Sofema Aviation Services (SAS) www.sassofia.com reviews the forthcoming Management System Requirements which will apply to EASA Part 145 Organisations.
Introduction
Regulation 2021/1963 amends Continuing Airworthiness Regulation (EU) No 1321/2014 as regards safety management systems in maintenance organisations and correcting that Regulation.
By way of derogation from points (1) and (2) of point 145.B.350(d) of Annex II (Part-145), a maintenance organisation that holds a valid approval certificate issued in accordance with Annex II (Part-145) may correct, until 2 December 2024, any findings of non-compliance related to the Annex II requirements introduced by Commission Regulation (EU) 2021/1963.
Where after 2 December 2024 the organisation has not closed such findings, the approval certificate shall be revoked, limited, or suspended in whole or in part.
Addition of Clause 145.A.200 – Management System
(a) The organisation shall establish, implement and maintain a management system that includes:
- clearly defined accountability and lines of responsibility throughout the organisation, including direct safety accountability of the accountable manager;
- a description of the overall philosophies and principles of the organisation with regard to safety (“the safety policy”), and the related safety objectives;
- 145.A.200(a)(3); the identification of aviation safety hazards entailed by the activities of the organisation, their evaluation, and the management of the associated risks, including taking actions to mitigate the risks and verify their effectiveness;
- maintaining personnel trained and competent to perform their tasks;
- documentation of all management system key processes, including a process for making personnel aware of their responsibilities and the procedure for amending that documentation;
- a function to monitor the compliance of the organisation with the relevant requirements. Compliance monitoring shall include a feedback system of findings to the accountable manager to ensure the effective implementation of corrective actions as necessary.
(b) The management system shall correspond to the size of the organisation and the nature and complexity of its activities, taking into account the hazards and the associated risks inherent in those activities.
(c) If the organisation holds one or more additional organisation certificates within the scope of Regulation (EU) 2018/1139, the management system may be integrated with that required under the additional certificate(s) held.
Addition of Clause 145.A.202 – Internal safety reporting scheme
(a) As part of its management system, the organisation shall establish an internal safety reporting scheme to enable the collection and evaluation of such occurrences that are to be reported under point 145.A.60.
(b) The scheme shall also enable the collection and evaluation of those errors, near misses, and hazards reported internally that do not fall under point (a).
(c) Through that scheme, the organisation shall:
- identify the causes of, and contributing factors to, the errors, near misses and hazards, reported, and address them as part of its safety risk management process in accordance with point 145.A.200(a)(3);
- ensure an evaluation of all known, relevant information relating to errors, near misses, hazards, and the inability to follow procedures, and a method to circulate the information as necessary.
(d) The organisation shall make arrangements to ensure the collection of safety issues related to subcontracted activities.
Note – Recognizing the importance of addressing contributing factors was addressed many years ago by Boeing with the introduction of the MDEA Program
Next Steps
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145.A.200, Annex II (Part-145), aviation, aviation safety, Commission Regulation (EU) 2021/1963, EASA, EASA 145, EASA Part 145, EASA Part 145 Organisation, Management System Requirements, Management Systems, Part 145 Environment, Regulation (EU) No 1321/2014, Regulation 2021/1963, sasblogs
