Sofema Aviation Services (SAS) considers the key relationship between safety culture and the EASA Management System Assessment Tool (MSAT)

ICAO Annex 19 sets the global expectation that a positive safety culture is an essential enabler for an effective Safety Management System (SMS). EASA has embedded this into the regulatory framework through requirements for Management Systems across all domains (Air OPS, CAMO, Part-145, Part-21, Aerodromes, ATC, etc.).

For the CA, understanding safety culture means:

•  Recognising the behaviours, attitudes, and values that drive decision-making within an organisation.

•  Identifying whether the organisation’s safety culture promotes proactive hazard identification, open reporting, and effective risk management—or whether there are indicators of a compliance-only, reactive mindset.

•  Understanding human factors and organisational dynamics, since safety culture weaknesses often manifest subtly before they translate into measurable performance issues.

MSAT Oversight Responsibilities

The MSAT framework requires Competent Authorities to move beyond paperwork compliance into performance-based oversight.
When considering safety culture under MSAT:

Evaluation of Safety Culture Maturity

•  MSAT indicators such as Leadership Commitment, Accountability, Involvement of Staff, and Promotion of Safety directly link to Annex 19 principles.

•  CAs assess whether the organisation’s leadership actively demonstrates visible safety commitment and whether safety is integrated into daily operations.

•  Oversight teams must recognise that “documented” does not equal “implemented”—cultural maturity is observed in behavioural evidence, not only in manuals or policies.

Interview & Observation Techniques

•  MSAT encourages interviews across all levels of the organisation—from the Accountable Manager to front-line staff—to identify alignment (or misalignment) in safety priorities.

•  Observations of meetings, decision-making forums, and reporting processes can reveal the true cultural climate.

Linking Safety Culture to Risk Performance

•  Competent Authorities should correlate safety culture maturity with safety performance data (occurrence trends, internal audit findings, risk register updates).

•  Weak safety culture often correlates with under-reporting, late hazard identification, and ineffective mitigation.

What This Means for CA Oversight Approach

For CAs, embedding the concept of “EASA & ICAO Annex 19 Driven Safety Culture” into oversight means:

Moving from Compliance to Conformance

>> Verifying not only that organisations have the required processes, but that these processes are lived and valued.

Prioritising Behavioural Evidence

>> Understanding how safety decisions are made is as important as what the decision was.

Encouraging Open Dialogue

>> Promoting a relationship where organisations can discuss weaknesses without fear of punitive action, aligning with the Just Culture principles of Annex 19.

Integrating Safety Culture Findings into the MSAT Score

>> Ensuring cultural aspects influence risk-based oversight planning and future surveillance focus.

Implications for Training & CA Competence

•  Oversight staff must be trained in human factors, organisational behaviour, and interview techniques to reliably assess safety culture.

•  Competent Authorities may need to adjust their oversight planning to allocate more time for on-site observation and less for document review.

•  Understanding Annex 19 principles becomes essential not only for assessing SMS structure but for measuring its cultural enablers.

Next Steps

See the following 2 day course available as Classroom or Webinar - Using The EASA Management System Assessment Tool (EASA MSAT) – 2 Days or email team@sassofia