BR-ANAC-ITRP cheat sheet

ANAC is Brazil's civil aviation authority; it issues RBAC (Regulamento Brasileiro da Aviação Civil) regulations, which map closely onto ICAO Annexes but are legally distinct national rules.

Hierarchy of norms: Lei 7.565/1986 (Código Brasileiro de Aeronáutica) sits above ANAC resolutions and RBAC; an RBAC provision conflicting with the CBA is invalid to that extent.

ICAO Annexes bind Brazil internationally, but domestically they take effect only once incorporated through an RBAC or ANAC resolution; cite the RBAC article, not the Annex paragraph, in enforcement work.

RBAC 121 governs scheduled and supplemental airline operations; RBAC 135 governs commuter and on-demand operations; RBAC 91 sets the general operating and flight rules applying to all aircraft.

ANAC rulemaking follows a defined cycle: regulatory agenda, Regulatory Impact Analysis, public consultation (consulta pública), draft resolution, and publication in the Diário Oficial da União.

An ANAC resolution generally enters into force on its publication date unless it states a later compliance date; operators must track both the effective date and any transition period.

ANAC issues Air Operator Certificates (AOC) and operating specifications; the certificate holder's authorizations are limited to the aircraft types, areas, and kinds of operation listed in those specifications.

State obligations are shared: ANAC regulates and certifies; the CENIPA investigates accidents; the DECEA provides air traffic services and airspace rules under COMAER. Do not attribute investigation to ANAC.

Airworthiness certification has two gates: type certification of the design (RBAC 21) and individual airworthiness certification of each aircraft (Certificate of Airworthiness, CA).

A CA remains valid only while the aircraft conforms to its type design and is maintained in accordance with the approved maintenance program; modification without approval voids conformity.

Airworthiness Directives are mandatory; compliance is not discretionary, and the AD's stated method (repetitive inspection, terminating action, or both) defines the required response.

Maintenance programs follow the MSG-3 logic: tasks are derived from failure consequences (evident, hidden, safety, economic) rather than from component wear alone.

Release to service after maintenance requires an authorized certifying person (normally an aircraft maintenance engineer with the appropriate type rating) and a signed maintenance record.

Continuing airworthiness management includes tracking life-limited parts, AD status, service bulletin embodiment, mass and balance, and defect deferral under the approved MEL.

The Minimum Equipment List is operator-specific and approved by ANAC; it derives from the Master MEL and defines dispatch conditions for inoperative items. A defect not covered by the MEL grounds the aircraft.

Export and import of aircraft require ANAC acceptance of the foreign airworthiness authority's certificate, plus verification of AD and maintenance status under the import regulation.

Operational control is the exercise of authority over flight initiation, continuation, diversion, and termination; the pilot in command has final authority in flight, while the operator retains dispatch responsibility.

Fuel planning uses the reserve framework: taxi fuel, trip fuel, contingency, alternate fuel, final reserve, and any additional fuel; the final reserve is not usable for normal planning.

Takeoff and landing performance must account for the most limiting runway condition, obstacle clearance, and the applicable factored distances; wet or contaminated runways change the required distances.

Approach minima are tied to the aircraft's certification and crew qualification: Category I, II, and III minima require specific equipment, training, and runway approval.

Crew duty and rest limits are prescribed by the applicable RBAC subpart; flight time, duty period, and rest are distinct quantities and are logged separately.

An MEL/CDL deferral must be evaluated before dispatch against the specific flight's conditions; a deferral valid for one route may be prohibited for another (for example, extended overwater).

Weight and balance must be computed for the actual load; the load sheet must be verified before departure, and last-minute changes require recomputation.

Emergency authority: the PIC may deviate from rules to the extent necessary in an emergency, but must report the deviation to the operator and the authority afterward.

Licences are issued by ANAC and are type- or category-specific; privileges are limited to the ratings endorsed, and exercising a privilege without the rating is a violation.

Recency requirements are separate from the licence: recent experience in the preceding period (landings, hours, or simulator sessions) must be met before acting as pilot in command.

A type rating requires approved training, a knowledge examination, and a practical test; a proficiency check renews the rating at the interval set by the applicable RBAC.

Training programs under RBAC 121/135 require an approved syllabus, qualified instructors and check airmen, records retention, and a defined recurrent cycle.

Crew resource management and threat-and-error management training are required components, not optional add-ons, for air carrier flight crew.

Medical certification is a condition of licence validity; the class of medical certificate required depends on the privilege exercised, and expiry dates differ by class and age.

Records of training, checking, and qualification must be retained and produced on request; the operator bears the burden of proving current qualification.

Instructor and examiner authority derives from a specific designation; an unauthorized person conducting a check does not produce a valid qualification.

