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Safety Management System (SMS)
Besides the changes in the management team (Compliance Monitoring Manager & Safety Manager), EASA Part-145 Approved Maintenance Organizations also need to implement the elements of a suitable SMS.
The mandated SMS system must contain the following elements:
- finding out what is wrong (hazard identification);
- proposing and implementing a fix or fixes (remedial action);
- making sure that the proposed fix or fixes work as intended (continuous monitoring); and
- constantly improving the management system to ensure effectiveness and efficiency of the delivery of services (continuous improvement of the SMS).
Procedures and instructions need to be developed, and a separate Safety Management Manual is recommended. Especially if you are a large and complex organisation.
Depending on the size of the organization, a suitable SMS software system that support the reporting needs and data collection and retention of the essential SMS elements is recommended.
This SMS software should be capable of providing reports and data related to the continuous monitoring and continuous improvements of the SMS.
And finally, provisions need to be made in the training program for the training of required staff in Safety Management and Compliance Monitoring functions. Safety Management training is combined with Human Factors training and the course syllabus is detailed in GM1 145.A.30(e). Safety Management needs to be promoted, and a solid SMS training program is one of the means of promoting Safety within your organisation.
SMS is a system that identify hazards and take action to reduce the applicable risks to and acceptable level.
- Hazards are actively identified,
- Hazards can be a Risk, so it includes Risk Management (process)
- It looks into, how can we lower the Risk (Mitigation actions)
- A change (corona, rules, mode of operations) could introduce new hazards and thus new risks. (Management of Change)
SMS is everyone’s responsibility, this means everyone needs to understand the importance of this system and their respective responsibility. Think of attitude.
SMS must be driven by Management.
What will be the upcomming changes to Human Factors training requirements for EASA Part-145 organisations?
According to NPA 2019-05 and with the introduction of SMS, Human Factors training will be included in Safety Training.
The course syllabus for Safety Training is proposed to become*:
- General/Introduction to safety management and human factors
1.1. Need to address safety management and human factors
1a. Safety risk management
1a.1. Hazard identification
1a.2. Safety risk assessment
1a.3. Risk mitigation and management
1a.4. Effectiveness of safety risk management
- Safety Culture/Organisational factors
2.1 Just culture
2.2 Reporting culture
2.3 Informed culture
2.4 Flexible culture/learning culture
- Human error
3.1. Error models and theories
3.2. Types of errors in maintenance tasks
3.4. Implications of errors
3.5. Avoiding and managing errors
3.6. Human reliability
- Human performance & limitations
4.4. Attention and perception
4.5. Situational awareness
4.7. Claustrophobia and physical access
4.11. Workload management
4.12. Fatigue and fatigue risk management
4.13. Alcohol, medication, drugs
4.14. Physical work
4.15. Repetitive tasks/complacency
5.1. Peer pressure
5.3. Time pressure and deadlines
5.5. Shift Work
5.6. Noise and fumes
5.8. Climate and temperature
5.9. Motion and vibration
5.10. Complex systems
5.11. Other hazards in the workplace
5.12. Lack of manpower
5.13. Distractions and interruptions
- Procedures, information, tools and practices
6.1. Visual Inspection
6.2. Work logging and recording
6.3. Procedure – practice/mismatch/norms
6.4. Technical documentation – access and quality
6.5. Critical maintenance tasks and error-capturing methods (independent inspection,
7.1. Shift/Task handover
7.2. Dissemination of information
7.3. Cultural differences
8.2. Management, supervision and leadership
- Professionalism and integrity
9.1. Keeping up to date; currency
9.2. Avoiding Error-provoking behaviour
- Organisation’s safety programme
10.1. Safety policy and objectives, just culture principles
10.2.Reporting errors and hazards, internal safety reporting scheme
10.3. Occurrence investigation process
10.4. Action to address problems
10.5. Feedback and safety promotion
* Changes are indicated in Italic
What will change for EASA Part-145 Approved Maintenance Organisations from EASA NPA 2019-05 (A) & (C) (Implementation of SMS)?
