Expositions for flying training organisations
Learn about expositions including who needs to submit one, what they should contain, how they're structured, how they're assessed and what support is available to help you develop one.
Who should read this information?
- Existing operators transitioning to Civil Aviation Safety Regulations (CASR) for which the development of an exposition is a regulatory requirement.
- New entrants to the aviation industry who are required to submit an exposition to CASA as part of the application and approval process.
- Exposition document writers.
What is an exposition?
An exposition is a document, or set of documents, which describe how your organisation will conduct its operations safely.
It sets out-both for CASA and the personnel involved in your operation-how you intend to comply with all applicable legislative requirements and manage the safety of your operation.
Do I need to have an exposition?
The regulations that are relevant to your operations will prescribe whether or not you need to have, and use, an exposition.
What should my exposition include?
Where you are required to have an exposition, the relevant regulations will outline what you must include. Generally, you will need to include information about your organisation, personnel, facilities, policies, systems and procedures for conducting your activities.
CASR Part 142.340 requires a Part 142 flight training organisation to describe procedures by which the operator conducts and manages its training activities, including the supervision of instructors and trainees.
Your exposition must accurately reflect how you will conduct your activities. It needs to be written and structured in a logical way. This will ensure the relevant parts can be readily identified and provided to your personnel who are responsible for complying with them. The procedures in your exposition should also provide enough detail so that your personnel can conduct their activities consistently in line with your intentions.
Each procedure should address, where required:
- what must be done
- who should do it
- when it must be done
- where it must be done
- how it must be done
- how the procedure is monitored and improved.
Once the relevant authorisation has been issued by CASA, you are obliged to conduct your activities in accordance with your exposition.
How is an exposition structured?
An exposition can be structured as a set of documents, or as a single document.
If structured as a set of documents, your exposition might include a 'principal document' which contains all the information which is common for all your activities, manuals which relate to specific aspects of your activities and the various systems and procedures you will use when conducting your activities. Your exposition would comprise both the principal document and the other manuals. If done this way, the principal document will need to reference the other manuals (or sections of your manuals) and state that they form part of the exposition.
CASA provides sample principal exposition documents for each new regulation. These sample documents contain a recommended table of contents and structure that you can use regardless of whether your exposition is a set of documents or a single document. For most existing operators, this method is likely to be the easiest because your existing manuals can form part of the exposition, often with only minor modifications required.
Option 1: the exposition document can be structured to include a set of documents including the operations manual, training plans and syllabuses, safety management system manual, dangerous goods manual, fatigue risk management system manual and other manuals/documents.
For most existing operators, this method is likely to be the easiest because your existing manuals can form part of the exposition, often with only minor modifications required.
For a CASR Part 142 flying training organisation, existing manuals could include your operations manual, safety management system manual, quality management system manual, dangerous goods manual, fatigue risk management system manual, training and checking manual and other manuals or related documents such as training plans, syllabuses and checklists. In this case, these manuals (as amended and updated) could form part of your exposition.
Alternatively, you may choose to present your exposition as a single document with all the required information contained in one spot. If you submit your exposition in this format it is still a good idea to include an introductory section that contains an overview of how the exposition is structured, and where compliance with certain legislative requirements can be found in the exposition.
This will help keep your exposition up to date, make it simpler to identify what parts need to be provided to your personnel and make CASA's assessment of your exposition quicker and easier.
Option 2: the exposition can be structured as a single document inclusive of operational procedures, training, safety management, dangerous goods, fatigue management and other information.
What is a 'principal document'?
A principal document can provide an overview of your organisation and contain common information. As noted above, it must also provide reference as part of your exposition to your other manuals (subject to them being reviewed and amended where necessary), that demonstrate your compliance with the applicable legislative requirements.
The type of information you might place in your principal document could include:
- details of your approved activities
- your locations
- your corporate and organisational structure
- key personnel details
- change management processes.
How should I develop my exposition?
Many of your procedures will already be compliant with the new regulations. Other procedures may need to be modified, or you may need to develop new ones. Therefore, the first step in developing your exposition should be to conduct a gap analysis of your existing processes against the new requirements to see what (if any) additional documentation is required, or what needs to be amended.
Part 142 operators will need to amend their training courses to reflect competency based training principles, to meet the knowledge and competency standards specified in the Part 61 Manual of Standards and to comply with the applicable provisions of CASR Part 61.
How much detail should I include in my exposition?
The level of detail to be included in an exposition is determined by an operator. However, you do not have to duplicate content that already exists within your manual suite. Instead, reference in a principal exposition document can be made to manuals (once they have been amended, if necessary), which contain existing procedures that meet the requirements of the legislation.
