Compliance statements
for all operations other than High Capacity RPT
Completion of a Compliance Statement assists both the applicant in achieving regulatory compliance and CASA's project team to verify that compliance. Section 28(1)(a) of the Act requires CASA to be satisfied that an applicant has complied with, or is capable of complying with, the regulatory requirements that relate to safety.
The Compliance Statement is used in the evaluation of an applicant's Operations Manual and, where applicable, Maintenance Control Manual.
Compliance lists
These two documents list the applicable sections of the Act, Regulations and Orders. They will assist you to complete your compliance statement.
Some items on the lists are only applicable to certain classes of operation, certain aircraft or certain specialised operations. LCRPT operators will use List A, and Charter and Flying Schools will use List B. CASA may also direct particular operations to submit a Compliance Statement from either List A or B as appropriate.
List A is to be completed by low capacity RPT operators or as directed by CASA. (132 k RTF document - MS Word compatible)
List B is to be completed by Charter operators and Flying Schools as directed. (100 k RTF document - MS Word compatible)
Where items are bold in either List A or List B, they refer to the Civil Aviation Regulations of 1998.
In considering an applicant's regulatory compliance capability, CASA needs to know that the applicant is either aware of, or has written procedures for, each applicable regulatory provision. Therefore, each item in the Compliance List is categorised as either 'A' or 'C'.
'A' indicates that the applicant may need to be aware of the requirement of that legislation.
'C' indicates that an applicant, where applicable, will need to develop specific
procedures to achieve compliance.
Compliance procedures need to be included in the company's relevant manual(s).
Furthermore, where legislation places a direct obligation on an operator or CofR holder by means of specific reference - for example, "CAR 219 -An operator shall not permit a pilot to act...", - the symbol * is added to the letter A or C in the low capacity RPT List A and only to the letter C in the case of List B.
In completing the Compliance Statement, the applicant must make a response against each applicable item in the Compliance List in accordance with the following procedures:
Against the annotation A, in List A and for existing AOC holders who use List B and have not been notified in writing that a meeting is required, the response should be an acknowledgement of the requirement - for example: "Acknowledged"
Against the annotation C, in both List A and List B the form of compliance should be described by reference to the applicant's relevant manual- for example:
| Legislation | Compliance | |
|---|---|---|
| C | CAR 176 | Operations Manual, subsection A2.6/A6.7 |
Where the symbol * is included with the annotation A or C, in List A and only against the annotation C in List B the response should include a further statement of management responsibility using such words as: "Management accountability is acknowledged" - for example:
| Legislation | Compliance | |
|---|---|---|
| C* | CAR 224 | Operations Manual, subsection Al.6 Management accountability is acknowledged. |
Where an item in the Compliance List is judged by the applicant to not be applicable to his or her operation, then the applicant may state against that item words such as: "Not applicable"
In most cases, reference to the root CAR or CAO alone, as shown in the Compliance List, will not provide the required level of detail. The Act, CARs and CAOs are divided into parts, sections, subsections, paragraphs, subparagraphs and sub-subparagraphs. Where compliance with a particular provision is required to be shown, it must be referenced at the level of the applicable legislative text.
For example, it will be necessary for an applicant to show compliance with many paragraphs in CAO 20.11. Each requirement will need to be listed as in the following example:
| Legislation | Compliance |
|---|---|
| CAO 20.11.14.1.3 | The oral briefing by the PIC will be supplemented by a printed briefing card located at a convenient location for use by the passengers. The oral briefing by the PIC will advise the passengers of the location of the card and its contents. A briefing card will be supplied for each type of aircraft with a seating capacity of more than 6 seats operated by the company. |
Signing the document, meeting with CASA
The Compliance Statement must be signed by the owner/director. Each page and any hand-written amendments must be initialled by the signatory.
In the case of a new applicant, or an existing applicant who has shown by various non-compliance that there is a deficiency in regulatory knowledge, compliance will be acknowledged at a meeting between the applicant (directors) and CASA. At the conclusion of the meeting the applicant (directors) will sign each page of the Compliance Statement for retention by CASA. This process will be completed prior to the AOC being issued.
Further information
The information on this page has been extracted from the Air Operator Certification Manual. If you need additional information refer to the manual or contact your local CASA office