OPINION NO 03/2011
OF THE EUROPEAN AVIATION SAFETY AGENCY
of 19 April 2011
Review presented by Sofema Aviation Services www.sassofia.com
The publication of the associated regulations is due by 8th April 2012
The following points are related to the implementation of Safety Management Systems
In order to assist Member States in fulfilling their obligations under the Chicago Convention and to continually improve the level of civil aviation safety in Europe, Part-AR Opinion 03/2011 19 Apr 2011 includes some essential elements for establishing a comprehensive management system at the EU level, encompassing EU and Member State responsibilities for safety management.
This framework will ensure compliance with the relevant ICAO standards on SMSs and State Safety Programmes (SSPs) for all EU Member States. In this area, the Agency supports a holistic approach towards management systems that incorporates the SMS as a fundamental element of the management system of an organisation or an authority.
In this respect, common authority requirements are directly relevant to the implementation of the European Aviation Safety Programme (EASP).
Editor note
This is a Unified European response to the State Safety Program (SSP)
In this area, more detailed requirements and associated AMC and GM encompassing the safety programme at the EU level and defining the interaction between the Member States and the Agency are currently under development.
This material will be based on the work being coordinated by the European Aviation Safety Advisory Committee (EASAC), in particular regarding the EASP.
With a view to transposing the relevant ICAO standards on SMS, Part-OR in its Subpart GEN proposes consolidated general requirements for management systems, designed to ensure applicability to all organisations holding an organisation certificate under the Basic Regulation.
The proposed requirements, while ensuring full compliance with the relevant ICAO standards on SMS, are scalable to the size of an organisation and the nature and complexity of its activities.
Editor note
EASA recognizes that SMS is not a one size fits all and discusses the merits of a scaleable system.
The Agency proposal promotes an integrated approach to management systems, encompassing compliance monitoring and safety management, rather than superimposing another system onto existing management systems.
The ICAO objective of introducing SMS in all aviation fields necessarily leads to the same basic principles of streamlined requirements for organisation approval and oversight and common management system requirements.
In order to assist Member States in fulfilling their obligations under the Chicago Convention and to continually improve the level of civil aviation safety in Europe, Part-AR
Opinion 03/2011 19 Apr 2011 includes some essential elements for establishing a comprehensive management system at the EU level, encompassing EU and Member State responsibilities for safety management.
This framework will ensure compliance with the relevant ICAO standards on SMSs and State Safety Programmes (SSPs) for all EU Member States. In this area, the Agency supports a holistic approach towards management systems that incorporates the SMS as a fundamental element of the management system of an organisation or an authority.
In this respect, common authority requirements are directly relevant to the implementation of the European Aviation Safety Programme (EASP). In this area, more detailed requirements and associated AMC and GM encompassing the safety programme at the EU level and defining the interaction between the Member States and the Agency are currently under development.
This material will be based on the work being coordinated by the European Aviation Safety Advisory Committee (EASAC), in particular regarding the EASP.
With a view to transposing the relevant ICAO standards on SMS, Part-OR in its Subpart GEN proposes consolidated general requirements for management systems, designed to ensure applicability to all organisations holding an organisation certificate under the Basic Regulation.
The proposed requirements, while ensuring full compliance with the relevant ICAO standards on SMS, are scalable to the size of an organisation and the nature and complexity of its activities.
The Agency proposal promotes an integrated approach to management systems, encompassing compliance monitoring and safety management, rather than superimposing another system onto existing management systems.
Editor note
EASA recognizes that an SMS system must be integrated within the organization and not bolted on, this is an essential pre-requisite to be effective.
The Agency believes that these should not be implemented through an additional management system requirement superimposed onto the existing rules, be they related to finance, quality or any other concern of an organisation manager
Imposing a safety management system separate from the others could be seen as a mere additional prescriptive requirement, with the risk that organisations would seek to satisfy their competent authority by showing that they have added in their organisation all the required prescriptive elements.*
* Editor note
There is a danger here of organisations who over focus on compliance with IOSA requirements falling into this trap (SIC)
This would not support the implementation of performance-based rules, as fostered by ICAO to facilitate the implementation of SMS principles.
