Sofema Aviation Services (SAS) considers key aspects of HF- CRM exposures
Introduction
Under EASA, the Air Operator (AOC holder) is governed by Part-ORO (Organisation Requirements for Air Operations), which must seamlessly interface with Part-CAMO and Part-145.The synergy between these regulations is where the most significant safety improvements as well as the most significant exposures are found.
The Integrated Management System (ORO.GEN.200)
Regulation 965/2012, specifically ORO.GEN.200, mandates a management system for operators that mirrors the requirements found in Part-CAMO and Part-145. This creates a unified regulatory language for safety.
The Challenge of the “Contractual Gap”
A major challenge is that while the Operator is responsible for the overall safety of the flight, the physical maintenance is often outsourced to a Part-145 AMO. If the Operator’s SMS (965/2012) and the AMO’s SMS (Part-145) are not synchronized, safety data can fall into the “contractual gap.”
- Cultural Exposure: The Operator might have a high-functioning Just Culture, but if their contracted Part-145 AMO operates under a “Blame Culture,” the Operator will never receive the full picture of the technical risks affecting their fleet.
- Best Practice: The Operator must perform Safety-Focused Audits of the CAMO and AMO that go beyond technical compliance.They should audit the safety culture of their partners to ensure that reporting remains transparent across organizational boundaries.
Delivering Cultural Change across the Triad
Delivering safety improvements through cultural change requires a shift from “Customer vs. Contractor” to a “Partnership for Safety.”
Aligning the Accountable Managers
Under 965/2012 and Part-CAMO, the Accountable Manager (AM) is the linchpin. If the AM for the Operator and the AM for the CAMO are different individuals, they must have a shared safety policy.
- Mitigation: Establish a Joint Safety Review Board (SRB). This brings the Flight Operations, Ground Operations, CAMO, and AMO leadership to the same table.This prevents “siloed” decision-making
- Mitigating HF/CRM and MRM Exposures- Human Factors (HF) in maintenance and Crew Resource Management (CRM) in operations are two sides of the same coin.Regulation 965/2012 places heavy emphasis on CRM, Whereas Regulation 1321/2014 “as amended” focuses on the importance of HF – SMS within both the 145 and CAMO area’s
The Pilot-Engineer Interface (The Technical Log)
One of the highest-risk HF exposures occurs at the point of aircraft handover between the Flight Crew (965/2012) and the Maintenance Crew (Part-145).
- Exposure: A pilot writes a vague defect in the Tech Log (e.g., “Engine feels rough”). The engineer, under time pressure, cannot replicate it and signs it off as “Checked OK.” This is a failure of Communication.
- Mitigation – How do you believe this exposure can be reduced ? -Discuss
Pressure and “The Mission”
Part-ORO.FC (Flight Crew) requirements often focus on mission completion. This can exert “indirect pressure” on Part-CAMO and Part-145 staff.
- Exposure: The “Commercial Push.” A flight is delayed, and the Ops center (965/2012) puts pressure on the CAMO to agree to defer a defect, or on the 145 to “speed up” a repair.
- Mitigation: Establish Pre-defined Safety Triggers. The SMS should define exactly when a commercial conversation must end and a safety decision must begin. By “proceduralizing” the refusal of pressure, you remove the individual burden from the technician or planner, mitigating the HF exposure of stress and intimidation.
Systemic Design: The “CAME-MOE-OM” Link
To remove exposures introduced by HF/CRM considerations, the organization’s manuals – the Operations Manual (OM), CAME, and MOE – should be harmonized where possible.
- Feedback Loops: When a Part-145 engineer identifies a design flaw that makes a task difficult (HF exposure), the CAMO must be able to report this through the Operator’s Occurrence Reporting System (ORO.GEN.160). This might lead to the need to contact the Type Certificate Holder (Boeing, Airbus, etc.) for a systemic fix.
Data-Driven Mitigations: The Operational Trigger (Regulation 965/2012):
Modern Flight Data Monitoring (FDM) and Aircraft Health Monitoring (AHM) systems continuously stream engine parameters
The CAMO Analysis:
The Part-CAMO reliability department analyzes this trend data against the fleet average. Instead of waiting for a pilot to report a “rough engine” (reactive), the CAMO uses the data to adjust the maintenance program. They might decide to move a scheduled Engine Compressor Wash forward by 200 flight hours to restore EGT margin and fuel efficiency.
