Sofema Online (SOL) www.sofemaonline.com considers key elements of the EASA Management System Assessment Tool.

‘The management system shall correspond to the size of the organisation and the nature and complexity of its activities, taking into account the hazards and associated risks inherent in these activities’.

• • Management System (MS)
• • Safety Management System (SMS)

Whilst the rules address the main, systemic risks, they cannot address all the risks. (consider  the variety of different organisations, their services, and products as well as the wide range of operating environments.)

Note - “Being compliant” does not mean “being safe”. The MS of any type of organisation should notably remain resilient, agile, and vigilant in a continuously moving context (such as new business models or technologies or change of methods, emerging risks, competition, or crisis). Finally, good safety performance and resilience with the absence of negative safety events in the past do not guarantee safe operations in the future.

Engagement Objectives

• • Organisations should seek to move beyond mere compliance with the requirements.
• • The Management System (MS) should thus provide ways to look for safety issues that are not appropriately captured by the rules, to maintain or improve safety.
• • All organisations, regardless of the size of their organisations, are exposed to risks, some of them being potentially significant, even for a limited business.
• • This means that:

 - All elements of an MS should thus apply;

 - The effectiveness of the MS will depend on how appropriately its elements are designed, implemented, and operated.

Implementation Cost Considerations

• • An operating MS does not need to be complicated and expensive to be effective.
• • The MS could be made scalable if it keeps on delivering as expected and provides an effective way to manage all key operational risks.
• • A system description of the MS should help to identify the different attributes and interfaces to be factored in the MS design and implementation.

Note - Scalability is not about applying specific elements of an MS or SMS light: it is about adapting an MS with all its elements to the specific operational context of the organisation.

The following aspects are vital for any organisation to understand the context in which its Management System operates, what the purpose of the Management System should be and the key risks that it must manage effectively:

For the size of the organisation:

• • Number of employees.
• • Number of sites, including permanent and temporary locations;
• • Internal and external interfaces;
• • Organisational structure.
• • Type and variety of operations (e.g. leasing agreements, an organisation with more than one approval, ACMI)
• • Aircraft types and number of aircraft
• • Number of passengers carried per flight and annually
• • Volume of traffic
• • Number of aircraft movements or runways (ADR and ANSP)

For the complexity of the risks to manage:

• • Risks associated with the operating environment (e.g. mountainous, freezing conditions, offshore, remote operations without close support, Polar / Arctic, active volcanos areas, operations near conflict zones)
• • Specialized operations requiring a specific approval (e.g. SPOs); safety consequence(s)
• • In case of failure of the products or services; potential downtime, etc.
• • Risks associated with the business model (e.g. extent of the contracted activities internally and externally, services based on a short turnaround or operations with commercial pressures
• • Nature of the approval’s privileges, single CAMO for several AOCs
• • Zero-hour contracts for pilot’s employment
• • Changes requiring approval before operations; - Exemptions and AltMoC granted by the competent Authority.

For the external and internal dimensions:

• • Societal and public expectations;
• • Economical, commercial, and
• • Financial environment
• • Competition; Stability in the business versus needs for changes.
• • Experience in the business
• • Adequacy and robustness of the existing procedures, etc.
• • Safety culture (open reporting culture, prevention culture, just culture
• • State’s overall performance.

Program Delivery

This multi-dimensional complexity should be consequently weighted. Several topics are proposed here, for consideration:

• • The safety policy may be a brief high-level statement of management’s commitment, supported by safety objectives that address significant risks.
• • It would be more detailed in a challenging environment.
• • Regular updates of the safety objectives would be necessary where the business/operations are continually evolving (e.g. changing operational activities, numerous deficiencies, crises etc.)
• • The communication of these safety objectives should be commensurate with the resources of the organisation
• • The reporting policy, just culture policy and safety objectives could be combined with the safety policy for small organisations;

Just Culture

• • For the implementation of a “just-culture” principles, any disciplinary action (e.g. illegal activity, negligence, wilful misconduct) would be submitted to an independent committee representative of the staff in a large organisation (e.g. Staff committee, Unions could be invited) to avoid any excessive decision detrimental to safety reporting culture.
• • For smaller organisations, staff representatives should have enough power to counterbalance any unilateral decision from the senior management
• • The significance of the areas of greater risks (severity, likelihood, robustness of the mitigation measures) will greatly impact the robustness of the processes and the monitoring of the safety barriers;

Lower Risk Organisations

• • For organisations with a lower risk level, the risk assessment model that is used may be very simple in cases in which the identified hazards are easy to mitigate;
• • In addition, the organisation will strive to consistently classify risks.
• • Expert judgement might be sufficient to measure the efficiency of the safety barriers,

- Especially when the volume of data or safety information does not allow precisely support for the evaluation of the likelihood and the severity of the consequences of the hazards;

Next Steps

Please see Sofema Aviation Services and Sofema Online or email team@sassofia.com for questions, comments or suggestions.