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ANNEX VIII : [PART-DTO] - Declared Training Organisation ( Easy Access )

DTO.GEN.210 Personnel requirements - Regulation (EU) 2020/359

  1. A DTO shall designate:
    1. a representative, who shall be responsible and duly authorised to do at least the following:
      1. ensure compliance of the DTO and its activities with the applicable requirements and with its declaration;
      2. develop and establish a safety policy which ensures that the DTO's activities are carried out safely, ensure that the DTO adheres to that safety policy and take the necessary measures in order to achieve the objectives of that safety policy;
      3. promote safety within the DTO;
      4. ensure the availability of sufficient resources within the DTO so that the activities referred to in points (i), (ii) and (iii) can be carried out in an effective manner.
    2. a head of training, who shall be responsible and qualified to ensure at least the following:
      1. that the training provided complies with the requirements of Annex I (Part-FCL), Annex III (Part-BFCL) to Commission Regulation (EU) 2018/395 and Annex III (Part-SFCL) to Commission Regulation (EU) 2018/1976 and with the DTO’s training programme;
      2. the satisfactory integration of flight training in an aircraft or a flight simulation training device (FSTD) and theoretical knowledge instruction;
      3. the supervision of the progress of students;
      4. in the case referred to in point DTO.GEN.250(b), the supervision of the deputy head or heads of training.
  2. A DTO may designate a single person as its representative and its head of training.
  3. A DTO shall not designate a person as its representative or its head of training if there are objective indications that he or she cannot be trusted to carry out the tasks listed in point (a) in a manner which safeguards and furthers aviation safety. The fact that a person has been subject to an enforcement measure taken in accordance with point ARA.GEN.355 in the past three years shall be deemed to constitute such an objective indication, unless that person can demonstrate that the finding leading to that measure, by reason of its nature, scale or impact on aviation safety, is not such as to indicate that he or she cannot be trusted to carry out those tasks in that manner.
  4. A DTO shall ensure that its theoretical knowledge instructors have either of the following qualifications:
    1. practical background in aviation in the areas relevant for the training provided and have undergone a course of training instructional techniques;
    2. previous experience in giving theoretical knowledge instruction and an appropriate theoretical background in the subject on which they will provide theoretical knowledge instruction.
  5. Flight instructors and flight simulation training instructors shall hold the qualifications required by Annex I (Part-FCL), Annex III (Part-BFCL) to Commission Regulation (EU) 2018/395 and Annex III (Part-SFCL) to Commission Implementing Regulation (EU) 2018/1976 for the type of training they provide.

GM1 DTO.GEN.210(a)(1)(i) Personnel requirements - ED Decision 2018/009/R


The following list provides an overview of the main elements of the occurrence-reporting system that is compliant with Regulation (EU) No 376/2014 and provides references to the relevant articles of that Regulation.

