An aircraft operator has a responsibility to ensure that contracted services are conducted in a manner
that meets its own operational safety and security requirements. Therefore a contract or agreement
shall be established with all external service providers (including the parent or an affiliate organization)
that conduct outsourced services for the operator. This contract should be also used as a basic
document for all further monitoring and auditing activities.
A contract or agreement is necessary to ensure that all outsourced services performed by the external
service provider are clearly explained and formally documented.
It not only sets forth the description of services the provider is expected to perform, but shall also
define the application of specific performance indicators and targets (i.e. measurable values) that will
be monitored by the operator. These measurable items specified in the contract (e.g. Service Level
Agreement SLA or Joint Procedure Manual JPM) together with operator's controlled documents (e.g.
Aircraft Handling Manual AHM), typically provide the basis for a monitoring process.
To ensure an effective monitoring process a range of internal and external methods might be used in
the oversight of external service providers. Methods might include auditing, systematic review and risk
assessment of reported hazards and/or occurrences, monitoring of performance output (e.g. Key
Performance Indicators KPIs), reporting and governance processes, monitoring and analysis of
targeted risk areas, as well as the establishment of an effective two-way communication link with the
service provider. Joint Procedure Manual JPM mentioned above is considered as good industry
There are some differences between monitoring certified external service providers (e.g. Part-145
Maintenance Organisations), uncertified external service providers (e.g. Ground Handling Agents) and
external service providers working under the Operator’s Quality System (e.g. organisations performing
some Continuing Airworthiness Task for Operator), but in all cases contract or agreement is the basis
for monitoring and auditing. IOSA or ISAGO registration is a way for an external service provider to
demonstrate fulfillment of requirements that affect the safety and/or security of operations and would
be acceptable as a method of monitoring when such registration is used in conjunction with a risk
assessment of the provider.
AUDIT ITEMS LIST
Certified external service providers
(e.g. Part-145 AMO Approved Maintenance Organisation, Part-
147 AMTO Approved Maintenance Training Organisation and Air Crew ATO Approved Training
These service providers are certified according to the applicable regulation and oversighted by the
applicable National Aviation Authority NAA. Basic intention of this certifications schema is that aircraft
operators can consider external service providers having appropriate certificate is in compliance with
applicable regulation without any additional checking. (However, in real life not every National Aviation
Authority shares this opinion).
But in any case, checking important safety and airworthiness related regulatory and/or standard
requirements shall be included in the Audit Items List of your contract or agreement. To clarify, Audit
Item List should be structured i.a.w. contract or agreement. It is very helpful if regulation or standard
defines contract or agreement structure (e.g. by Appendix XI to AMC M.A.708(c) for maintenance
contracts) as this might be used also as structure of Audit Item List. However, I would suggest you
check what is really important to you also by your audit. This can be done by including safety critical
regulatory or standard requirements into most suitable Audit Items from the List.
Uncertified external service providers
(most of airport Ground Service Provider, e.g. GHA Ground
Handling Agent falls in this category).
For these service providers there are no mandatory regulations or certifications. Some providers might
be ISAGO registered and actually this is the only certificate you can take into account for
monitoring/auditing uncertified service providers. However, it is a good industry practice to take the
ISAGO standard as the basis for your own Audit Item List. Joining industry pools for monitoring /
auditing Fuel and De/Anti-icing providers might be a wise solution.
External service providers working under operator’s responsibility
(e.g. organisations performing
Continuing Airworthiness Task for Operator)
These external service providers actually perform work for which the operator is responsible in front of
the related National Aviation Authority. Because of this, monitoring and auditing external service
providers working under operator's responsibility is even more important. Due to importance for safe
and airworthy operation, EU regulation defines contract or agreement structure for subcontracting
continuing airworthiness management tasks by Appendix II to AMC M.A.711(a)(3) and it is a good
industry practice to include these requirements in your contract Audit Item List.
Be aware that sometimes you would have less work if you perform Continuing Airworthiness Tasks by
yourself than subcontracting and continuously monitoring external service providers compliance with
regulatory requirements. So, think twice before you outsource Continuing Airworthiness Tasks.
Customer is King! Partnership with external service providers should be clearly visible from the
contract or agreement and related documents. However be aware of possible company culture
differences. Even thousands of contract pages would not prevent operational problems in case of big
company cultural differences, e.g. operators focused on customer satisfaction may expect frequent
operational problems originated from maintenance service providers focused only on profit (usually
proudly declared by themselves as lean).
On the other side, not many pages are needed to define partnership with external service providers
which share the same values, therefore think well before you sign the contract, and don’t let only top
level management and financial staff decide who is the appropriate external service provider. Your
operational staff and your customers would appreciate this!
And don’t forget, contract or agreement based audit shall take a look on both contractual sides, as
every side has some contractual obligations needed to be continuously fulfilled to make possible the
required level of service to be provided by the external service provider.
Aviation Safety and Compliance Consultant