Filters

GM1 ORGH.MGM.200(b)(2) General requirements for the management system

ED Decision 2025/007/R

SAFETY RISK MANAGEMENT

(a)The scalability and suitability of the safety management system are expected to be a function of the inherent safetyriskrelated capabilities of the organisation. For example, complex structures are usually exposed to complex risks, which require a robust safety risk management process. Or, for organisations facing a lower level of risk:

(1)the safety risk assessment model may be very simple if the hazards identified are easy to mitigate;

(2)expert judgement may be sufficient to measure the efficiency of safety barriers;

(3)the collection of data, including on occurrences, and consequently the safety information may be very limited;

(4)there may be no need for software or tools to manage the SMS; and

(5)the communication policy may be limited.

(b)The safety risk and safety risk tolerability matrices provided in ICAO Doc 9859, Safety Management Manual, may be used to determine the tolerability of the safety risks within the organisation. Nevertheless, the GH organisation may use other models to assess and manage the safety risk.

The ICAO safety risk matrix:

Safety risk

Severity

Probability

Catastrophic
A

Hazardous
B

Major
C

Minor
D

Negligible
E

Frequent5

5A

5B

5C

5D

5E

Occasional4

4A

4B

4C

4D

4E

Remote3

3A

3B

3C

3D

3E

Improbable2

2A

2B

2C

2D

2E

Extremely
improbable1

1A

1B

1C

1D

1E

The ICAO safety risk tolerability matrix:

Safety risk tolerability: Safety risk index range

Safety risk description

Recommended action

5A, 5B, 5C, 4A, 4B, 3A

INTOLERABLE

Take immediate action to mitigate the risk or stop the activity. Perform priority safety risk mitigation to ensure additional or enhanced preventative controls are in place to bring down the safety risk index to tolerable.

5D, 5E, 4C, 4D, 4E, 3B, 3C, 3D, 2A, 2B, 2C, 1A

TOLERABLE

Can be tolerated based on the safety risk mitigation. It may require management decision to accept the risk.

3E, 2D, 2E, 1B, 1C, 1D, 1E

ACCEPTABLE

Acceptable as is. No further safety risk mitigation required.

GM2 ORGH.MGM.200(b)(2) General requirements for the management system

ED Decision 2025/007/R

GUIDANCE FOR SMALL GH ORGANISATIONS ON BUILDING A SCALABLE SMS

The GH organisation may use the following guidelines from ICAO Doc 10121, Manual on Ground Handling:

The principles of good SMS apply to all organisations, companies and operators irrespective of their size and complexity of operation. The four components and twelve elements of the ICAO SMS framework can be used appropriately for both large and small organisations alike. Scalability does not mean picking particular elements; all the elements are applicable but will vary in scale. The individual GH organisation should carry out an analysis of its activities to determine the right level of applicability and resource to manage its SMS. Even small GH Organisations could be involved in activities having significant safety risks or be affected by other organisations working around them.

For small organisations, the low volume of incidents and safety data will mean it is more difficult to identify trends. Other more qualitative means of assessing safety might be required such as safety meetings and collaborating with other service providers or industry representative bodies.

Further information on scalability can be found in Doc 9859 and the Safety Management International Collaboration Groups (SMICG) SMS for small organisations.

The safety risk assessment and identification of the appropriate mitigation measures include the humanfactor element.

AMC1 ORGH.MGM.200(b)(2)(i) General requirements for the management system

ED Decision 2025/007/R

SAFETY POLICY

(a)The safety policy is a statement expressing the commitment of management to safety and the implementation of the SMS. It should:

(1)be signed by the accountable manager;

(2)clearly identify safety as the highest organisational priority over commercial, operational, environmental or social pressures;

(3)reflect organisational commitments regarding safety, its proactive and systematic management and the provision of appropriate resources;

(4)be communicated, with visible endorsement, throughout the organisation;

(5)promote safety behaviours, encourage safety reporting with reference to just culture principles, indicate which types of operational behaviours are unacceptable and include the conditions under which disciplinary action would not apply;

(6)emphasise the responsibility of GH personnel to comply with all applicable regulations, applicable standards best practices, instructions and procedures established through its management system documentation;

(7)promote the continuing improvement of the management system and operational safety;

(8)be periodically reviewed to ensure that it remains relevant and appropriate to the organisation.

(b)Senior management should:

(1)continually promote the safety policy to all personnel and demonstrate their commitment to it;

(2)establish safety objectives and performance standards.

AMC1 ORGH.MGM.200(b)(2)(ii) General requirements for the management system

ED Decision 2025/007/R

KEY PROCESSES IN SAFETY MANAGEMENT

(a)Hazard identification processes

(1)The GH organisation should implement an SMS that enables the adoption of reactive, proactive and predictive methods. A reporting scheme that is based on a combination of reactive, proactive and predictive methods of safety data collection should be the formal means of collecting, recording, analysing, acting on and generating feedback about hazards and associated risks that may affect the safety of GH services.

(2)Hazards identified should include:

(i)hazards that may be generated by human factors; and

(ii)hazards that may stem from the organisational setup or the existence of complex operational arrangements (e.g. when an organisation (aircraft operator) both performs selfhandling and contracts GH services to a thirdparty GH organisation, when a selfhandling aircraft operator provides GH services to other aircraft operators within a single air carrier business grouping or when other services or products are contracted in multiple layers).

(b)Risk management processes

(1)The GH organisation should implement and maintain a formal safety risk management process, to include:

(i)analysis of risks (e.g. in terms of likelihood and severity of the consequences of hazards and occurrences;)

(ii)risk classification (in terms of tolerability); and

(iii)control (in terms of mitigation) of risks to an acceptable level.

(2)The levels of management personnel who have the authority to make decisions regarding the tolerability of safety risks, in accordance with point (b)(1)(ii), should be specified.

(3)A risk register, hazard log or equivalent system should be used.

(c)Management of change. See the AMC and GM to point ORGH.GEN.130.

(d)Continuing improvement. The GH organisation should seek to continuously improve its safety performance and the effectiveness of its management system. There should be a focus on updating the risk register, ensuring the continued relevance of the safety performance indicators and the effectiveness of mitigation measures in managing the safety risks identified, and monitoring the competence of personnel and their understanding of their own role in maintaining safety of GH operations.

(e)Immediate safety action and coordination with the aerodrome operator’s and aircraft operator’s ERPs.

AMC2 ORGH.MGM.200(b)(2)(ii) General requirements for the management system

ED Decision 2025/007/R

EMERGENCY RESPONSE PLAN

(a)As part of its SMS, the GH organisation should develop and implement an ERP that ensures prompt, appropriate and effective responses to emergencies. It should be adjusted to the size and complexity of the organisation.

(b)The ERP should cover the corporate and station levels. At the station level, the GH organisation should follow the ERP of the aerodrome operator and support or replace the aircraft operator.

(c)The ERP should:

(1)be coordinated with the aircraft operator’s ERP and with the ERP of the aerodrome operator and any other relevant stakeholder;

(2)provide the actions to be taken by the personnel of the GH organisation or specific individuals in an emergency;

(3)include clear instructions on who to contact at the aircraft operator to which the organisation provides GH services at the aerodrome(s) relevant to the emergency and how to contact them (including outside normal business hours) in accordance with the instructions received from the operator.

(d)The GH organisation should ensure that its personnel are aware of their role in an emergency response and are trained adequately to provide the expected support.

(e)The ERP should be tested regularly to ensure that it remains relevant and personnel’s training remains current.