  1. Occurrence-reporting system that caters for both mandatory and voluntary reporting (cf. Articles 4 and 5).
    Note 1: The mandatory reporting system established under Regulation (EU) No 376/2014 is also intended for the reporting of those additional items that qualify for mandatory reporting and are defined in the EASA implementing rules.
    Note 2: The voluntary reporting system is intended to facilitate the collection of details of occurrences that may not be captured by the mandatory system and of other safety-related information which is perceived by the reporting organisation as an actual or potential hazard to aviation safety.
  2. Designation of one or more persons to independently handle the collection, evaluation, processing, analysis and storage of details of occurrences with regard to data collection and hazard identification (cf. Article 6(1)).
    Note 1: In agreement with their competent authority, small-sized organisations may make use of simplified mechanisms to ensure the collection, evaluation, processing, analysis and storage of details of occurrences, possibly by sharing those tasks with other similar organisations.
    Note 2: An existing internal safety-reporting scheme, which collects safety-relevant data, proposals and information, including data, proposals and information on potential safety issues that have not resulted in any occurrence, may serve as a basis for the mandatory and voluntary occurrence-reporting system. From this pool of safety relevant information and data collected internally, the organisation will determine whether a mandatory report is required or whether a voluntary report may be adequate.
  3. Reporting details of occurrences collected under the mandatory scheme as soon as possible and in any event no later than 72 hours after becoming aware of the occurrence (cf. Article 4(8) & (9)).
    Note 1: The reference to ‘becoming aware of’ an occurrence implies that a person in the organisation identifies the occurrence as falling into the category of a mandatory occurrence report — usually through being involved in the occurrence or witnessing it, but also on review or investigation of information reported to the organisation’s safety reporting scheme. In the case of design or production organisations, the 72-hour period starts at the point when the unsafe condition is identified.
    In the case of automated data collection systems, the 72-hour period starts when the person that is responsible for the analysis of the data detected the reportable occurrence.
    Note 2: The 72-hour period does not apply to the reporting of details of occurrences which may involve an actual or potential aviation safety risk and safety-related information collected under the voluntary scheme. These are to be reported in a timely manner (cf. Article 5(5) & (6)).
  4. Establishment of data quality checking processes to ensure that the information initially collected and the data stored in the database(s) are consistent (cf. Article 7(3)).
    Note: It is understood that data quality checking processes should address four main areas:
    • errors in data entry;
    • completeness of data, specially referring to mandatory data;
    • proper use of the ADREP 32 taxonomy;
    • improve data consistency, notably between the information collected initially and the report stored in the database (cf. Article 7(3)).
  5. Storage of occurrence reports that qualify for mandatory and voluntary reporting in one or more databases (cf. Article 6(5)) using standardised formats to facilitate information exchange and which are compatible with the ECCAIRS 33 software and ADREP taxonomy (cf. Article 7(4)).
    Note: Organisations that are able to report through an ECCAIRS software compatible reporting system provided by their competent authority are deemed to be automatically compliant with the reporting system requirements in Article 7(4) and do not need to have their own ECCAIRS software compatible reporting system.
  6. Application of the safety policy (cf. AMC1 DTO.GEN.210(a)(1)(ii)) to occurrences:
    1. identification of the safety hazards that are associated with identified occurrences or groups of occurrences reported to the competent authority (cf. Article 13(1));
    2. analysis of the related risks in terms of probability and severity of the outcome, as well as assessment of the risks in terms of tolerability;
    3. based on the result of the risk assessment: determination of the need for mitigation action, as required for improving aviation safety (cf. Article 13(2)); and
    4. monitoring the timely implementation and effectiveness of any mitigation action required (cf. Article 13(2)).
  7. In addition to the actions required under paragraph (f) above, where the organisation identifies an actual or potential aviation safety risk as a result of the analysis of occurrences or group of occurrences:
    1. transmission of the following information to the competent authority within 30 days from the date of notification of the occurrence to the authority (cf. Article 13(4)):
      1. the preliminary results of the risk assessment performed; and
      2. any preliminary mitigation action to be taken.
    2. where required, transmission of the final results of the risk analysis to the competent authority as soon as they are available and, in principle, no later than 3 months from the date of notification of the occurrence to the authority (cf. Article 13(4)).
      Note: The legal obligation to provide the initial results of the analysis of the occurrence, follow-up reports and final results lies with the other organisation that issued the initial report. Where an organisation receives a copy of a report from another organisation that initially reported the occurrence to the competent authority, depending on its contribution to the actual or potential aviation safety risk underlying the occurrence, it may however be required to perform its own analysis of the issue reported and to provide a follow-up report to the competent authority.
    3. Safety policy and just culture: Consultation of staff representatives to ensure mutual agreement on and adoption of the rules describing how ‘just culture’ principles are guaranteed and implemented within the organisation.
      Note 1: The purpose of those rules is to ensure that employees and contracted personnel that report or are mentioned in occurrence reports, both mandatory or voluntary, are not subject to any prejudice by their employer or any other organisation for which the services are provided on the basis of the information supplied by the reporter (cf. Article 16(9)), unless an exception applies (cf. Article 16(10)).
      Note 2: Staff representatives may be nominated either by the trade union(s) or by the staff themselves.
    4. Ensuring that employees and contracted personnel are regularly provided with information concerning the analysis of, and follow-up on, occurrences for which mitigation action is taken (cf. Article 13(3), while ensuring that only disidentified information is disseminated.
    5. Ensuring that personal details are made available to staff of their organisation, other than the persons designated in accordance with paragraph (2), only where absolutely necessary to investigate occurrences with a view to enhancing aviation safety.
    6. Ensuring that reports addressed to the competent authority contain at least the information listed in Annex I to Regulation (EU) No 376/2014.

