Holders of airline operating licences and air operator’s certificates (AOC) need to take action to ensure they can continue to operate in and out of the UK and the EU.
UK commercial air transport operators have until now implemented EU baseline measures from EC 300/2008 and EU 2015/1998 when writing an Aircraft Operator Security Programme (AOSP), occasionally referred to as an Airline Security Operating Programme (ASOP). UK law for aviation is empowered by the statutory instrument of the EU Withdrawal Act 2018. The withdrawal included a transition period which ended on 31st December 2020. Having left the EU the UK now defaults to the primary international measures of ICAO Annex 17.
The UK CAA ordered air transport operators to submit their AOSP in accordance with ICAO Annex 17 requirements by 31st December 2020. To many, this may have been seen as a paperwork exercise, with a simple change of references from EU to ICAO being all that was required. The reality is not so straightforward, in fact fundamental changes are required in the transition from EU to ICAO Annex 17 baseline measures.
It may be tempting to try to respond to everything Annex 17 provides guidance on but this could result in an AOSP which is unmanageable, verbose and potentially harmful: if the AOSP becomes ‘the’ security programme, the CAA will find a commercial air transport operator deficient if they have not implemented all aspects of their AOSP.
Conversely, if the AOSP is too light in content and fails to describe the security operation adequately, the operation may not be implementing what is necessary to maintain a secure operation; this may result in unnecessary risks, from the potential exploitation of weak security, or by a detrimental assessment by the regulators.
The number of pages in an AOSP is not a measure of quality, however if your AOSP is less than 80 pages it’s likely to be missing essential security information. If it’s in excess of 250 pages you either have an extremely complex multifaceted operation, or your AOSP is overly wordy.
The UK CAA were inundated with AOSPs arriving just in time to meet the deadline, at a point where Christmas holidays may have adversely impacted their ability to read them.
While you may have submitted an AOSP in time to meet the deadline, if it fails to meet the requirements you may not be aware until notified by the CAA, and follow-up inspections may be required.
If you require assistance crafting your AOSP, we are on hand to help
We work with many commercial air transport operators in the creation of AOSPs and are delighted with the feedback received.
We use our knowledge and experience to ensure your AOSP is crafted to meet your requirements and those of the CAA.
Whether you’d like a review of your AOSP, help with the creation of your AOSP or a full bespoke AOSP created on your behalf, we can help.
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