GM1 ORGH.MGM.200(b)(2)(ii) General requirements for the management system

ED Decision 2025/007/R

SAFETY MANAGEMENT — RISK REGISTER FOR SMALL GH ORGANISATIONS

(a)It is recommended that the risk register cover at least the following aspects:

(1)individual steps in the operational procedures applied in the provision of GH services;

(2)training of personnel;

(3)adequate resources for the provision of GH services;

(4)existence of operational procedures and instructions for the provision of GH services;

(5)changes in the usual way of providing GH services;

(6)operational context, aerodrome context and weather;

(7)if applicable, the serviceability of any GSE used.

(b)The results of the assessment of the potential adverse consequences or outcomes of each hazard may be recorded in a risk register, an example of which is provided below.

Hazard identification

Safety risks*

Severity/likelihood
pre-mitigation

Existing controls**

Risk evaluation:

severity/likelihood

post-mitigation

Assess residual risk

Who does what in applying the mitigation measures?

No

Description

Severity

Likelihood

Severity

Likelihood

Severity

Likelihood

*That is, how those hazards could lead to an incident or accident.

**That is, how the safety risk is mitigated.

GM2 ORGH.MGM.200(b)(2)(ii) General requirements for the management system

ED Decision 2025/007/R

EMERGENCY RESPONSE PLAN

(a)It is recommended that the ERP cover any type of emergency in which the GH organisation may be involved.

(b)An emergency response may be required even when the aircraft operator does not disseminate its ERP to the GH organisation. However, the GH organisation should consider whether it is liable for emergencies that are exclusively related to the safety of its own services and how it should respond to them as part of its business continuity plan.

(c)The ERP at the corporate level:

(1)sets out how the procedures of the GH organisation are coordinated with the ERP of the aerodrome operator(s) and other entities that will respond during emergency situations;

(2)defines the roles and responsibilities of the GH organisation; and

(3)describes the procedures for notifying and/or communicating with the aircraft operator(s), the aerodrome operator(s) and other relevant entities.

(d)At the station level, it is recommended that the GH organisation be responsible for the following actions:

(1)apply the aerodrome ERP, as well as the aircraft operator’s station ERP;

(2)define and document the roles and responsibilities of the organisation at stations;

(3)establish a timeline of actions to be taken in response to emergency events;

(4)ensure that the station personnel are properly trained in relation to the organisation’s ERP;

(5)participate as required in any emergency exercises and training run by the aircraft operator and/or aerodrome operator;

(6)review the own station ERP to ensure its relevance.

(e)A small GH organisation may scale the ERP to its size. If it operates at more than one station, the corporate and stationlevel plans can be combined.

(f)The obligation to follow the aircraft operator’s ERP, as per its service contract, remains applicable at all times.

GM3 ORGH.MGM.200(b)(2)(ii) General requirements for the management system

ED Decision 2025/007/R

HUMAN FACTORS AND SAFETY HAZARDS

(a)Human factors can be addressed as part of a GH organisation’s SMS to optimise human performance within the system. This can be achieved by analysing tasks, the individuals involved and the organisation, and how each of these can affect safety behaviour.

(b)A task or job should be designed with ergonomic principles in mind, taking into account typical human performance limitations to ensure that workers are not overloaded and are able to carry out their tasks in all operational circumstances. The physical design of the workplace, the work environment and equipment, and the mental abilities of the person making decisions, as well as their perception of the task and risks, need to be considered.

(c)Individuals have varying strengths and weaknesses related to their attitudes, skills and personalities.

(d)An organisation’s culture and organisational attitudes can have a considerable influence on individual and group behaviour. A positive culture promotes employee involvement and commitment at all levels and highlights where deviations from safe working practices are not acceptable.

(e)The GH environment still relies heavily on people. However, as technical systems become more reliable, the remaining occurrences are largely related to human error.

(f)Human factors or operator errors have been identified by industry as being responsible for over 90 % of accidents involving damage to aircraft and infrastructure. Common causes of such accidents have been highlighted as poor training and supervision, failure to follow standard operational procedures, communication failure, distraction and work pressure. As part of its SMS, it is recommended that the GH organisation identify and target root causes related to human factors and take appropriate mitigating actions.

(g)There is a considerable amount of research and academic material on the subject of human factors. One commonly used concept is the ‘dirty dozen’. This term refers to 12 of the most common conditions for human error that can act as precursors to accidents or incidents. These 12 elements lead people to make mistakes. Since the introduction of this concept in aircraft maintenance in 1993, the dirty dozen has been a useful starting point in all areas of the aviation industry for discussions of human error within businesses, organisations and workplaces.

(h)While the dirty dozen have increased awareness of how humans can contribute to accidents and incidents, the aim of the concept is to focus attention and resources on reducing and containing human error. There are examples of typical countermeasures designed to reduce the possibility of any human error causing a problem related to each of the 12 elements. There are over 300 elements in the Human Factors Training Manual (ICAO Doc 9683), out of which the dirty dozen is listed below.

(i)It is recommended that the GH organisation conduct an analysis of the human factors in their operations and organisation. Using the dirty dozen is an efficient and simple way to conduct this analysis. The 12 elements are shown in the figure below (see also Appendix G to ICAO Doc 10121, Manual on Ground Handling).

1. Lack of communication

2. Distraction

3. Lack of resources

4. Stress

5. Complacency

6. Lack of teamwork

7. Pressure

8. Lack of awareness

9. Lack of knowledge

10. Fatigue

11. Lack of assertiveness

12. Norms
(‘the way we do things around here’)

(j)The GH organisation should be aware of the issues when employing temporary, including from a third party, and seasonal personnel. Some examples are:

(1)maintenance of competency through training;

(2)inexperienced personnel working unsupervised; and

(3)infrequent use of equipment and procedures.

(k)It is recommended that the GH organisation maintain an appropriate balance between temporary workers and fulltime employees within its operational teams to ensure sufficient levels of experience and competency.

AMC1 ORGH.MGM.200(b)(2)(iii) General requirements for the management system

ED Decision 2025/007/R

MONITORING SAFETY PERFORMANCE

(a)The GH organisation should conduct an annual review of its safety performance, to assess whether it carries out the declared tasks and responsibilities safely and effectively, as established through its safety policy and safety objectives.

(b)The safety review should be based on relevant data and information, risk registers and potential risks identified through safety audits, reviews and/or surveys, and it should be appropriate for the size and complexity of the organisation. For large, complex organisations, it should include safety trends.

GM1 ORGH.MGM.200(b)(2)(iii) General requirements for the management system

ED Decision 2025/007/R

SAFETY PERFORMANCE INDICATORS

The GH organisation may use the following safety performance indicators:

(a)safety reports, including the number of mandatory and voluntary safety reports generated/received by the organisation; the GH activities, processes or procedures being reported on; and the number of occurrences resulting in aircraft damage, vehicles or other property or injuries to persons, and the severity of the damage or injuries;

(b)safety reviews, including trend reviews conducted when introducing new GSE, products (e.g. training) or technologies, when implementing new or updated procedures, or in response to organisational changes that may have an impact on safety or changes to the safety policy, safety objectives, safety performance indicators, safety risk levels;

(c)safety audits focusing on the integrity of the organisation’s management system, on the effectiveness of its safety culture and on periodically assessing the relevance of the safety performance indicators and the effectiveness of actions to mitigate safety risks;

(d)safety surveys examining particular elements or procedures at a specific aerodrome generated by a particular operational context or bottlenecks in daily operations;

(e)staff surveys (including cultural surveys), which can provide useful feedback on how engaged personnel are with the SMS;

(f)changes to the usual volume of GH activities performed over the year, number of new or closed stations, or number of new GH services added to the organisation’s portfolio or to operating stations;

(g)availability of sufficient resources for the safe performance of the declared GH services;

(h)lessons learned.