Instead, the Agency proposes to list the elements that the organisations must address. Thus, the proposed requirements are based on the idea that safety, as well as compliance with rules, should be a concern for all personnel and for all activities of the organisation. Therefore, the requirements are presented in such a way that allows the organisation to apply them in the way it sees fit, taking into account its own business model.
In particular, the requirements would allow the implementation of an integrated management system where safety is a parameter to be taken into account with each decision, rather than a juxtaposition of management systems. Integrated management enables managers to recognise and take into account all significant influences on their organisation, such as the strategic direction of their business, relevant legislation and standards, internal policies and culture, risks and hazards, resource requirements and the needs of those who may be affected by any aspect of the organisation’s operation.
In terms of quality systems the Agency proposes to retain what the regulator is really interested in when requiring the organisations to implement a quality system: compliance with the rules. Indeed, a quality system may be used to satisfy different sets of requirements. The Agency believes that it is necessary to simply require compliance monitoring as part of the management system requirements. The proposed requirements thus offer the ability to implement the ICAO SMS standards, without obliging the organisation to alter its business model.
Although different in wording, not only are the proposed requirements compliant with ICAO, but the Agency proposal may also be a model that ICAO will follow.
Indeed, the 37th ICAO Assembly, held in September/October 2010, confirmed the creation of a new Annex dealing with safety management.
It will contain the standards related to the safety programme required from the authorities and may contain the general SMS standards applicable to all organisations, thus following the total system approach proposed by EASA in its NPA on Authority and Organisation Requirements.
The management system requirements, as proposed, fit various organisations, whatever their size, nature or complexity of the activities and whatever business model they wish to apply, thus ensuring their proportionate application.
The Agency also proposes that, in case an organisation would contract out part of its activities subject to the present proposed requirements, it should retain the responsibilities of compliance with the applicable rules.
* Editor note
This would for example refer to the use of Subcontractors to support the operation of the airline, Ground Handling, Cargo Loading, Catering etc etc.
This is necessary to ensure that organisations remain fully accountable for those activities that are subject to certification.
The management system requirements are proposed to apply to all organisations covered by these proposed Organisation Requirements. When drafting the management system requirements, the Agency checked what was already applicable to initial and continuing airworthiness organisations in order to check compatibility with those, keeping the wording of those already applicable rules when possible. However, the Agency intends to propose rules implementing the ICAO SMS standards for other types of organisations in the future.
As far as possible, the Agency will strive to keep the requirements as similar as possible to those proposed in these Organisation Requirements. This will facilitate a streamlined implementation of the ICAO standards, in particular for those organisations whose activities cover several aeronautical sectors.
When necessary, the management system requirements are complemented by the corresponding requirements for specific types of organisations in order not to change the requirements currently followed by these specific types of organisation (e.g. concerning an already agreed duration for record keeping).
The Agency is collaborating with major authorities and ICAO on how to measure safety performance, it will propose AMC or GM to verify the effectiveness of actions taken to mitigate the risks, in accordance with the corresponding requirement.
The Agency also found it interesting that some stakeholders requested to move further in the direction of performance-based rules. However, the Agency thinks that it would not be wise to propose full performance-based rules at this stage and that continuous improvement of the rules, consistent with the progress made at the level of organisations, will facilitate the route towards performance-based rules.
Sofema Aviation services are pleased to provide industry wide training in compliance with Safety Management Systems
– Safety Management Systems For Safety and Quality Managers – 2 Days
– Safety Management Systems for Accountable Managers and Post Holders – 1 Day
– Safety Management Systems Implementation – Workshop – 2 Days
– Safety Management Systems for Maintenance Staff – 1 Day
– Safety Management Systems for Operations Staff – 1 Day
– SMS Risk Assessment Techniques and Strategies – 1 Day
For additional details please visit www.sassofia.com or email office@sassofia.com
