Discussion about EASA Management System Roles & Responsibilities document by Steve Bentley CEO of Sofema Aviation Services (SAS) www.sassofia.com
Introduction
Who is in Charge the Safety Manager (SM) or the Compliance Manager (CM) / Quality Manager (QM)?
This was a genuine question asked of me many years ago by a Senior Post Holder in an airline in an attempt to come to terms with Roles & Responsibilities within his organisation.
In fact, he was the SM and was not prepared to be challenged by the QM (Clearly an unusual state of affairs), and just in case you are not sure, unless the organisation specifically decides differently the answer is neither, as both SM & QM report to the Accountable Manager (AM).
Roles & Responsibilities
I further explained the entire concept of the EASA-mandated management system headed by the AM & supported by the Nominated Post Holder (NPH) (Subject Matter Experts):
- Note: the Core Management System does not include the SM & QM – they are in fact best considered as service providers.
о The QM/CM provides an independent assessment (primarily by audit) of the compliance with External (regulatory) and Internal (process & procedures) obligations – any deviation will be identified as a non-conformity and delivered to the business area owner as a “finding” requiring corrective action to return the system to compliance. Closing the finding should be considered a mandatory obligation (means the business area owner can NOT ignore a corrective action).
- The SM heads up the process to identify an unacceptable level of Risk concerning any of the Hazards which the business faces. The SM is responsible for the analysis process (subjective) and to make a “recommendation” to the business area owner for mitigation. However, the business area owner is ultimately responsible and is at liberty to reject the recommendation. (Nevertheless, the process steps and acceptance/objection are fully documented) Disagreement or clarification are arbitered by the AM.
Reality Check
To be successful ownership of an issue problem must reside with a person who has the capacity to effect change. The success of the EASA Management System is that it is built on this understanding.
To make the SM responsible to deliver safety within an organisation without the ability to control the budget, process & procedures is doomed to fail (The SM clearly is not the “boss” of the NPH).
OK, what you say is all very nice but where does EASA actually say this?
I consider this question – which incidentally is asked quite regularly – often by people who should not be asking (due to their current roles & responsibilities).
Please consider the following reference from regulation 965/2012 as supporting evidence with comments in italics:
AMC1 ORO.GEN.200(a)(1) Management system – ED Decision 2019/019/R
COMPLEX OPERATORS — ORGANISATION AND ACCOUNTABILITIES
The management system of an operator should encompass safety by including a safety manager and a safety review board in the organisational structure.
(a) Safety manager:
(1) The safety manager should act as the focal point and be responsible for the development, administration, and maintenance of an effective safety management system. (No mention of personal responsibility for ownership or mitigation delivery)
(2) The functions of the safety manager should be to:
(i) facilitate hazard identification, risk analysis, and management;
(ii) monitor the implementation of actions taken to mitigate risks, as listed in the safety action plan;
(iii) provide periodic reports on safety performance;
(iv) ensure maintenance of safety management documentation;
(v) ensure that there is safety management training available and that it meets acceptable standards;
(vi) provide advice on safety matters; and
(vii) ensure initiation and follow-up of internal occurrence/accident investigations.
The above responsibilities do not at any point make the SM personally responsible for delivery
(b) Safety review board:
(1) The safety review board should be a high-level committee that considers matters of strategic safety in support of the accountable manager’s safety accountability.
(2) The board should be chaired by the accountable manager and be composed of heads of functional areas.
(3) The safety review board should monitor:
(i) safety performance against the safety policy and objectives;
(ii) that any safety action is taken in a timely manner; and
(iii) the effectiveness of the operator’s safety management processes.
(c) The safety review board should ensure that appropriate resources are allocated to achieve the established safety performance.
(d) The safety manager or any other relevant person may attend, as appropriate, safety review board meetings. He/she may communicate to the accountable manager all information, as necessary, to allow decision-making based on safety data.
Important point (d) above identifies that it is not necessary for the SM to attend or be part of the SRB meetings – potentially distancing the SM and allowing the management team to assess how it is managing its Safety responsibilities.
Conclusion
The Management System Concept introduced by EASA in 2012 has been progressively introduced throughout all Domains (Airports – CAMO – Maintenance, etc.) and fundamentally places responsibility on those persons who can effect the required changes which the organisation needs to adopt to ensure safety & compliance.
Next Steps
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aviation, Compliance Manager, EASA, EASA Management System, EASA Regulation EC 965/2012, EU 965/2012, Nominated Post Holder, Post Holder, Quality Manager, Safety Manager, SAS blogs
