Sofema Aviation Services (SAS) considers the forthcoming changes to SMS & Organizational Performance Management System in EASA Part 145 environment.
Organizational Performance Management Systems – Introduction
Regulation 2021/1963 amends Continuing Airworthiness Regulation (EU) No 1321/2014 as regards safety management systems in maintenance organisations and correcting that Regulation.
Additional Clause 145.A.120 – Means of Compliance
Provides an opportunity for the organisation to use alternate means of compliance (AMOC) to comply with the requirements – An interesting note is that once the organisations formally submit a request for approval – it may in fact commence using said AMOC!
(a) An organisation may use any alternative means of compliance to establish compliance with this Regulation.
(b) If an organisation wishes to use an alternative means of compliance, it shall, prior to using it, provide the competent authority with a full description.
The description shall include any revisions to manuals or procedures that may be relevant, as well as an explanation indicating how compliance with this Regulation is achieved.
The organisation may use those alternative means of compliance subject to prior approval from the competent authority.
Additional Clause 145.A.140 – Access
Concerns the ability of the regulatory authority to be provided with access to any aspect of the organisations systems, processes, and data needed to demonstrate compliance.
For the purpose of determining compliance with the relevant requirements of Regulation (EU) 2018/1139 and its delegated and implementing acts, the organisation shall ensure that access to any facility, aircraft, document, records, data, procedures, or to any other material relevant to its activity subject to certification, whether it is subcontracted or not, is granted to any person authorised by one of the following authorities:
(a) the competent authority defined in point 145.1;
(b) the authority performing the oversight tasks in accordance with point 145.B.300(d).
Additional Clause 145.A.140 – Immediate reaction to a safety problem
The organisation shall implement:
(a) any safety measures mandated by the competent authority in accordance with point 145.B.135;
(b) any relevant mandatory safety information issued by the Agency.
Additional Reference to Competent Authority Requirements
145.B.135 Immediate reaction to a safety problem.
(a) Without prejudice to Regulation (EU) No 376/2014 and its delegated and implementing acts, the competent authority shall implement a system to appropriately collect, analyse and disseminate safety information.
(b) The Agency shall implement a system to appropriately analyse any relevant safety information received and, without undue delay, provide the relevant authority of the Member States and the Commission with any information, including recommendations or corrective actions to be taken, that is necessary for them to react in a timely manner to a safety problem involving products, parts, appliances, persons or organisations that are subject to Regulation (EU) 2018/1139 and its delegated and implementing acts.
Note 1 – EASA is responsible to collect analyse and disseminate safety information.
Note 2 – Once information is provided by EASA to the CA:
- The CA shall take measures to address the issues identified by informing any organisations which need to comply.
- The CA shall advise EASA on such steps taken.
The effectiveness of this process depends on EASA managing the received information and making the necessary recommendations.
Next Steps
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Sofema Aviation Services www.sassofia.com & Sofema Online www.sofemaonline.com provide Classroom, Webinar & Online Regulatory Training & Consulting Related to EASA Part 145. For additional details visit our websites or email team@sassofia.com
Tags:
Alternate means of Compliance (AMOC), aviation, aviation safety, Aviation SMS, Basic Regulation (EU) 2018/1139, Clause 145.A.120, Clause 145.A.140, EASA, EASA Part 145, Organisational Management System, Part 145, Regulation (EU) No 1321/2014, Regulation (EU) No 376/2014, Regulation 2021/1963, Safety Management Systems (SMS)