GM2 ORGH.MGM.200(b)(2)(iii) General requirements for the management system

ED Decision 2025/007/R

MONITORING SAFETY PERFORMANCE BY SMALL GH ORGANISATIONS

A complete assessment of safety performance and safety risks contains information on the following aspects:

(a)changes to safety targets (safety performance indicators) and measures taken to mitigate the identified safety risks, as documented in the safety risk register;

(b)number of occurrences resulting in damage to aircraft, vehicles or other property or injuries to persons, and the severity of damage or injuries;

(c)evaluation of adequacy and effectiveness of followup and corrective actions taken in response to noncompliance that have been detected as part of the compliance monitoring function;

(d)safety risks arising from changes such as:

(1)an increase or decrease in the volume of GH activities performed over the year that requires an increase in the number of employees (including seasonal employees);

(2)provision of new GH services or extension of provision of GH services to other stations;

(3)availability of sufficient resources for the safe performance of the services declared.

GM3 ORGH.MGM.200(b)(2)(iii) General requirements for the management system

ED Decision 2025/007/R

SAFETY ASSURANCE

(a)As part of the safety assurance actions, the GH organisation may set up a joint safety committee composed of the organisation’s management and representatives of personnel from the operational areas.

(b)It is recommended that the joint safety committee meet at least quarterly to review safety reports, training needs and outcomes, and operational risk assessments, and to monitor the implementation of safetyrelated training and procedural changes.

AMC1 ORGH.MGM.200(b)(2)(iv) General requirements for the management system

ED Decision 2025/007/R

TRAINING AND COMMUNICATION ON SAFETY AND SAFETY CULTURE

The GH organisation should ensure that the processes developed under its SMS increase or maintain safety in the provision of GH services and aim to foster a safety culture within the organisation.

(a)Training

(1)All operational personnel should receive safety training that is relevant to their safety responsibilities.

(2)Adequate records should be kept of all safety training provided.

(b)Communication

(1)The GH organisation should establish communication about safety matters that:

(i)ensures that all personnel are aware of the safety management activities relevant to their safety responsibilities;

(ii)conveys safetycritical information, especially relating to risks assessed and hazards analysed;

(iii)explains why particular actions are taken; and

(iv)explains why safety procedures are introduced or changed.

(2)Regular meetings with personnel, where information, actions and procedures are discussed, may be held to communicate safety matters.

(c)Training and communication processes should be assessed and reviewed at relevant intervals to ensure their effectiveness (including understanding by personnel of their individual responsibility in maintaining safety).

GM1 ORGH.MGM.200(b)(2)(iv) General requirements for the management system

ED Decision 2025/007/R

SAFETY PROMOTION

(a)Safety training, combined with safety communication and information sharing, forms part of safety promotion.

(b)Safety promotion activities support:

(1)the organisation’s policies, encouraging a positive safety culture, creating an environment that is conducive to the achievement of the organisation’s safety objectives;

(2)organisational learning;

(3)the implementation of an effective safety reporting scheme and the development of a just culture.

(c)Depending on the particular safety issue, safety promotion may also constitute or complement actions to mitigate risk.

GM2 ORGH.MGM.200(b)(2)(iv) General requirements for the management system

ED Decision 2025/007/R

BUILDING AND MAINTAINING A SAFETY CULTURE

It is recommended that the GH organisation consider the aspects and examples below to foster a safety culture within its organisation:

(a)SMS training

(1)Safety and safety culture training for all levels of management to ensure that personnel are aware of the following:

(i)All safety management practices and procedures applicable to their role.

(ii)Their individual responsibility in maintaining safety in their daily tasks. This can be achieved by highlighting aspects of safety when delivering training to develop personnel’s technical competence. The training should include explanations of why particular safetyrelated actions are taken and why safety procedures are introduced or changed. The competence of personnel is proven when they are able to draw conclusions from safety information systems and willing to implement safetyrelated changes.

(iii)How various human, technical and organisational factors affect the safety of the whole system.

(2)Training on the analysis of safety data and investigation of occurrences for the personnel participating in such activities.

(3)Training and communication to encourage personnel to identify hazards and suggest solutions. Use openended questions to encourage discussion instead of questions that require only a ‘yes’ or ‘no’ answer.

(b)Communication on safety — open, consistent and transparent communication and informationsharing among GH personnel regarding safety aspects, horizontally (among personnel) and vertically (from management to frontline personnel and vice versa).

(1)Organise communication sessions to help the GH personnel understand the main concepts of safety culture and become aware of the following aspects:

(i)the importance of reporting,

(ii)the outcome of reporting (meaningful, visible result),

(iii)the potential safety consequences of not reporting,

(iv)the concept of a just culture and reporter’s protection,

(v)the difference between an inadvertent error/mistake/lapse and an intentional act/reckless conduct,

(vi)the importance of reporting errors on a voluntary basis and of sharing experiences.

(2)Organise formal and informal discussions about safety culture concepts, such as ‘error’, ‘mistake’, ‘intentional’, ‘nonintentional’, ‘negligence’, ‘wilful misconduct’ and ‘gross negligence’, and examples of ‘crossing the line between error and negligence’.

(3)Ensure the timely and effective dissemination of safety notices and safety information to all personnel.

(4)Include any feedback from past briefings and report on followup action taken.

(5)Apply positive reinforcement (praise/thanks for appropriate behaviour).

(6)Share feedback on disseminated results of reported events on a regular basis, in both formal and informal discussions/meetings.

(7)Schedule short debriefings regularly with whole teams about how activities went — aspects that were noticeable, different, not in line with operational procedures, positive or negative — and whether something should be changed. It is important to understand why people do things the way they do.

(8)Listen to the concerns of personnel, without being defensive. The purpose of a briefing is to encourage personnel to start thinking about safety problems. Practical examples can be used in the discussion.

(9)Review the lessons learned from the organisation’s own occurrence reports and safety surveys on a regular basis.

(10)Arrange a ‘display wall’ in the briefing room, to pose questions to personnel — for example, asking them for their opinion about changing an operational procedure — or to inform them about changes stemming from the industry standards that they apply, the regulator or ICAO.

(11)Arrange competitions and games that aim to increase awareness of safety or improve the safety of daytoday activities.

(12)Personalise safety outcomes (including health and safety).

(13)Participate in safetyrelated communication campaigns organised by the aerodrome operator or aircraft operator at the aerodrome where the organisation provides GH services.

(c)Safety reporting

(1)Personnel are encouraged to report essential safetyrelated information. However, a clear line is drawn between acceptable and unacceptable behaviour. This helps in building accountability.

(2)Safety reporting is facilitated using forms that are easy to find, easy to fill in and easy to submit, and that ensure full anonymity. Consider the difficulty of reporting after/during a night shift or a difficult shift (involving congested traffic, severe weather conditions, etc.). In unusual or emergency situations, personnel can report directly to decisionmakers to allow a timely response. This aids the flexibility and effectiveness of reporting.

(3)The outcome of internal safety investigations should ensure that the GH organisation disseminates the lessons learned and applies nonpunitive measures to improve the safety culture within the organisation and avoid the occurrence of similar incidents.