An SMS has four components: safety policy and objectives, safety risk management, safety assurance, and safety promotion; each component has defined elements.

Safety risk = severity × likelihood, assessed against a documented matrix; risk is then mitigated to acceptable or tolerable levels, with the rationale recorded.

Hazard identification feeds the safety risk management process; a hazard is a condition with potential for harm, while a risk is the assessed combination of severity and likelihood of that harm.

Safety assurance uses data: audits, surveys, flight data monitoring, and occurrence reports, with defined performance indicators and targets.

Just culture distinguishes inadvertent error from reckless or intentional conduct; the distinction determines protective versus disciplinary response.

Occurrence reporting: serious incidents and accidents are notified promptly to the investigating authority (CENIPA) and to ANAC; the operator also files the required occurrence report.

ICAO Annex 13 governs investigation; the investigating authority conducts the investigation, and the operator's internal investigation supports but does not replace it.

Protection of safety data: voluntarily supplied safety information is generally protected from disciplinary use, except in cases of gross negligence or wilful misconduct.

Dangerous goods are classified into nine classes; the applicable ICAO Technical Instructions and the operator's approved manual govern acceptance, packing, marking, labelling, and documentation.

The shipper is responsible for correct classification, packing, and declaration; the operator is responsible for acceptance checks and for ensuring the consignment matches the declaration.

Hidden dangerous goods: acceptance staff must question shipments whose contents are not obvious, because many prohibited items (lithium batteries, aerosols, fuels) are not declared as such.

Passenger and crew provisions set quantity limits for carry-on and checked items; spare lithium batteries must be in carry-on, and terminals are protected against short circuit.

The NOTOC (notification to the captain) informs the pilot in command of the location and nature of dangerous goods loaded; it must be delivered before departure.

Cargo security includes known consignor and regulated agent concepts, screening, and chain-of-custody controls, applied to prevent prohibited items reaching the aircraft.

An undeclared or misdeclared dangerous goods shipment must be reported; the operator records it and notifies the authority as required by the applicable regulation.

Training for dangerous goods acceptance is function-specific and time-limited; personnel without current training may not accept, handle, or load dangerous goods.

Facilitation covers the formalities at borders: documents, immigration, customs, and health checks; ICAO Annex 9 sets the standards that national practice implements.

The passenger manifest and advance passenger information are used for border control; accuracy of the manifest is an operator responsibility.

Denied boarding and compensation are governed by the applicable consumer and ANAC rules; the operator must document the reason and the assistance provided.

Passenger with reduced mobility: assistance must be provided without charge, and the request must be transmitted through the booking and handling chain.

Refusal of carriage must rest on a documented ground (safety, security, health, or document deficiency); arbitrary refusal exposes the carrier to enforcement and civil liability.

Disembarkation and embarkation procedures at international airports require coordination with immigration, customs, and health authorities; the operator does not waive these checks.

Lost or damaged baggage claims follow the applicable liability limits; the passenger must be informed of the claim process and the deadline for filing.

Document checks: the operator must verify travel documents before boarding, because carrying an inadmissible passenger creates return obligations and penalties.

ANAC enforcement begins with detection (inspection, audit, occurrence, or complaint), followed by assessment, notification, and an opportunity to respond.

Administrative sanctions include warning, fine, suspension, and revocation; the applicable sanction depends on the gravity and the recurrence of the infraction.

Due process requires notice of the alleged infraction, the legal basis, and a defined period to present a defence before the sanction is imposed.

Inspection findings are classified by risk; a finding that affects immediate safety can ground the aircraft or suspend the authorization pending correction.

The operator must submit a corrective action plan with a root-cause analysis; closure requires evidence of implementation, not merely a stated intent.

Appeal of a sanction goes through the administrative hierarchy defined by ANAC; the appeal does not automatically suspend the sanction unless so ordered.

Records of inspections, findings, and corrective actions are retained and are disclosable in later proceedings.

Repeat findings within a defined period escalate the sanction level; the enforcement file must show the prior finding to support escalation.

ANAC is Brazil's civil aviation authority; it issues RBAC regulations, which implement ICAO Annexes as binding national rules.

Lei 7.565/1986 (Código Brasileiro de Aeronáutica) sits above ANAC resolutions; a conflicting RBAC provision is invalid to that extent.

ICAO Annexes bind Brazil internationally but take domestic effect only through an RBAC or ANAC resolution.

RBAC 121 covers airline operations; RBAC 135 covers commuter and on-demand; RBAC 91 sets general operating rules for all aircraft.

Rulemaking cycle: regulatory agenda, Regulatory Impact Analysis, public consultation, draft resolution, publication in the Diário Oficial.

ANAC issues the Air Operator Certificate and operating specifications; authorizations are limited to the listed types and kinds of operation.

