagram, ARINC classification);

(8) details of main failures leading to training interruption or multiple occurrences of some failures;

(9) hardware and/or software updates or changes since last evaluation and planned hardware and/or software updates or changes;

(10) subjective open defect(s);

(11) airport visual databases including for each visual scene, name of the airport, ATA and ICAO codes, type of visual scene (specific or generic), additional capabilities (snow model, WGS 84 compliance, EGPWS);

(12) QTG status: the list should include for each QTG test available, the date of run during the past year, any comment, and the status of the tests; and

(13) results of scheduled internal audits and additional quality inspections (if any) since last evaluation and a summary of actions taken.

ORA.FSTD.105 Maintaining the FSTD qualification

Regulation (EU) No 290/2012

(a) In order to maintain the qualification of the FSTD, an FSTD qualification certificate holder shall run the complete set of tests contained within the master qualification test guide (MQTG) and functions and subjective tests progressively over a 12-month period.

(b) The results shall be dated, marked as analysed and evaluated, and retained in accordance with ORA.FSTD.240, in order to demonstrate that the FSTD standards are being maintained.

(c) A configuration control system shall be established to ensure the continued integrity of the hardware and software of the qualified FSTD.

ORA.FSTD.110 Modifications

Regulation (EU) No 1178/2011

(a) The holder of an FSTD qualification certificate shall establish and maintain a system to identify, assess and incorporate any important modifications into the FSTDs it operates, especially:

(1) any aircraft modifications that are essential for training, testing and checking,whether or not enforced by an airworthiness directive; and

(2) any modification of an FSTD, including motion and visual systems, when essential for training, testing and checking, as in the case of data revisions.

(b) Modifications of the FSTD hardware and software that affect handling, performance and systems operation or any major modifications of the motion or visual system shall be evaluated to determine the impact on the original qualification criteria. The organisation shall prepare amendments for any affected validation tests. The organisation shall test the FSTD to the new criteria.

(c) The organisation shall inform the competent authority in advance of any major changes to determine if the tests carried out are satisfactory. The competent authority shall determine if a special evaluation of the FSTD is necessary prior to returning it to training following the modification.

AMC1 ORA.FSTD.110 Modifications

ED Decision 2012/007/R

GENERAL

(a) The FSTD, where applicable, should be maintained in a configuration that accurately represents the aircraft being simulated. This may be a specific aircraft tail number or may be a representation of a common standard.

(b) Users of the device should always establish a differences list for any device they intend to use, and to identify how any differences should be covered in training. In order to ensure each device is maintained in the appropriate configuration, the organisation operating an FSTD should have a system that ensures that all relevant airworthiness directives (ADs) are introduced where applicable on affected FSTDs.

(c) ADs from both the State of Design of the aircraft and the State where the FSTD is located should be monitored. ADs from the State of Design of an aircraft are usually automatically applicable, unless specifically varied by the aircraft’s State of Registry.

(d) Where appropriate, ADs issued by States where users of the device have aircraft registered should also be monitored. In addition to ADs, the FSTD operator should also put in place processes that ensure all aircraft modifications are reviewed for any effect on training, testing and checking. This can be achieved by reviewing the aircraft manufacturer’s service bulletins and may require a specific link to the aircraft manufacturer to be developed. In practice this link is often established through aircraft operators who use the device.

(e) Organisations operating FSTDs should notify the competent authority of major changes.

(f) This does not imply that the competent authority will always wish to directly evaluate the change. The competent authority should be mindful of the potential burden placed on the organisation by a special evaluation and should always consider that burden when deciding if such an evaluation is necessary.

(g) The organisation operating FSTDs should have an internal acceptance process for modifications, to be used when implementing all modifications, even if the competent authority has made a decision to carry out an evaluation.

GM1 ORA.FSTD.110 Modifications

ED Decision 2012/007/R

EXAMPLES OF MAJOR MODIFICATIONS

The following are examples of modifications that should be considered as major. This list is not exhaustive and modifications need to be classified on a case-by-case basis:

(a) any change that affects the QTG;

(b) introduction of new standards of equipment such as flight management and guidance computer (FMGC) and updated aerodynamic data packages;

(c) re-hosting of the FSTD software;

(d) introduction of features that model new training scenarios; e.g. airborne collision avoidance system (ACAS), EGPWS;

(e) aircraft modifications that could affect the FSTD qualification; and

(f) FSTD hardware or software modifications that could affect the handling qualities, performance or system representation.

ORA.FSTD.115 Installations

Regulation (EU) No 1178/2011

(a) The holder of an FSTD qualification certificate shall ensure that:

(1) the FSTD is housed in a suitable environment that supports safe and reliable operation;

(2) all FSTD occupants and maintenance personnel are briefed on FSTD safety to ensure that they are aware of all safety equipment and procedures in the FSTD in case of an emergency; and

(3) the FSTD and its installations comply with the local regulations for health and safety.

(b) The FSTD safety features, such as emergency stops and emergency lighting, shall be checked at least annually and recorded.

AMC1 ORA.FSTD.115 Installations

ED Decision 2012/007/R

MINIMUM ELEMENTS FOR SAFE OPERATION

(a) Introduction

(1) This AMC identifies those elements that are expected to be addressed, as a minimum, to ensure that the FSTD installation provides a safe environment for the users and operators of the FSTD under all circumstances.

(b) Expected elements

(1) Adequate fire/smoke detection, warning and suppression arrangements should be provided to ensure safe passage of personnel from the FSTD.

(2) Adequate protection should be provided against electrical, mechanical, hydraulic and pneumatic hazards, including those arising from the control loading and motion systems, to ensure maximum safety of all persons in the vicinity of the FSTD.

(3) Other areas that should be addressed include the following:

(i) a two-way communication system that remains operational in the event of a total power failure;

(ii) emergency lighting;

(iii) escape exits and escape routes;

(iv) occupant restraints (seats, seat belts etc.);

(v) external warning of motion and access ramp or stairs activity;

(vi) danger area markings;

(vii) guard rails and gates;

(viii) motion and control loading emergency stop controls accessible from either pilot or instructor seats;

(ix) a manual or automatic electrical power isolation switch.

GM1 ORA.FSTD.115 Installations

ED Decision 2012/007/R

GENERAL

(a) The intent of ORA.FSTD.115 is to establish that the organisation operating an FSTD has all the necessary procedures in place to ensure that the FSTD installation remains in compliance with all requirements affecting the safety of the device and its users.

(b) Based on experience, the competent authority should pay particular attention to the quality of safety briefings on the FSTD provided to users and instructors, and to the execution of regular checks on the FSTD safety features.

(c) It is recognised that certain checks, such as that of the emergency stop, can have adverse impact on the FSTD if carried out in full.

(d) It is acceptable to develop a procedure that protects elements of the device by shutting them down in advance, in a more controlled manner, provided it can be shown that the procedure still demonstrates the whole device can be shut down by the operation of a single emergency stop button, when required.

ORA.FSTD.120 Additional equipment

Regulation (EU) No 1178/2011

Where additional equipment has been added to the FSTD, even though not required for qualification, it shall be assessed by the competent authority to ensure that it does not adversely affect the quality of training.