(d)Human resource management

(1)Ensure management’s full involvement in and support for these activities;

(2)Allocate sufficient resources to analysing safety events, to identifying the root causes and providing feedback to reporters and to creating a hazard register based on which safety performance indicators can be established to measure the achievement of safety objectives.

(3)Ask frontline personnel to provide input or feedback when developing or improving procedures.

(4)Involve, as necessary, frontline GH personnel to clarify technical or procedural aspects in the investigation of occurrences and further dissemination of the outcomes and lessons learned from an event.

GM3 ORGH.MGM.200(b)(2)(iv) General requirements for the management system

ED Decision 2025/007/R

GOOD PRACTICES IN BUILDING A SAFETY CULTURE

The following are examples of good practices to help an organisation build and maintain a safety culture:

(a)Provide opportunities for management, operational personnel and personnel representatives to discuss operational risks and promote a positive safety culture.

(b)Ensure that senior management are aware of the top operational risks (‘hotspots’) and key safety objectives.

(c)Involve frontline personnel executing daily operational tasks in safety activities, including hazard identification, procedure development and safety risk assessment and mitigation measures, to provide the operational background and context and ensure a just culture within the organisation.

(d)Involve senior management in activities promoting safety culture. One of the core messages of safety culture that should be relayed to GH organisations’ personnel is that by working safely and not taking risks, and by looking out for each other, everyone gets to go home safely at the end of the day.

(e)Develop a plan to address gaps and deficiencies identified during the safety culture assessment.

(f)Communicate the general results of the assessments of personnel’s safety culture and action plans throughout the organisation.

(g)Empower GH personnel to address any safety concerns regarding unsafe operations using a nonpunitive reporting system.

(h)Always provide personal protective equipment to GH operational personnel and encourage them to use all appropriate equipment.

(i)Personnel do not feel pressure to come into work when unfit to do so.

(j)Develop standard operating procedures together with the GH personnel and relevant stakeholders.

(k)Enable and encourage GH personnel to submit suggestions for improving processes and procedures to enhance safety.

(l)Implement a safety stack model at aerodromes, where this is feasible. However, this initiative remains at the discretion of the aerodrome operator.

GM4 ORGH.MGM.200(b)(2)(iv) General requirements for the management system

ED Decision 2025/007/R

SAFETY CULTURE AND JUST CULTURE

(a)Safety is not the responsibility of a single person or a limited group of people in an organisation. A safety culture should be developed throughout the organisation, involving all personnel as active contributors to the safety of the final product or service.

(b)Just culture, as a component of safety culture, operates with complex concepts. Therefore, it is important to consider human factors in the way in which training is provided to GH personnel, to ensure its effectiveness. For example, complex concepts should be explained in simple terms and using concrete and relevant examples from daily operation.

(c)It is good practice for the GH organisation to develop a just culture policy (ideally a standalone document) that is formally endorsed by top management and staff representatives.

(d)The GH organisation could refer to the European Corporate Just Culture Declaration.

SAFETY CULTURE INDICATORS

The GH organisation may use the following table, containing safety culture characteristics and indicators, to measure the maturity of safety culture in its organisation (from the Netherlands Aerospace Centre’s study Aircraft Ground Handling and Human Factors21):

Characteristic

Indicators

Commitment

Reflects the extent to which every level of the organisation has a positive attitude towards safety and recognises its importance.

Management concern

Personal concern

Investment in safety

Justness

Reflects the extent to which safe behaviour and reporting of safety issues are encouraged or even rewarded and unsafe behaviour is discouraged.

Evaluation of (un)safe behaviour

Perception of evaluation

Passing of responsibility

Information

Reflects the extent to which safetyrelated information is distributed to the right people in the organisation.

Safety training

Communication of safetyrelated information

Safety reporting system

Willingness to report

Consequences of safety reports

Awareness

Reflects the extent to which employees and management are aware of the risks the organisations operations pose to themselves and to others.

Awareness of jobinduced risks

Attitudes towards unknown hazards

Attention to safety

Adaptability

Reflects the extent to which employees and management are willing to learn from past experiences and are able to take whatever action is necessary to enhance the level of safety within the organisation.

Actions after safety occurrences

Proactiveness to prevent safety occurrences

Employee input

Behaviour

Reflects the extent to which every level of the organisation behaves to maintain and improve the level of safety.

Job satisfaction

Working situation

Employee behaviour with respect to safety

Mutual expectations and encouragement

GM1 ORGH.MGM.200(b)(4) General requirements for the management system

ED Decision 2025/007/R

CONSIDERATION OF FATIGUE IN PLANNING GH ACTIVITIES

(a)The GH organisation is already subject to compliance with the provisions of Directive 2003/88/EC of the European Parliament and of the Council of 4 November 2003 concerning certain aspects of the organisation of working time. This is considered the most relevant document enabling the GH organisation to manage fatigue among its GH operational personnel.

(b)Fatigue is one of the factors that may contribute to errors when it is not properly considered as part of planning activities.

(c)Fatigue may be induced by:

(1)the environment and conditions in which work is carried out (e.g. noise, rain, high or low temperature), working in enclosed spaces, lifting/moving heavy items or working in uncomfortable positions (e.g. in a bent position or on knees);

(2)excessive hours of duty and shift working, particularly with changing shift periods or patterns, work intensification due to, for example, flight delays or short turnaround times, personnel shortage, additional overtime or night work.

(d)The way and the extent to which the GH organisation should consider the threat of fatigue in the planning of GH tasks and organisation of shifts may vary from one organisation to another, depending on the type of GH activity and the operational context in which it is performed (where, when and by whom).

(e)Fatigue is one example of a human factor that should be considered by the management system, particularly in the planning of activities. In this respect, where the personnel involved in an activity are prone to experiencing fatigue, it is recommended that the GH organisation:

(1)ensure that the safety reporting system required by point ORGH.GEN.165 enables the collection of data on fatigue issues;

(2)ensure that the threat of fatigue is adequately considered by the management system’s key processes (e.g. assessment, management, monitoring);

(3)provide safetyrelated promotional material and adapt safety training accordingly.

(f)When organising shifts, the GH organisation should consider good practices in the GH domain and applicable rules. Below are a few examples of how the GH organisation can set up activities and shifts in a way that enables GH personnel to remain sufficiently free from fatigue to perform the planned activities safely:

(1)include regular breaks in the working schedule, adjusted to the type of activity;

(2)provide rest periods of sufficient time to enable workers to overcome the effects of the previous shift and to be rested by the start of the following shift;

(3)avoid shift patterns that cause a serious disruption of an established sleep/work pattern, such as alternating day/night duties;

(4)inform the personnel of the shift schedule and changes to it sufficiently in advance to enable them to plan adequate rest;

(5)plan recurrent extended rest periods and notify the personnel of these sufficiently in advance.

(g)It is recommended that the GH organisation have a procedure, including mitigation measures, to address cases where working hours are going to be significantly increased or where shift patterns will be significantly modified, such as for urgent operational reasons. In cases not covered by that procedure, the organisation is expected to perform a specific risk assessment and define additional mitigation actions, as applicable. Basic mitigation measures may include:

(1)provision of additional supervision;

(2)use of additional rest breaks.

AMC1 ORGH.MGM.200(b)(6) General requirements for the management system

ED Decision 2025/007/R

COMPLIANCE MONITORING — INTERNAL AUDITS

(a)Compliance monitoring process

(1)The implementation of a compliance monitoring process should enable a GH organisation to monitor its compliance with the requirements of Annexes I and II to Commission Delegated Regulation (EU) 2025/20, as well as with any other applicable regulatory requirements and instructions and with procedures established by the aerodrome operator or the aircraft operator to which GH services are provided.

