Possible Implications of a No-Deal Brexit on Airline Operations

Many businesses were in the midst of implementing operational changes to function in the new UK/EU trading environment, when the COVID-19 pandemic affected the world in an unprecedented way. However, ahead of the industry is the Transition Period which will last until 31^st December 2020. Until that time, UK airlines remain part of EASA and subject to the requirements of EU-Ops; operations to and from the EU 27 countries remain unhindered. However, there is much to achieve and a whole host of agreements have to be set in place if the United Kingdom are to exit the EU in an orderly fashion. It is possible that the UK could leave the EU with no agreement in place (a hard BREXIT). This raises the spectre of what happens to the UK aviation industry in the event of a no-deal exit?

How will this affect my manuals?

In the event that the UK CAA becomes the National Regulator, independent of EASA, it is highly likely that the UK will continue to operate in accordance with EU Ops as stated on the CAA web site. However, the implication here is that all operational manuals will need to be amended to reflect the new, UK regulations (it is presumed that these would be in the form of a revised Air Navigation Order). This is likely to involve a lot of work for all operators but especially so for those still using either paper manuals or multiple tool sets across different fleet types, for management of content, distribution and viewing. Leveraging the benefits of an enterprise-wide solution for managing documentation, and partnering with a proven aviation software provider such at Vistair, will undoubtedly relieve the technical burden associated with manual changes, freeing up time to focus on core operations.

Of course, it is not just the airline operations that will be affected by this possible outcome. The entire industry will face a degree of upheaval. OEMs, CAMOs, Part 145, Part M, ANSPs, Airports, Aero-Medical and ATOs (to name but a few) will all need to undertake amendment processes to adapt their approved manuals to the revised, UK regulations.

Should it be necessary for all airlines and service providers to amend their operational manuals to reflect the new, UK regulations, it is assumed that the CAA will allow for a period of grace to achieve this laborious process. Certainly, the team at Vistair have been preparing for this eventuality and will have personnel ready to undertake the amendment process for our existing and future customers.

Will EASA conduct safety Audits on my Operation?

EASA reserve the right to conduct meetings and safety audits of Third Country Operators. Since the 1^st January 2020, these events have attracted charges. Current advice is that a meeting would be held in EASA Headquarters in Cologne and cost the operator €10,000. A safety audit would cost €19,000 in addition to per day and travel costs for the EASA team. Admittedly, it is unlikely that EASA would wish to audit UK operators because of our continued, close alignment with EU-Ops and the fact that the CAA will continue to exercise oversight of the industry. However, it is in all operator’s interests to make sure that your SMS is compliant and that you can demonstrate to any authority that you have a robust and reliable approach towards safety management that is backed up by a sound reporting culture.

This often requires a well-designed reporting software that facilitates the collection of consolidated, reliable and comprehensive data for evidenced-based decision making. Vistair’s SafetyNet platform for example, delivers a “full picture” of safety and risk, enabling partner organisations to proactively target safety and risk issues. With easy-to-use, desktop and mobile-first interfaces (online, offline), SafetyNet has proven to encourage voluntary staff reporting , playing an active role in enhancing an airline's safety culture.  

Conclusion

Whilst a no-deal exit from the EU remains uncertain, the implications of it are actually quite large. Certainly, the UK CAA has completed a huge amount of planning for this eventuality and it would be in your interests to do likewise. An early application for TCO approval is a must (as indicated by the fact that most UK organisations have already completed this process). It is recommended that you ensure that your SMS is fully compliant and also that you start early liaison with your document management system provider. Should the UK depart from EASA, there is likely to be something of a rush to get all operational manuals amended accordingly. Rest assured, Vistair is standing by to assist with the short- and long-term needs of the industry.