ANAC regulates and certifies; CENIPA investigates accidents; DECEA provides air traffic services under COMAER.

A resolution enters into force on publication unless it states a later compliance or transition date.

Two gates: type certification of the design (RBAC 21) and individual airworthiness certification (Certificate of Airworthiness).

A CA stays valid only while the aircraft conforms to type design and is maintained per the approved program.

Airworthiness Directives are mandatory; the stated method (inspection, terminating action, or both) defines the required response.

MSG-3 derives tasks from failure consequences (evident, hidden, safety, economic), not from wear alone.

Release to service requires an authorized certifying person and a signed maintenance record.

Continuing airworthiness tracking covers life-limited parts, AD status, service bulletins, mass and balance, and MEL deferrals.

The MEL is operator-specific and ANAC-approved; a defect not covered by the MEL grounds the aircraft.

Import/export requires ANAC acceptance of the foreign authority's certificate plus AD and maintenance verification.

Operational control covers flight initiation, continuation, diversion, and termination; the PIC has final in-flight authority.

Fuel plan: taxi, trip, contingency, alternate, final reserve, additional; final reserve is not usable for normal planning.

Takeoff and landing distances must reflect the most limiting runway condition, obstacle clearance, and factored distances.

Category I, II, and III minima require specific aircraft equipment, crew qualification, and runway approval.

Flight time, duty period, and rest are distinct quantities, logged separately under the applicable RBAC subpart.

An MEL/CDL deferral must be evaluated for the specific route; some deferrals are prohibited for extended overwater.

Weight and balance must reflect actual load; last-minute changes require recomputation before departure.

A PIC may deviate from rules in an emergency but must report the deviation afterward.

Licences are issued by ANAC and are type- or category-specific; exercising a privilege without the rating is a violation.

Recency is separate from the licence: recent experience must be met before acting as PIC.

A type rating requires approved training, a knowledge examination, and a practical test, renewed at the set interval.

RBAC 121/135 training programs need an approved syllabus, qualified instructors and check airmen, and records retention.

CRM and threat-and-error management training are required for air carrier flight crew.

Medical certification is a condition of licence validity; the required class depends on the privilege exercised.

Training and checking records must be produced on request; the operator bears the burden of proving current qualification.

Instructor and examiner authority derives from a specific designation; an unauthorized check is invalid.

SMS components: safety policy and objectives, safety risk management, safety assurance, safety promotion.

Safety risk = severity × likelihood, assessed on a documented matrix and mitigated to acceptable or tolerable levels.

A hazard is a condition with potential for harm; a risk is the assessed severity and likelihood of that harm.

Safety assurance draws on audits, surveys, flight data monitoring, and occurrence reports, with defined indicators and targets.

Just culture separates inadvertent error from reckless or intentional conduct, determining the response.

Serious incidents and accidents are notified promptly to CENIPA and ANAC; the operator also files the required occurrence report.

ICAO Annex 13 governs investigation; the operator's internal investigation supports but does not replace it.

Voluntarily supplied safety data is generally protected from disciplinary use, except for gross negligence or wilful misconduct.

Nine dangerous goods classes; the ICAO Technical Instructions and the operator's manual govern acceptance, packing, marking, labelling, and documentation.

The shipper is responsible for classification, packing, and declaration; the operator for acceptance checks and matching goods to declaration.

Hidden dangerous goods: acceptance staff must question shipments whose contents are not obvious (batteries, aerosols, fuels).

Spare lithium batteries must travel in carry-on, protected against short circuit; passenger limits apply to carry-on and checked items.

The NOTOC informs the PIC of the location and nature of dangerous goods loaded and must be delivered before departure.

Cargo security uses known consignor, regulated agent, screening, and chain-of-custody controls.

Undeclared or misdeclared dangerous goods must be reported, recorded, and notified to the authority as required.

Dangerous goods training is function-specific and time-limited; untrained personnel may not accept or load such cargo.

Facilitation covers border formalities: documents, immigration, customs, and health checks, implementing ICAO Annex 9 standards.

Passenger manifests and advance passenger information support border control; manifest accuracy is an operator responsibility.

Denied boarding and compensation follow applicable consumer and ANAC rules; the reason and assistance provided must be documented.

Passengers with reduced mobility must receive assistance without charge, requested through the booking and handling chain.

Refusal of carriage must rest on a documented ground (safety, security, health, documents); arbitrary refusal creates liability.

International embarkation and disembarkation require coordination with immigration, customs, and health authorities; checks are not waived.

Baggage claims follow the applicable liability limits; passengers must be told the claim process and filing deadline.

The operator must verify travel documents before boarding; carrying an inadmissible passenger creates return obligations and penalties.

Enforcement sequence: detection (inspection, audit, occurrence, complaint), assessment, notification, opportunity to respond.