(2)The compliance monitoring process should be properly implemented and maintained and continually reviewed and improved, as necessary.

(3)Compliance monitoring should include a method of providing feedback on the findings to the accountable manager to ensure the effective implementation of corrective actions, as necessary.

(4)The GH organisation should monitor the consistent application of its operational procedures and their compliance with the applicable procedures of the aircraft operators to which it provides services and the aerodrome operator of the aerodromes where it operates. In doing so, the organisation will ensure that its activities are performed safely. The GH organisation should, as a minimum and where appropriate, monitor the compliance of the following elements with the applicable requirements:

(i)the declaration;

(ii)the SMS;

(iii)the training programmes;

(iv)the documents and records system, including the GH manual;

(v)the procedures for local operation contained in the aerodrome manual that are applicable to the GH organisation;

(vi)the GSE maintenance programme;

(vii)the GH activities of the organisation carried out under the supervision of the person(s) nominated in accordance with point ORGH.MGM.210(b)(3);

(viii)any activities outsourced in accordance with ORGH.MGM.205, for compliance with the contract.

(b)Organisational setup

(1)The accountable manager, as directly accountable for safety, should ensure, in accordance with point ORGH.MGM.210(a), that sufficient resources are allocated to compliance monitoring. When the person responsible for compliance monitoring also acts as the safety manager, the accountable manager should ensure that sufficient resources are allocated to both functions, taking into account the size of the GH organisation and the complexity of its activities.

(2)The independence of the compliance monitoring function should be established by ensuring that audits and inspections are not carried out by personnel responsible for the function, process or procedure being audited.

(3)Personnel involved in compliance monitoring should have access to any part of the GH organisation and any contracted organisation, as required.

(c)Compliance monitoring documentation

(1)Relevant documentation should include the relevant part(s) of the GH organisation’s management system documentation.

(2)In addition, relevant documentation should include the following:

(i)terminology;

(ii)specified activity standards;

(iii)a description of the organisation;

(iv)the allocation of duties and responsibilities;

(v)procedures for ensuring regulatory compliance;

(vi)the compliance monitoring programme, reflecting:

(A)the schedule of the programme;

(B)audit and inspection procedures, including an audit plan that is implemented, maintained and continually reviewed and improved;

(C)reporting procedures;

(D)root cause analyses for findings identified during internal compliance monitoring activities;

(E)procedures for followup and corrective action; and

(F)the recording system;

(vii)the syllabus of the training referred to in point (d)(2);

(viii)document control.

(d)Training

(1)To achieve optimum outcomes of training, the GH organisation should ensure that all personnel understand the training objectives, as set out in the organisation’s management system documentation.

(2)The persons responsible for the compliance monitoring function should receive training in this function. The training should cover the compliance monitoring requirements, the manuals and procedures related to the necessary tasks, auditing techniques, root cause analysis, reporting and recording.

(3)Time and resources should be allocated based on the volume and complexity of the activities concerned.

(e)Compliance monitoring — audit scheduling

(1)The GH organisation should establish audit schedules to be completed during a specified period, as well as a periodic review cycle for each audited area. The compliance monitoring itself should also be audited according to a defined audit schedule. Unscheduled audits should be possible to perform when noncompliance data shows an increasing trend. The audits should follow up on corrective actions to ensure that they have been implemented, effective and completed, in accordance with the policies and procedures specified in the GH manual.

(2)The management system’s key processes and procedures and the operation of the GH organisation should be audited within the first 12 months from the date when the declaration was first registered.

(3)Following that, the GH organisation should consider the results of its safety risk assessments and past compliance monitoring activities in order to adapt the planning cycle for its compliance monitoring activities to cover its management system’s key processes, procedures, training and operations. This planning cycle should not exceed 36 months or the duration of the oversight planning cycle established by the competent authority for each organisation (whichever is shorter).

GM1 ORGH.MGM.200(b)(6) General requirements for the management system

ED Decision 2025/007/R

COMPLIANCE MONITORING — GENERAL

(a)The completion of a safety risk register is one of the most relevant methods of compliance monitoring, along with the documentation related to safety risk management and to mitigation measures and their implementation.

(b)The person(s) responsible for compliance monitoring may perform all audits and inspections themselves or appoint one or more auditors by choosing personnel with the relevant competence and qualification (as defined in point (b) of AMC1 ORGH.MGM.210(g)(1)), from either within or outside the GH organisation.

(c)Regardless of the option chosen, it is recommended that the independence of the audit function remain unaffected, in particular where those persons performing the audit or inspection are also responsible for other functions within the GH organisation.

(d)When compliance audits or inspections are performed by a contracted party:

(1)it is recommended that any such audits or inspections be performed under the responsibility of the person(s) responsible for compliance monitoring within the GH organisation; and

(2)the GH organisation remains responsible for ensuring that the personnel of the contracted party have knowledge and experience relevant to the activities being audited or inspected, including qualifications and experience in compliance monitoring.

(e)The GH organisation remains responsible for ensuring the effectiveness of compliance monitoring, in particular for the effective implementation and followup of all corrective actions.

GM2 ORGH.MGM.200(b)(6) General requirements for the management system

ED Decision 2025/007/R

COMPLIANCE MONITORING — SMALL GH ORGANISATIONS

(a)Compliance monitoring audits and inspections may be documented using a compliance monitoring checklist, and any findings recorded in a noncompliance report. The following documents may be used for this purpose.

(b)The elements to be checked for a GH activity should be those that make up the steps involved in the operational procedure that is applied for that activity.

COMPLIANCE MONITORING CHECKLIST

Year

Subject

Date checked

Checked by

Comments/noncompliance

Report No

GH activity

Instructions for the provision of the GH service

Dangerous goods instructions, if applicable

Training

Training records are uptodate and accurate

Current qualification

Any additional licence (e.g. security, driving)

Recurrent training, as applicable

Refresher training, as applicable

Documentation

GH manual has been updated and correctly amended

Latest amendments to regulations are included

Operator procedures and aerodrome procedures are included and are current

Declaration is current and valid

Management of change is current and documented

Safety risk register has been completed

GSE maintenance, if applicable

GSE maintenance programme is current and accurate

Outofservice GSE is correctly and visibly labelled

Preventive maintenance has been completed

NONCOMPLIANCE REPORT No

Reported by:

Date:

Category:

GH activityTrainingGSE maintenance

Safety managementDocumentation

Description:

Reference:

Level of finding:

Root cause of noncompliance:

Suggested correction:

Compliance monitoring person:

Corrective action required: Corrective action not required:

Responsible person:

Time limitation:

Corrective action:

Reference:

Signature of responsible person:

Date:

Compliance monitoring person:

Correction and corrective action verified: Report closed:

Signature of compliance monitoring person:

Date:

AMC1 ORGH.MGM.200(d) General requirements for the management system

ED Decision 2025/007/R

INTEGRATED MANAGEMENT SYSTEM

To enable the implementation of an integrated management system, the GH organisation should identify the following elements in its structure and documentation:

(a)other certificates approvals, authorisations issued or declarations submitted under Regulation (EU) 2018/1139 and its delegated and implementing acts that are intended to be covered by the integrated management system;

(b)the domains that are integrated in its management system, with the interfaces that enable effective functioning and communication between them; and

(c)applicable requirements for each domain.

