What does EASA expect in relation to the Quality System (Compliance) Oversight of the Safety Management System (SMS)?
Article by Steven Bentley MD of Sofema Aviation Services www.sassofia.com
The first comment to make is where Commission Regulation 965/2012 leads the others will follow! The “others” in this case being EASA Part 145, EASA Part M, EASA Part 21 etc.
Does EASA expect oversight of the SMS system?
The answer is – Of course! The SMS is no different in this respect to any other business area and just as in other business areas, the QMS is looking at compliance with both the regulatory requirements “regulations” and internal process and procedures.
So what does this mean in practice?
a) That the regulatory requirements related to SMS are visible within the organisations system;
b) That the SMS documentation is controlled effective and delivered to the people who need it;
c) That the SMS training is delivered to an organisational standard, which is documented and recorded;
d) That the competence of people within the SMS system is managed to an organisational standard;
e) That the risk assessment process is managed and delivered using competent persons in accordance with an organisational standard;
f) That the flow of “data” means reporting into the SMS system is adequate and can be demonstrated to comply with the organisational objectives.
Remember every compliance audit is delivered against a standard and in this case the majority of the standard comes from ensuring that the “documented” SMS is being delivered as “advertised”.
What does EASA Actually Say?
Compliance & safety management – Compliance monitoring shall also look into the requirements on identification of aviation safety hazards and management of associated risks.
Here EASA is re-iterating what is said above (that there is in fact an obligation)
EASA goes on to say:
Are policies and procedures in place and adhered to?
Are hazard identified and risks assessed ?
Drawing the line!
Here we see that EASA is identifying that whilst the oversight and compliance of procedures and processes form part of the Quality Audit “Compliance” Program The actually measure of the effectiveness of the delivery of the SMS is contained within the SMS processes directly.
EASA goes on to say:
The verification of the effectiveness of the hazard identification process and mitigation actions is within the remit of the safety management function (safety manager – SRB – SAG).
How effectively have risks been mitigated ?
Has overall safety performance increased ?
It is further noted by EASA and related to independence of the audit process?
If the same person acts as SM and CM, he/she cannot audit SM processes.
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