Sanctions include warning, fine, suspension, and revocation; the choice depends on gravity and recurrence.

Due process requires notice of the alleged infraction, its legal basis, and a defined period to present a defence.

Findings are classified by risk; an immediate-safety finding can ground the aircraft or suspend the authorization.

Corrective action plans require root-cause analysis; closure requires evidence of implementation.

Appeals follow the administrative hierarchy defined by ANAC; an appeal does not automatically suspend the sanction.

Inspection, finding, and corrective action records are retained and disclosable in later proceedings.

Repeat findings within a defined period escalate the sanction; the file must show the prior finding.

ANAC issues RBAC regulations implementing ICAO Annexes as binding national rules.

The Código Brasileiro de Aeronáutica (Lei 7.565/1986) outranks ANAC resolutions.

ICAO Annexes take domestic effect only through an RBAC or ANAC resolution.

RBAC 121: airline operations; RBAC 135: commuter and on-demand; RBAC 91: general operating rules.

Rulemaking: agenda, Regulatory Impact Analysis, public consultation, draft, publication.

The AOC and operating specifications limit authorized types and kinds of operation.

CENIPA investigates accidents; DECEA provides air traffic services under COMAER.

An ANAC resolution enters into force on publication unless a later compliance date is stated.

Type certification of the design and individual airworthiness certification are separate gates.

A Certificate of Airworthiness requires continued conformity to type design and approved maintenance.

Airworthiness Directives are mandatory and specify the compliance method and interval.

MSG-3 derives maintenance tasks from failure consequences.

Release to service requires an authorized certifying person and a signed record.

Continuing airworthiness tracking covers life-limited parts, ADs, service bulletins, and MEL deferrals.

The ANAC-approved MEL defines dispatch conditions; uncovered defects ground the aircraft.

Import/export requires acceptance of the foreign authority's certificate plus AD verification.

Operational control spans flight initiation, continuation, diversion, and termination.

Fuel includes taxi, trip, contingency, alternate, final reserve, and additional fuel.

Performance planning uses the most limiting runway condition and factored distances.

Category I/II/III minima require matching equipment, crew qualification, and runway approval.

Flight time, duty, and rest are separate logged quantities.

MEL/CDL deferrals must be checked against the specific route and conditions.

Weight and balance reflect actual load; last-minute changes require recomputation.

Emergency deviations by the PIC must be reported afterward.

ANAC issues licences; privileges are limited to endorsed ratings.

Recency requirements are separate from licence validity.

Type ratings require approved training, a knowledge examination, and a practical test.

Training programs require an approved syllabus, qualified instructors, and records retention.

CRM and threat-and-error management training are mandatory for air carriers.

Medical certification class depends on the privilege exercised.

The operator must prove current qualification of crew on request.

Instructor and examiner authority requires a specific designation.

SMS components: policy and objectives, risk management, assurance, promotion.

Risk assessment uses severity × likelihood on a documented matrix.

Safety assurance uses audits, flight data monitoring, and occurrence reports.

Just culture separates error from reckless or intentional conduct.

Accidents and serious incidents are notified to CENIPA and ANAC.

ICAO Annex 13 governs the investigation; internal investigation is supplementary.

Voluntary safety data is generally protected from disciplinary use.

Safety performance indicators and targets must be defined and monitored.

Nine classes; ICAO Technical Instructions and the operator's manual govern handling.

Shipper classifies and declares; operator verifies acceptance.

Hidden dangerous goods require questioning of unclear shipments.

Spare lithium batteries travel in carry-on, protected against short circuit.

The NOTOC must reach the PIC before departure.

Cargo security uses known consignor, regulated agent, and screening controls.

Misdeclared dangerous goods must be reported and recorded.

Dangerous goods training is function-specific and time-limited.

Facilitation covers documents, immigration, customs, and health formalities under ICAO Annex 9.

Manifest and advance passenger information accuracy is an operator responsibility.

Denied boarding requires documented reasons and assistance.

Reduced-mobility assistance is provided without charge.

Refusal of carriage must rest on a documented safety, security, health, or document ground.

International formalities require coordination with immigration, customs, and health authorities.

Baggage liability limits and claim deadlines must be communicated to passengers.

Document verification before boarding prevents inadmissible-passenger penalties.

Enforcement: detection, assessment, notification, opportunity to respond.

Sanctions range from warning and fine to suspension and revocation.

Due process requires notice, legal basis, and a defence period.

Immediate-safety findings can ground aircraft or suspend authorization.

Corrective action plans require root-cause analysis and evidence of implementation.

Appeals follow ANAC's administrative hierarchy and do not automatically suspend sanctions.

Enforcement records are retained and disclosable.

Repeat findings within a defined period escalate the sanction level.