GM1 ORGH.MGM.200(d) General requirements for the management system

ED Decision 2025/007/R

INTEGRATED MANAGEMENT SYSTEM

(a)Organisations are expected to embed safety management and riskbased decisionmaking into all their activities, instead of superimposing another system onto their existing management system and governance structure. In addition, if the organisation holds multiple organisation certificates that are issued under Regulation (EU) 2018/1139, it may choose to implement a single management system to cover all of its activities. An integrated management system may be used not only to capture multiple management system requirements resulting from Regulation (EU) 2018/1139, but also to cover for other regulatory provisions requiring compliance with ICAO Annex 19 or for other business management systems, such as security, occupational health and environmental management systems. Integration will remove duplication and exploit synergies by managing safety risks across multiple activities. Organisations may determine the best way to structure their management systems to suit their business and organisational needs.

(b)Aerodrome operators providing GH services and aircraft operators performing selfhandling are not expected to duplicate their existing management systems to comply with Commission Delegated Regulation (EU) 2025/20.

(c)The organisations mentioned in point (b) are instead expected to revise their existing management system to cover the new elements required by Commission Delegated Regulation (EU) 2025/20, in particular:

(1)the organisation’s safety policy and safety risk management process;

(2)its compliance monitoring function;

(3)the duties and responsibilities of its GH personnel;

(4)interfaces with the other activities performed by the organisation;

(5)the training programme of the personnel performing GH activities;

(6)GH processes and procedures;

(7)documents and records;

(8)the policy regarding the management of change;

(9)the maintenance programme for GSE.

ORGH.MGM.201 Information security management system

Regulation (EU) 2025/20

The ground handling organisation shall establish, implement and maintain an information security management system in accordance with the Annex (Part-IS.D.OR) to Commission Delegated Regulation (EU) 2022/164522 to ensure the proper management of information security risks which may have an impact on aviation safety.

[point ORGH.MGM.201 applicable from 27 March 2031 — Regulation (EU) 2025/20]

ORGH.MGM.205 Contracted services or products

Regulation (EU) 2025/20

(a)Where the ground handling organisation, for the purpose of its operation or compliance with this Regulation, enters into contracts for services or products that are not certified, approved, authorised or covered by a declaration in accordance with Regulation (EU) 2018/1139 and its delegated and implementing acts, those services or products shall be provided once the ground handling organisation has applied the safety management process to manage the risk of those services or products for its own operation.

(b)When the ground handling organisation enters into contracts for services or products that are certified, authorised, approved or declared in accordance with Regulation (EU) 2018/1139 and its delegated and implementing acts, the organisation providing those services or products shall be responsible for their safety, in compliance with the EU aviation regulations applicable to that organisation and the relevant requirements of Annex I or Annex II to this Regulation.

(c)The ground handling organisation shall ensure all the following:

(1)the contracted services or products comply with the applicable requirements, depending on the type of service or product;

(2)any aviation safety hazards associated with the contracted services or products are riskassessed within its own management system;

(3)the competent authority is enabled access to the thirdparty provider, to determine continued compliance with the applicable requirements;

(4)any such contract is documented.

AMC1 ORGH.MGM.205 Contracted services or products

ED Decision 2025/007/R

RESPONSIBILITIES WHEN CONTRACTING SERVICES

(a)The GH organisation may contract certain activities included in the scope of its declaration to thirdparty service providers, including other GH organisations.

(b)A written agreement should exist between the GH organisation and the contracted service provider that clearly defines at least the contracted services and the responsibilities of both parties.

(c)The GH organisation should include the contracted safetyrelated activities relevant to the agreement in its safety management and compliance monitoring programmes.

(d)The GH organisation should ensure that the contracted service provider has the necessary authorisation or approval to provide the services, as required, that the services are appropriate for the purpose, and the contracted service provider has the resources and expertise to undertake the task.

(e)The GH organisation should notify the aircraft operator and/or aerodrome operator concerned, where relevant, of any services carried out by third parties on its behalf.

AMC2 ORGH.MGM.205 Contracted services or products

ED Decision 2025/007/R

AUDITS PERFORMED BY THIRDPARTY AUDITORS

(a)The GH organisation may contract a thirdparty service provider to perform its internal audits and inspections as part of its compliance monitoring responsibilities, in accordance with point ORGH.MGM.200(b)(6). In such a case, the GH organisation should ensure the following:

(1)a documented arrangement has been established with the thirdparty auditor;

(2)the audit applies an evaluation method designed to assess the operational, management and control systems of the GH organisation;

(3)the thirdparty auditor and its evaluation method are independent and the auditors are impartial;

(4)the auditors are appropriately qualified and have sufficient knowledge, experience and training, including onthejob training, to perform their allocated tasks;

(5)audits or at least the parts of them verifying the GH operations are performed onsite;

(6)access of the thirdparty auditor to the relevant data and facilities is granted at the level necessary to verify compliance with the applicable requirements;

(7)the GH organisation is granted access to the full audit report;

(8)procedures have been established for monitoring continued compliance of the organisation with the applicable requirements; and

(9)procedures have been established to notify the GH organisation of any noncompliance with the applicable requirements and findings raised, the corrective actions to be taken, the followup of these corrective actions and the closure of findings.

(b)The full audit report of the thirdparty auditor should be made available to the competent authority upon request.

GM1 ORGH.MGM.205 Contracted services or products

ED Decision 2025/007/R

THIRDPARTY SERVICE PROVIDERS

(a)It is recommended that the GH organisation consider, when selecting the providers of contracted services, relevant references and criteria such as safety and security aspects, or whether the safety culture in the contracted organisation is commensurate with the one in its own organisation, to ensure the safety of its own operation.

(b)If the contracted service is a GH service listed in Article 2(2) of Commission Delegated Regulation (EU) 2025/20, the provider of those services is bound to comply with that Regulation.

ORGH.MGM.210 Personnel

Regulation (EU) 2025/20

(a)The ground handling organisation shall appoint an accountable manager. This person shall:

(1)be accountable for the safe provision of ground handling services;

(2)have the authority to ensure that sufficient resources are allocated so that all activities can be carried out in accordance with this Regulation;

(3)be responsible for establishing and maintaining an effective management system.

(b)The ground handling organisation shall appoint one or more competent persons for the following functions:

(1)safety management;

(2)ground handling training;

(3)ground handling operations;

(4)if applicable, cargo operations.

(c)The competent person for the safety management function shall be responsible for the management and implementation of the safety management system within the whole ground handling organisation. The competent person for this function shall act independently of other functions within the organisation, shall have direct access to the accountable manager and to other management personnel, as relevant for safety matters, and shall report to the accountable manager. The following arrangements may apply:

(1)depending on the scale of operations, one or more persons may be appointed to manage the safety of the provision of ground handling services at each aerodrome. One person may be responsible for more than one aerodrome. That or those persons shall report to the competent person(s) for the safety management [of the organisation], as determined by the ground handling organisation and clarified in its ground handling manual;

(2)aircraft operators performing self-handling and aerodrome operators providing ground handling services may integrate the safety manager function within another function with similar responsibilities already existing in their organisation under the applicable requirements.

(d)The competent person for the ground handling training function shall be responsible for the development and implementation of the training and assessment programme and continued competence of the personnel involved in ground handling activities. The competent person for this function shall have direct access to the accountable manager and to the appropriate management for training matters.

(e)The competent person for the ground handling operations function shall be responsible for the coordination and safety performance of all ground handling activities at all aerodromes or regionally, as established by the ground handling organisation and described in its standards and objectives in accordance with point ORGH.GEN.110(c). The competent person for this function shall have direct access to the accountable manager and to the appropriate management for operational matters. Aircraft operators, holders of an air operator certificate, who perform self- handling may integrate this function within the already existing function of the organisation’s nominated person for ground operations.

