Steve Bentley FRAeS CEO of Sofema Aviation Services (SAS) www.sassofia.com – considers a number of key processes involved in the process of hazard assessment within an EASA Part 21 J organisation
Introduction
Theoretical Foundations of Hazard Identification in Part 21J
Hazard identification (HAZID) under Part 21J is anchored in theoretical safety concepts, primarily driven by a proactive risk management approach.
The main theories include:
- Reason’s Swiss Cheese Model: Emphasizes that hazards result from multiple latent conditions within organizational processes, each representing a “slice” in the “cheese” where weaknesses may align to create risk.
- Risk-Based Approach (RBA): Promotes risk prioritization by focusing on high-impact and high-likelihood hazards, thus facilitating efficient resource allocation.
- System-Theoretic Process Analysis (STPA): Uses a system perspective to examine design process controls, helping to identify potential hazards that may arise from control failures within the design process. (See Sofema Download Library Area – Part 21 SMS)
- The Structured What-If Technique (SWIFT): A proactive hazard analysis approach that uses structured brainstorming with guidewords and prompts to identify potential risks efficiently.
>> It is designed to be faster than more comprehensive methods like Failure Mode and Effects Analysis (FMEA), making it adaptable to various sectors, including the aerospace industry.
>> For EASA Part 21J Design Organization Safety Management Systems (SMS), SWIFT offers a valuable method to identify design and operational risks early in the development process.
>> Its structured approach enables the design organization to assess potential safety issues systematically, facilitating timely and targeted mitigations.
Note – Like other methods such as FMEA, SWIFT may not provide comprehensive risk coverage when used in isolation. Integrating SWIFT into a broader SMS framework enhances its effectiveness, as it supports proactive risk identification while aligning with EASA’s safety objectives for design assurance and continuous safety monitoring.
Practical Solutions for Hazard Identification within Part 21J
Note the relationship between the cost of design changes and the evolution of development.
Integration of Hazard Identification within Design Stages
- Early Design Review: Conducting hazard identification during initial design reviews can help identify system-level hazards before they evolve into complex issues.
- Use of HAZID Tools: Techniques such as Failure Modes and Effects Analysis (FMEA), Preliminary Hazard Analysis (PHA), and Hazard and Operability Studies (HAZOP) can be embedded into routine design assessments.
- Cross-Functional Teams: Involving engineers, safety specialists, and quality assurance staff in hazard identification activities facilitates diverse perspectives, promoting comprehensive hazard assessment.
Leveraging Digital Solutions for Hazard Tracking
- Digital Tracking and Reporting Systems: The use of digital tools like safety dashboards to track hazards and monitor their mitigation status in real-time enhances accountability.
- Data Analytics for Trend Analysis: Trend analysis of past incidents and non-conformities helps to recognize recurring patterns that might indicate latent hazards.
Embedding Safety Culture and Reporting Mechanisms
- Speak-Up Culture: Encouraging employees to report potential hazards without fear of negative consequences strengthens the identification process.
- Incident and Hazard Reporting Systems: Implementing easy-to-use reporting systems that are accessible to all employees within the 21J environment increases the likelihood of early hazard identification.
Challenges in Hazard Identification for Part 21J
- Complex and Rapidly Evolving Design Environments
>> Complex System Interactions: As systems become more integrated and complex, identifying hazards related to these interactions is increasingly challenging.
>> Dynamic Regulatory and Technological Landscape: Rapid advancements in technology and evolving regulations make it difficult to continuously update hazard identification processes.
- Resource Constraints
>> Time and Budget Limitations: Organizations often face time and budget constraints that may limit the extent and frequency of hazard assessments.
>> Skilled Personnel Shortage: The need for specialized knowledge in hazard identification, coupled with a limited workforce, can constrain SMS effectiveness.
Best Practices for Part 21J Hazard Identification – Developing a Structured Hazard Identification Program
- Defined Roles and Responsibilities: Clarifying roles within the hazard identification process ensures accountability and engagement from all levels.
- Regular Safety Audits and Reviews: Conducting routine safety audits focused on hazard identification strengthens the proactive identification process.
- Collaborative Workshops and Brainstorming Sessions: Engaging cross-functional teams in hazard identification workshops can foster collaboration and uncover hidden hazards.
Safety Training Programs Tailored to 21J Environments
- Initial and Recurrent Training: Regularly updated training programs should cover theoretical aspects of hazard identification, familiarizing employees with tools like FMEA, PHA, and other HAZID methodologies.
- Scenario-Based Training: Using real-life case scenarios in training allows participants to apply hazard identification techniques in controlled, relevant situations.
- SMS Competency Assessments: Assessing employee competence in SMS processes ensures they retain necessary hazard identification knowledge and skills.
Detailed Training Considerations for Hazard Identification in Part 21J
Theoretical and Practical Components
- Fundamentals of Hazard Identification: Training should emphasize the core theories, such as risk-based approaches, the Swiss Cheese Model, and STPA.
- Application of HAZID Techniques: Providing hands-on training in FMEA, PHA, and root cause analysis methods prepares employees for real-world applications.
Training on Advanced Risk Assessment Techniques
- Advanced Risk Analysis: Training on advanced risk assessment techniques, like bow-tie analysis and fault tree analysis, enables in-depth hazard examination.
- Systemic Thinking Skills: Developing systemic thinking abilities equips employees to view hazards within the broader context of the design process.
Next Steps
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For more information, visit the following training course: EASA Part 21 Subpart J Safety Management System Implementation – 2 Days or contact us at team@sassofia.com.
Tags:
Safety Culture, SAS blogs, Safety Training Program, Sofema Aviation Services (SAS), Steve Bentley FRAeS, EASA Part 21 J, Hazard Identification Processes, Risk-Based Approach (RBA), System-Theoretic Process Analysis (STPA), The Structured What-If Technique (SWIFT), Digital Solutions, Reporting Mechanisms
