GCAA says now –EASA Says Later! ICAO says 8 years ago (2009)

Sofema Aviation Services (www.sassofia.com) considers the current status of SMS within an EASA-compliant Part 145 organisation.

What is SMS?

Sure we all know what is a Safety Management System (SMS)

But consider the two options:-

a) Safety Management System focused on ensuring “Mandatory Compliance” with all Safety Objectives

b) Management System focused on developing in an effective way optimized for efficiency and delivering all Mandatory Safety Objectives

What’s the Difference?

Well, both will tick the regulatory box – the cost is quite similar but b) generates efficiency leading to cost savings which typically exceed the cost of the implementation and management of the SMS.

So why would any organisation choose option “a”?

This an excellent question and the only possible answer is the executive team does not fully understand the option of choosing “b)”

Background

ICAO Introduced the requirements related to SMS (Standard & Recommended Practices – SARPs) back in 2009. This placed a burden of responsibility on all nation-states.

Related to GCAA 145

The Gulf Civil Aviation Authority which essentially mirrors EASA in the delivery of regulations compliant with ICAO was essentially obliged to move in a different direction due to the absence of EASA source documents and has issued GCAA CAR X to identify Proactive SMS as a requirement within the CAR 145 Compliant Organisation.

Related to EASA Part 145

EASA as of writing (Dec 2017) has issued an NPA to cover requirements within Part 21 - NPA 2017-20 - Embodiment of level of involvement acceptable means of compliance and guidance material to Part-21 - RMT.0262 (MDM.060)

Task RMT.0251 (MDM.055) addresses continuing airworthiness - Commission Regulation (EC) No. 1321/2014 - "Part-M", "Part-145", “Part-66” and "Part-147", meaning safety management in the area of maintenance organisations, continuing airworthiness management organisations and maintenance training organisations.

This task resulted in the publication of two distinct NPAs:

NPA 2013-01, published in January 2013 to cover Part-M and Part-145 & NPA 2013-19, published in October 2013 to cover Part-66 (very limited changes) and Part-147.

NPAs 2013-01 and 2013-19 proposed changes to Sections A and B of the continuing airworthiness Regulation to implement the ICAO SMS framework and to support the implementation of SSP/EASP.

In 2015 the Agency decided to adopt a two-phased approach for RMT.0251 (MDM.055) and to include in this rulemaking task the SMS part of rulemaking task MDM.060:

Phase I: Introduction of SMS requirements in Part-M - This led to the publication of Opinion 06/2016 ‘Part-CAMO’. Part-CAMO is aligned with the authority- and organisation requirements already introduced for ATM/ANS, aerodromes, aircrew, and air operations.
Phase II: Changes to Part-66 (SMS elements to be added to the training syllabi)

Introduction of SMS requirements in Part-145 organisations

Phase II will be the subject of new Terms of Reference and a new NPA, to be published in 2017 (Not yet Published December 2017)

Decision Time for EASA 145 Organisations

Currently, EASA Compliant 145 Organisations have a reactive SMS system typically integrated within the Quality Assurance System.

Developing a more proactive SMS in preparation for future EASA Compliance will not only send out the correct message to customers, but it will also help the organisation to better understand its exposures across several business areas.

What does a basic SMS system typically look like within a “145” Organisation.

This regulation establishes the Safety Management System (SMS) requirements for organisations approved/certified following CAR 145

The  (Safety Review Board) SRB:

(a) monitors the effectiveness of the SMS;

(b) monitors that any necessary corrective action is taken promptly;

(c) monitors safety performance against the organisation‘s safety policy and objectives;

(d) monitors the effectiveness of the organisation‘s safety management processes which support the declared corporate priority of safety management as another core business process;

(e) monitors the effectiveness of the safety supervision of subcontracted operations;

(f) ensures that appropriate resources are allocated to achieve safety performance beyond that required by regulatory compliance.

d) The Safety Action Group may assist the Post Holder SMS in:

1) oversee operational safety performance within the functional areas of the organisation and ensures that appropriate safety risk management activities are carried out with staff involvement as necessary to build up safety awareness;

2) coordinate the resolution of mitigation strategies for the identified consequences of hazards and ensure that satisfactory arrangements exist for safety data capture and employee feedback;

3) assess the safety impact related to the introduction of operational changes or new technologies;

4) coordinate the implementation of corrective action plans and ensure that corrective action is taken promptly;

5) oversee safety promotion activities as necessary to increase awareness of safety issues among relevant employees, and ensure that employees are provided appropriate opportunities to participate in safety management activities.

What are the Practical SMS Implementation Challenges

Anything which creates a barrier to the most effective system we can implement within our organisation. So consider the following areas and identify the physical constraints

a) Documentation Issues – Have we completed all Documentation required to support the SMS system

b) Communication & Marketing Issues – Are we able to demonstrate “buy-in” and commitment from the tip down

c) Culture and Behaviour Issues – Have we carried out a Cultural Survey? – Do we have organisational issues which we should address?

d) Resource Issues – Have we allocated enough resources to comply with our intentions

e) Training Issues – Do we have the Training Material Ready (Have we constructed the Training Program – content)

SMS Training Requirements

The service provider shall develop and maintain a safety training programme that ensures that personnel is trained and competent to perform the SMS duties.

The scope of the safety training shall be appropriate to each individual’s involvement in the SMS.

Implementation Strategy?

The safety manager should provide current information and training facilitation relevant to specific safety issues encountered by organizational units.

The provision of training to appropriate staff, regardless of their level in the organization, is an indication of management‘s commitment to an effective SMS.

Safety training and education curricula should consist of the following:

a) Organizational safety policies, goals & objectives ;

b) Organizational safety roles and responsibilities related to safety;

c) Basic safety risk management principles;

d) Safety reporting systems;

e) Safety management support (including evaluation and audit programmes);

f) Lines of communication for dissemination of safety information;

g) A validation process that measures the effectiveness of training;

h) Documented initial indoctrination and recurrent training requirements;

i) Training requirements consistent with the needs and complexity of the organization should be documented for each area of activity. (A training file should be developed for each employee, including management.)  Safety training within an organization must ensure that personnel are competent to perform their safety-related duties.

ii) Training procedures should specify initial and recurrent safety training standards for operational personnel, managers and supervisors, senior managers, and the Accountable Executive.

iii) The amount of safety training should be appropriate to the individual‘s responsibility and involvement in the SMS.

iv) The SMS training documentation should also specify responsibilities for the development of training content and scheduling as well as training records management.

v) The training should include the organization‘s safety policy, safety roles and responsibilities, SMS principles related to safety risk management and safety assurance, as well as the use and benefits of the organization‘s safety reporting system(s).

vi) Safety training for senior managers should include content related to compliance with national and organizational safety requirements, allocation of resources, and active promotion of the SMS including effective inter-departmental safety communication.

vii) In addition, safety training for senior managers should include material on establishing safety performance targets and alert levels.

viii) Finally, the safety training programme may include a session designed specifically for the Accountable Executive.

 This training session should be at a high level providing the Accountable Executive with an understanding of the SMS and its relationship to the organization‘s overall business strategy.

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