(f)The competent person for the cargo operations function shall be responsible for the coordination and safety performance of all cargo operations either at all aerodromes or regionally, as established by the organisation and described in its standards and objectives in accordance with point ORGH.GEN.110(c).

(g)In addition, the ground handling organisation shall establish the following functions:

(1)a function for the implementation of the compliance monitoring process required under point ORGH.MGM.200(b)(6); the competent person or persons for that function shall have direct access to the accountable manager;

(2)a function for the operation and maintenance of the GSE, if the organisation uses GSE in the frame of its operation; the ground handling organisation shall determine the reporting lines for this function, which may be carried out by one or more persons.

(h)The ground handling organisation shall establish a proportionate number of supervisory functions considering the structure of the organisation and the number of personnel employed. The persons exercising supervisory functions shall coordinate, advise and ensure that the individuals in a team perform the ground handling activities in accordance with the established standards and operational procedures included the organisation’s ground handling manual. The duties and responsibilities of the person or the persons exercising those functions shall be well defined, and any other arrangements shall be made to ensure that they can discharge their responsibilities. The supervisory functions shall be exercised by competent individuals with the skills to ensure the performance of ground handling activities as per the organisation’s standards specified in the ground handling manual.

(i)The same person may fulfil more than one function referred to in points (b), (g) and (h) if both the following conditions are met:

(1)they are trained and qualified to perform the assigned tasks;

(2)any conflict of interest in performing the assigned tasks has been addressed before the person takes up those functions.

(j)The ground handling organisation shall have sufficient and qualified personnel for the safe provision of ground handling services in accordance with this Regulation.

AMC1 ORGH.MGM.210 Personnel

ED Decision 2025/007/R

CUMULATION OF FUNCTIONS

(a)The cumulation of several functions into one person’s role, including the function of an accountable manager, should depend on the size of the organisation and the scale of its operation. The person should meet two main conditions, namely to be competent and to have the capacity to fulfil their assigned responsibilities.

(b)As regards competence in different areas of responsibility, there should not be any difference from the requirements applicable to persons holding only one post.

AMC1 ORGH.MGM.210(c) Personnel

ED Decision 2025/007/R

RESPONSIBILITIES OF THE SAFETY MANAGEMENT FUNCTION

The GH organisation should establish a safety management function and a safety review board in the organisational structure. If more than one person is designated for the safety management function, the accountable manager should identify the person who acts as the unique focal point (i.e. the safety manager).

(a)The safety manager should act as the focal point and be responsible for the development, management and maintenance of an effective SMS. The safety manager should perform the following duties and responsibilities:

(1)act as a focal point for the safety aspects of the GH activities, as per ICAO Doc 9859 (Section 9.3.6);

(2)monitor safety concerns in the aviation industry;

(3)coordinate and communicate with the competent authority and with the accountable manager;

(4)facilitate hazard identification, risk analysis and management;

(5)monitor the implementation of actions taken to mitigate risks, as listed in the safety action plan;

(6)provide periodic reports on safety performance;

(7)ensure the maintenance of safety management documentation;

(8)ensure that safety management training is available and that it meets acceptable standards;

(9)provide independent advice on safety matters;

(10)ensure the initiation and followup of internal occurrence investigations;

(11)assess the risks related to changes affecting the main elements of the declaration.

(b)For GH organisations with over 25 FTEs, the safety management function should be independent of operational line management.

AMC2 ORGH.MGM.210(c) Personnel

ED Decision 2025/007/R

SAFETY MANAGER

(a)Depending on the size of the GH organisation, the safety manager may be assisted by additional safety personnel to enable the performance of all tasks related to safety management.

(b)Regardless of the organisational setup, it is important that the safety manager remains the unique focal point as regards the development, administration and maintenance of the operator’s SMS.

COMPETENCIES OF THE SAFETY MANAGER

(c)The safety manager supports, facilitates and leads the implementation and maintenance of the SMS, fostering an organisational culture that ensures effective safety management, risk management and occurrence reporting. The competencies of the safety manager should include, but not be limited to, the following:

(1)knowledge of:

(i)ICAO standards and European requirements and provisions on safety management, related to:

(A)monitoring safety performance,

(B)conducting safety risk assessments,

(C)managing safety information databases (systems),

(D)investigating reportable matters and hazardous events;

(E)safety promotion/communication methods;

(ii)basic safety investigation techniques;

(iii)human factors in aviation;

(2)other suitable skills and competencies include:

(i)promotion of a positive safety culture,

(ii)interpersonal, influencing and leadership skills,

(iii)oral and written communication skills,

(iv)data management, analytical and problesolving skills,

(v)computer skills; for example, in word processing, spreadsheets and database management,

(vi)professional integrity.

(d)The safety manager should have work experience, relevant and documented, preferably in a comparable position, in any of the following areas:

(1)management systems, including compliance monitoring systems, and safety management;

(2)GH operations.

AMC1 ORGH.MGM.210(g)(1) Personnel

ED Decision 2025/007/R

COMPLIANCE MONITORING FUNCTION

Those performing the compliance monitoring function should be responsible for ensuring that the compliance monitoring process established in accordance with point ORGH.MGM.200(b)(6) is properly and consistently implemented and continued compliance with the applicable regulatory requirements.

(a)If more than one person is appointed to perform the compliance monitoring function, the accountable manager should identify the person who acts as the unique focal point (i.e. the ‘compliance monitoring manager’.)

(b)The person(s) responsible for compliance monitoring should:

(1)be able to demonstrate relevant knowledge of, and appropriate experience in GH operations, and qualification(s) and experience in compliance monitoring;

(2)have knowledge of the applicable requirements in the GH domain; and

(3)have access to all parts of the GH organisation and, as necessary, any contracted service provider.

(c)In a small GH organisation, this function may be executed by the accountable manager if the accountable manager complies with points (b)(1) and (2).

(d)If the compliance monitoring function and the safety management function are cumulated in one person, the accountable manager should ensure that:

(1)sufficient resources are allocated to both functions, considering the size and complexity of the organisation;

(2)the person is qualified and competent to perform both functions;

(3)any potential conflict of interest between the two functions is addressed.

(e)The independence of the compliance monitoring function should be established by ensuring that audits and inspections are carried out by personnel not responsible for the function, procedure or products being audited.

AMC1 ORGH.MGM.210(j) Personnel

ED Decision 2025/007/R

SUFFICIENT PERSONNEL

The GH organisation should plan in advance to ensure that it has sufficient personnel during peak periods, where the number of aircraft to be serviced is expected to be above the average level for which the GH organisation is prepared.

GM1 ORGH.MGM.210(j) Personnel

ED Decision 2025/007/R

PLANNING SUFFICIENT PERSONNEL FOR SAFE PROVISION OF GH SERVICES

To determine an appropriate number of qualified personnel as sufficient to ensure the safe provision of GH services, it is recommended that the GH organisation perform a task and resource analysis. It may consider several aspects, such as:

(a)types of GH services provided as per the declaration and tasks planned;

(b)number of stations covered;

(c)peak seasons and changes to the seasonal flight programmes;

(d)number of aircraft operators to which it provides services;

(e)estimated number of ad hoc requests for GH services per season;

(f)any GH services contracted to third parties.