The Part-145 Mitigation:
Based on the CAMO’s data-driven instruction, the Part-145 AMO performs a targeted Borescope Inspection of the High-Pressure Turbine (HPT). Because the data pointed to a specific trend, the technician knows exactly what to look for, such as premature blade coating degradation.
The Best Practice: The “Single Safety Portal”
For organizations that hold both an AOC and a Part-CAMO/145, the most effective tool is a Single Safety Reporting Portal.
- By integrating the operational standards of Regulation 965/2012 with the technical rigor of Part-CAMO and Part-145, an organization creates a “Resilient System.”
- This system doesn’t just rely on people not making mistakes; it relies on a culture that expects mistakes and has the systemic strength to catch them.
Delivering Safety Improvements through Cultural Change – Consider Mitigations that may remove the Exposures introduced by HF / CRM Considerations.
The implementation of a Safety Management System (SMS) within Part-CAMO and Part-145 organizations represents a move toward a proactive, data-driven safety environment.
Delivering Safety Improvements through Cultural Change
A safety culture is the collective value system of an organization regarding safety. In the world of CAMO (Continuing Airworthiness Management) and AMO (Approved Maintenance), cultural change is the only way to ensure that safety reports actually reach the Safety Manager.
The Foundation: Just Culture
The primary challenge is the “Blame Culture” legacy.
- The Best Practice: Establish a formal Just Culture Policy signed by the Accountable Manager. It must clearly draw the line between “honest human error” and “gross negligence.” (When staff feel safe to report, the organization gains the data necessary to fix systemic flaws before they cause an accident.)
Leadership and “Tone from the Top”
- Best Practice: Leadership must demonstrate safety commitment through visibility. Safety should be the first item on the agenda of every management meeting, not an afterthought in a quarterly report.
Communication and Handover Exposures
Miscommunication is a leading cause of maintenance errors, particularly during shift changes or when moving tasks from CAMO planning to the shop floor.
- Implement Standardized Handover Protocols. This includes mandatory face-to-face briefings for critical tasks and “Closed-Loop Communication” (read-back) to ensure the receiving party fully understands the status of the aircraft.
Fatigue and Stress – Maintenance often happens at night (Part-145), while airworthiness reviews involve high-stakes data analysis (Part-CAMO). Both are susceptible to fatigue.
Complacency and the “Norm” – Experienced staff are often the most at risk for complacency—the “I’ve done this a thousand times” mindset.
- Exposure: Deviating from the approved data (Maintenance Manual) because a “short cut” is perceived as more efficient.
- Mitigation: On critical tasks, the person performing the work should be independent of the person performing the duplicate inspection.
– Rotating teams can also prevent “normalized deviance” where a group collectively starts ignoring a rule.
Best Practices for Integrated Safety
To bridge the gap between the office (CAMO) and the hangar (Part-145), organizations should adopt these systemic improvements:
- Cross-Functional Safety Action Groups (SAGs): Ensure that CAMO planners sit in on Part-145 safety meetings and vice versa. This breaks down silos and helps planners understand the physical constraints of the hangar, while technicians learn the importance of meticulous record-keeping.
- Error Management Systems (EMS): Instead of asking “Who did this?”, the SMS should ask “What in our process allowed this to happen?” For example, if a part is installed incorrectly, the mitigation might be better lighting, clearer labeling, or redesigned toolkits rather than a reprimand for the technician.
- Safety Promotion: Use digital dashboards in the hangar and office to show staff the “Safety ROI.” If a technician reports a tool deficiency and the company buys a new tool, publicizing that win reinforces the culture of reporting.
Next Steps
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Tags:
Human Factors, Part 145, EASA regulations, Just Culture, Part CAMO, ORO.GEN.200, Part-ORO, Risk Mitigation, Sofema Aviation Services (SAS), organizational culture, Sofema Aviation (SA), Aviation Safety Management (SMS), CRM, Pilot-Engineer Interface, Integrated Management Systems, Data-Driven Maintenance (FDM / AHM)