AMC1 DTO.GEN.210(a)(1)(ii) Personnel requirements - ED Decision 2018/009/R


  1. The safety policy should define, in relation to the DTO training programme, at least the means and methods used for:
    1. hazard identification;
    2. risk assessment; and
    3. effectiveness of the mitigation measures (implementation and follow-up).
  2. The safety policy should additionally include the procedures required for occurrence reporting pursuant to Regulation (EU) No 376/2014 (cf. GM1 DTO.GEN.210(a)).

AMC1 DTO.GEN.210(a)(2) Personnel requirements - ED Decision 2018/009/R


  1. The HT should, with regard to the size and the training scope of the DTO, possess sufficient managerial capabilities in order to discharge their responsibilities, and should:
    1. in the case of a DTO that provides training in aircraft or FSTDs, hold an unrestricted instructor certificate in accordance with Part-FCL with instructional privileges that are relevant to the training provided by the DTO, including sufficient experience as necessary;
    2. in the case of a DTO that provides theoretical knowledge training only, have appropriate experience in aviation and knowledge relevant to the training provided.
  2. At a DTO that provides training courses for different aircraft categories, the HT should be assisted by one or more nominated deputy HTs qualified in accordance with paragraph (a) and with regard to the other category or categories of aircraft.

GM1 DTO.GEN.210(a)(2) Personnel requirements - ED Decision 2018/009/R


‘Sufficient experience’, as per AMC2 DTO.GEN.210(a)(1) paragraph (a)(1), means that the HT should have gained the required experience as an instructor in order to have the capacity to administer the particular training activity of the DTO in question. The following factors should be taken into consideration for determining the experience required:

  1. training scope of the DTO, including specific training courses (e.g. aerobatic rating, sailplane cloud flying rating, examiner courses for sailplanes and balloons);
  2. location of the DTO training area (e.g. mountains, sea, congested airspace);
  3. size of the DTO (volume of activity, number of training aerodromes and operating sites);
  4. use of FSTDs;
  5. training aircraft models used by the DTO.

GM1 DTO.GEN.210(c) Personnel requirements - ED Decision 2018/009/


Examples of objective indications that a person cannot be trusted to carry out the tasks of a representative or an HT in a manner which safeguards and furthers aviation safety.

If that person, within the last 5 years preceding their nomination as representative or HT, in a declaration in accordance with Part-DTO:

  1. holds or has held a pilot licence and that licence and/or any associated ratings, certificates or authorisations have been subject to limitation, suspension or revocation;
  2. has knowingly and deliberately been responsible for committing any non-compliance with the Basic Regulation and its implementing rules.

AMC1 DTO.GEN.210(d);(e) Personnel requirements - ED Decision 2018/009/R


In order to ensure and monitor that instructors maintain their required qualification, DTOs should permanently keep a list of all instructors, including information on their instructional privileges as well as on the validity periods of their licences, ratings and certificates, including their medical certificates.

GM1 DTO.GEN.210(d);(e) Personnel requirements - ED Decision 2018/009/R


  1. The ratio of all students to flight instructors should allow maintaining the quality and safety of the training provided.
  2. Class numbers in ground subjects involving a high degree of supervision or practical work should not exceed 28 students.