ORGH.MGM.215 Facilities

Regulation (EU) 2025/20

(a)The ground handling organisation shall ensure availability of facilities allowing the performance and management of all planned tasks and activities provided for in Annex I and Annex II to this Regulation.

(b)Where the ground handling organisation uses a warehouse at the premises of an aerodrome within the scope of Regulation (EU) 2018/1139 to store and prepare cargo items containing dangerous goods, all the following requirements shall be complied with:

(1)the facility has clear in-bound and outbound flows and dedicated areas for dangerous goods acceptance and for loading and unloading of packages and ULDs;

(2)an X-ray verification area is provided;

(3)segregation of dangerous goods according to their compatibility and their separation from general cargo are ensured in accordance with the international standards and recommended practices;

(4)adequate conditions are provided to prevent any damage to the dangerous goods items;

(5)the storage area for dangerous goods items is visibly marked and is temperaturecontrolled, where applicable;

(6)an emergency toolkit is readily available.

AMC1 ORGH.MGM.215 Facilities

ED Decision 2025/007/R

STORAGE AREA FOR DANGEROUS GOODS

The GH organisation should ensure the following at the storage area for dangerous goods:

(a)A map of the dangerous goods storage facility is provided at all storage facilities and dangerous goods acceptance areas, indicating the following:

(1)purpose of the storage facility, including the classes and divisions of dangerous goods to be stored;

(2)storage area for temporary or longterm storage of dangerous goods, with visible markings for separation such as paint or redandwhitestriped ribbon;

(3)if applicable, the point of loading/unloading from/to ULDs or buildup of ULDs;

(4)public area or airside safety (restricted) area;

(5)entrance, exit and area for transit to the storage facility/warehouse;

(6)dangerous goods acceptance area;

(7)if applicable, positioning of Xray equipment;

(8)positioning of fire extinguishers.

(b)Any necessary approvals from other state entities — for example, for environmental protection, emergency response or the storage of explosive or radioactive material, are obtained in advance, or such approvals are obtained by the aerodrome operator providing the storage facility.

(c)Fire extinguishers specific to dangerous goods are stored and instructions for their use are available at the location.

(d)The storage conditions are adequate to address the specific hazards of the dangerous goods classes and divisions to be stored in the facility.

(e)Dangerous goods are segregated in accordance with ICAO’s Technical Instructions.

(f)The acceptance point is located as close as possible to the storage facility and properly marked as the dangerous goods acceptance point.

(g)A copy of the international standards and recommended practices for dealing with dangerous goods is available at the acceptance point.

(h)Emergency response procedures are easy to access or displayed in a visible location.

(i)The area where the acceptance documents are kept (dangerous goods acceptance checklist, airway bill, shipper’s declaration, etc.)is easily accessible to the authorised personnel.

ORGH.MGM.220 Software used for the provision of ground handling services

Regulation (EU) 2025/20

The ground handling organisation shall ensure that the software it uses for the provision of ground handling services is functional and does not negatively affect the safety of the flight. It shall ensure that:

(a)a backup system is available to ensure operational continuity in case of breakdown;

(b)the data is easily accessible and retrievable upon request by authorised persons;

(c)if the software includes document issuance, it complies with point ORGH.DOC.100;

(d)personnel are trained and competent to use the software to perform their assigned tasks.

GM1 ORGH.MGM.220 Software used for the provision of ground handling services

ED Decision 2025/007/R

SOFTWARE

(a)Any of the software used by the GH organisation to provide GH services is in the scope of point ORGH.MGM.220 if its malfunction would endanger the safety of a flight. The following list of activities or processes for which software is used is not exhaustive:

(1)departure control;

(2)turnaround coordination;

(3)deicing/antiicing documentation or management of holdover time tables;

(4)ramp resource planning;

(5)driving and operation of autonomous vehicles;

(6)baggage and cargo sorting, and processing/preparation of baggage and cargo for loading;

(7)processing and documentation of cargo or dangerous goods or completion of load control documentation.

(b)Before using new software, it is recommended that the GH organisation ensure, when feasible, that it has been properly tested for use in an aviation environment, is robust enough for use in daily operation and does not pose a risk to the safety of operations.

(c)Testing the software is recommended to ensure that it is fully functional following updates.

GM1 ORGH.MGM.220(b) Software used for the provision of ground handling services

ED Decision 2025/007/R

AUTHORISED PERSONS

The term ‘authorised persons’ is used in relation to the following, in compliance with the applicable data protection requirements:

(a)GSE maintenance,

(b)safety management,

(c)training,

(d)cybersecurity,

(e)inspection or occurrence investigation.

SUBPART DEC — DECLARATION

ORGH.DEC.100 Declaration — general requirements

Regulation (EU) 2025/20

(a)The ground handling organisation shall submit a duly filled declaration, including the annex for each aerodrome where it provides services, to the competent authority as identified in point ORGH.GEN.105.

(b)If the ground handling organisation applies any of the following changes affecting the content of the declaration, it shall notify the competent authority of those changes and submit an amended declaration:

(1)the name of the organisation;

(2)the name and/or contact details of the accountable manager;

(3)adding or removing aerodromes where it provides ground handling services;

(4)adding or removing ground handling services provided at an aerodrome listed in the declaration;

(5)new AltMoC;

(6)implementation of an industry standard.

(c)The ground handling organisation shall ensure compliance with this Regulation and with the information provided in the declaration and shall maintain continued compliance throughout its activities.

AMC1 ORGH.DEC.100 Declaration — general requirements

ED Decision 2025/007/R

SUBMITTING A DECLARATION

(a)The GH organisation should submit its declaration or amended declaration at least 10 working days before starting the operation or before the changes indicated become effective, respectively. This point does not apply to GH organisations that were already operating on the date of applicability of Commission Delegated Regulation (EU) 2025/20. Such GH organisations should comply with Article 5 of that Regulation.

(b)It is the responsibility of the GH organisation to ensure that the declaration has been successfully submitted to the competent authority. If the organisation does not receive acknowledgement of receipt of the declaration from the competent authority, as indicated in point ARGH.OVS.320 of Commission Implementing Regulation (EU) 2025/23 and AMC1 ARGH.OVS.320(a), it should contact the competent authority.

GM1 ORGH.DEC.100 Declaration — general requirements

ED Decision 2025/007/R

GENERAL

The intention of a declaration is to:

(a)have the GH organisation acknowledge its responsibilities under the applicable safety regulations;

(b)inform the competent authority of the existence of a GH organisation; and

(c)enable the competent authority to conduct oversight in accordance with Subpart ARGH.OVS of Commission Implementing Regulation (EU) 2025/23.

ORGH.DEC.105 Termination of the provision of ground handling services

Regulation (EU) 2025/20

If a ground handling organisation intends to permanently cease the provision of the ground handling service at an aerodrome, it shall:

(a)notify the aerodrome operator and the competent authority as soon as possible, as well as the impacted aircraft operators as per the agreement;

(b)submit to the competent authority a request for de-registration of the declaration, upon the date of termination of the provision of the services.

The prior notice to the aerodrome operator referred to in point (a) shall be made sufficiently in advance, as established in the formal arrangements with the aerodrome operator, so that the latter can take appropriate measures, as necessary, for the continuation of the service at the aerodrome.

AMC1 ORGH.DEC.105 Termination of the provision of ground handling services

ED Decision 2025/007/R

NOTIFICATION

The prior notice of terminating the provision of GH services at an aerodrome should be given with sufficient time in advance to enable the aerodrome operator to take appropriate measures for the continuation of the services at that aerodrome, if necessary.