Please note that once reference is made to these manuals in this way, they then form part of your exposition. Any changes to these documents are classified as either 'significant' or 'non-significant' and need to be managed in accordance with the change management process outlined in your exposition.
Significant changes generally include things like changes to the location and operation of your activities or services, your corporate or organisational structure, key personnel and reporting lines. A full list of those which are relevant to your operations can be found in the related regulations under the definition of significant change.
Will one exposition cover the requirements for all my operations?
Operators are not obliged to create multiple expositions to comply with each operational CASR Part that requires one. It is up to the operator to decide whether they have one exposition or more than one exposition. In some cases, it might be sensible to have multiple expositions for practical working purposes.
If you choose to have a single exposition covering all the CASR Parts that are relevant to your operations, you simply need to expand your principal document to ensure it links to, or references, all the relevant sections in your existing manuals. However, you will still be required to submit the exposition to CASA each time you are required to for transition purposes.
Are all expositions the same?
No. There is no single exposition format that will meet the needs of all organisations. The structure and content of your exposition must reflect your particular organisation, including its structure, policies and procedures.
One of the key features of an exposition is that it gives you the freedom to meet the safety outcomes in a way that fits well and is appropriate for your organisation.
What support is available to help me develop my exposition?
CASA has published a range of guidance material online to help operators develop their expositions and understand the requirements that must be met. This includes:
- Sample exposition templates and guidance
- Sample flying training syllabuses
- CASR Part 142 technical assessor guidance
- Manual Authoring and Assessment Tool (MAAT).
CASA's technical assessor handbooks may also be helpful to use when you are developing an exposition. While they are not specifically designed to help you develop an exposition, they provide a guide to the sorts of matters CASA inspectors will be considering when they assess your compliance against the regulations.
Who are the Part 142 sample exposition templates designed for and which one should I use?
CASA has published two sample templates to help organisations develop a part 142 exposition.
The Microsoft Word Part 142 Sample Exposition, released in August 2016, is based on the fictitious organisation Sample Aviation Pty Ltd. It is designed for operators who would like to submit their exposition as a single document and contains an operations manual and training management system, as well as an example of how to manage fatigue under Appendix 6 of Civil Aviation Order 48.1. It will require the operator to develop their own Safety Management System Manual.
This template uses Sample Aviation Pty as an example of an operator that is already conducting Part 141 activities and has developed an operations manual using the Part 141 Sample Operations Manual as a guide. The operator has grown and expanded its business, and now needs to develop a Part 142 exposition. The operator will be conducting training in a number of single-engine aircraft, and staff numbers have increased to approximately 15 employees. In addition to their Part 141 training, the operator will be offering full-time integrated training to a commercial pilot licence standard.
This sample exposition serves as an easy-to-tailor template for operators who are conducting activities similar to the fictitious operator profile. While it is somewhat flexible, it is primarily designed for organisations that would like to submit their exposition as a single document and employ 15 to 25 people.
An online Part 142 exposition was also released in CASA’s Manual Authoring and Assessment Tool (MAAT) in November 2014, and continues to be available.
Any flying training organisation can choose to use this template, and can also customise it to fit their own types of operations. The MAAT exposition template allows for additional manuals (such as an operations manual or dangerous goods manual) to be referred to as separate documents, or attached to the exposition as required. The MAAT template also allows operators to develop additional manuals within MAAT to form part of their exposition.
To access the templates go to CASA website and click on ‘Guidance for Part 142 operators.’
MAAT is a free, easy to use online tool which contains a number of templates to assist organisations applying for an authorisation or transitioning to new regulations. It does all of the formatting for you, including producing and updating the list of effective pages, allowing you to focus on writing the technical content. Guidance material, sample text, links to relevant information and the ability to add your own notes and include comments to communicate with the assessing CASA inspector are some of the standard features of MAAT. The manuals and expositions are produced in a PDF format which can be incorporated into your manual suite after the assessment process is complete. More information about MAAT, including how you can register as a new user or for a training session, is available on the CASA website.
When do I need to submit my exposition?
Applicants for an initial issue of a CASA approval to conduct Part 142 flight training activities must submit an exposition as part of their application.
Existing operators transitioning to Part 142 will need to submit their exposition within a timeframe agreed with their local CASA office, to allow CASA to assess the exposition and issue an approval before the transition period ends on 31 August 2018.
For more information about when and how you should submit your exposition, talk to your local CASA Regional Office.