Introducing the new ‘MANAGEMENT SYSTEM’. 145.A.65 ‘Safety and quality policy, maintenance procedures and quality system’, will be changed into 145.A.65 ‘Maintenance System’. 145.A.65 ‘Maintenance System’ reproduces all elements of the management system requirements including the organisation requirements and related AMC. These changes are supported by a series of Guidance Material specific to the context of maintenance organisations, with particular focus on Human Factors and Safety Risk Management/Fatigue Risk Management.
The new management system provisions are introduced to ensure maximum flexibility by defining core requirements of the management system at Implementing Rule (IR) level, and including the detailed means to achieve these goals at AMC level. They also allow considering those elements that are already in place today in any Part-145 Approved Maintenance Organisation, in terms of quality system related provisions that deliver the ‘compliance monitoring function’ of the new management system requirements.
Most of the provisions related to ‘quality system’ in the current Part-145 deals with the monitoring of compliance and related reporting and corrective action processes. As there are multiple types of quality systems defined in different international or national standards, with different meanings and scopes, it is more appropriate to refer to compliance monitoring function when it comes to Part-145. This does not mean that organisations will be required to change designations of their quality system personnel. It is left up to each organisation to decide how to refer to this function. Conversely, at the level of the requirements, no reference to ‘quality system’ will remain.
No longer ‘Quality System’. The former term ‘quality system’ is not used any longer. It has been replaced by ‘management system, in order to define a consistent set of management system requirements that would be compatible with a wide range of management system standards. This new management system focusses primarily on the monitoring of compliance, a proper reporting to management, and the need to take effective corrective actions.
‘Quality Manager’ will be replaced by ‘Compliance Monitoring Manager’ and an additional manager function will be introduced in EASA Part 145: the ‘Safety Manager’. The Safety Manager is responsible for the development, administration, and maintenance of effective safety management processes as part of the management system in accordance with 145.A.65.
For non-complex organisations, the Compliance Monitoring Manager and Safety Manager can be one person, although this is not recommended for the larger, complex organisations.
‘Quality audit personnel’ will be replaced by ‘Compliance Monitoring and safety management personnel’. The organization’s compliance monitoring personnel performs the same work as it was described for the previous quality audit personnel and they may request the safety management personnel to perform a safety risk assessment.
All these changes and additions will mainly impact MOE chapter 1.1 up to 1.5 and chapter 3.
“MOE chapter 3 Management System Procedures” does no longer include “quality” in the title and the following altered and new paragraphs need to be developed and implemented in MOE chapter 3:
EASA wants to further improve the level of safety with respect to EASA Part-145 Approved Maintenance Organizations. The principles of safety management as indicated in the ICAO Annex 19 SARP’s will be fostered and the procedures for oversight and enforcement will be streamlined.
The safety risks introduced by the aviation industry must result in an Acceptable Level of Safety (or ALoS). Acceptable level means as long as safety risks and operational errors are kept under a reasonable degree of control, a system as open and dynamic as commercial civil aviation is considered to be safe. In other words, safety risks and operational errors that are controlled to a reasonable degree are acceptable in an inherently safe system.
The EASA system establishes at legislative level the safety objectives to be met by means of essential requirements. These requirements have been designed to mitigate any probable risk linked to civil aviation activities within the scope of the EASA system. These mitigating means will be further detailed in appropriate Part-145 Implementing Rules (IR), Acceptable Means of Compliance (AMC) and Guidance Material (GM).
So why do we need to implement SMS, besides complying with the EASA regulations?
Because, besides achieving Improved Safety, it will also result in Continuous Improvement of operational processes and Repetitive Common Cause Accidents will essentially be eliminated.
This can only be achieved when EASA Part-145 Approved Maintenance Organizations move from a reactive to a proactive and predictive approach towards safety risks.
Implementation of SMS also has financial benefits. Besides cost reduction and cost avoidance, it will also result in a reduction of the direct and indirect costs of accidents, incident investigation and operational disruptions.
And finally, implementing an effective SMS, will provide EASA Part-145 Approved Maintenance Organizations with a competitive benefit. That is as mentioned before because of the financial benefits, but also because a well matured SMS will result in establishing a marketable safety record.
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