Sofema Aviation Services (SAS) www.sassofia.com considers SMS within an ATO environment
Introduction
Complex Organisations – Organisation and Accountabilities (Ref AMC1 ORA.GEN.200 (a)(1) ED Decision 2012/007/R)
The Organisation Should:
- Nominate a Safety Manager (SM);
- Include a Safety Review Board (SRB).
Related to the Safety Manager Role (GM1 ORA.GEN.200(a)(1) ED Decision 2012/007/R):
- SM may require additional resources (Depending on the size, nature & complexity);
- SM should remain the unique focal point as regards the development, administration and maintenance of the organisation’s safety management system.
Safety Manager
- Focal – responsible for:
o SMS Development;
o Administration; and
o Maintenance of the system.
Safety Manager – Responsibilities
- Facilitate hazard identification, risk analysis and management;
- Monitor the implementation of actions taken to mitigate risks, as listed in the safety action plan;
- Provide periodic reports on safety performance;
- Ensure maintenance of safety management documentation;
- Ensure that there is safety management training available and that it meets acceptable standards;
- Provide advice on safety matters; and
- Ensure initiation and follow-up of internal occurrence / accident investigations.
Safety Review Board
- High-level committee strategic safety in support of the AM safety accountability;
- Chaired by AM;
- SRB Activities:
o Safety performance against the safety policy and objectives;
o Expedite Safety Actions
o Monitor effectiveness of the SM process
o Ensure appropriate resources
o SM attendance optional (but makes sense) – consider why attendance is not mandatory?
Complex Organisations – Safety Action Group (SAG) – GM2 ORA.GEN.200(a)(1) ED Decision 2012/007/R
- SAG optional as standing group or Ad-Hoc;
- Multiple SAG’s possible;
- SAG strategic Direction from SRB;
- SAG should contain managers, supervisors and personnel from operational areas.
Safety Action Group (SAG) Role
- Monitor operational safety;
- Resolve identified risks;
- Assess the impact on safety of operational changes;
- Ensure that safety actions are implemented within agreed timescales; and
- Review the effectiveness of previous safety recommendations and safety promotion.
Safety Policy AMC1 ORA.GEN.200(a)(2)- ED Decision 2012/007/R
- Be endorsed by the accountable manager;
- Reflect organisational commitments – proactive and systematic safety management;
- Communicated, with visible endorsement, throughout the organisation; and
- Includes safety reporting principles.
- Commitment to:
o Improve towards the highest safety standards;
o Comply with standards & Legislation
o Provide resources
o Safety as one primary responsibility of all managers;
o Just Culture
Senior Management should:
- Continually promote the safety policy to all personnel and demonstrate their commitment to it;
- Provide necessary human and financial resources for its implementation; and
- Establish safety objectives and performance standards.
SAFETY RISK MANAGEMENT
- Hazard identification processes:
o Reactive and proactive schemes;
o Formal means of collecting, recording, analyzing, acting on and generating feedback about hazards and the associated risks that affect the safety of the operational activities of the organisation;
o All reporting systems, including confidential reporting schemes, should include an effective feedback process.
- Risk assessment and mitigation processes:
o Formal risk management process should be developed and maintained that ensures analysis (in terms of likelihood and severity of occurrence), assessment (in terms of tolerability) and control (in terms of mitigation) of risks to an acceptable level;
o The levels of management who have the authority to make decisions regarding the tolerability of safety risks, should be specified.
Internal Safety Investigation
- Should extend beyond the scope of reportable to CA occurrences.
Safety performance monitoring and measurement
- Safety performance monitoring and measurement – assessment against policy & objectives to include:
o Safety reporting;
o Safety studies,
o Safety reviews including trends reviews;
o Safety audits – system Integrity & Risk Controls; and
o Safety surveys.
The management of Change
- Manage safety risks related to a change.
o Documented process;
o Identify external and internal change that may have an adverse effect on safety;
o It should make use of the organisation’s existing hazard identification, risk assessment and mitigation processes.
Continuous improvement
- Seek to improve its safety performance through:
o Proactive and reactive evaluations of facilities, equipment, documentation and procedures through safety audits and surveys;
o Proactive evaluation of individuals’ performance to verify the fulfilment of their safety responsibilities; and
o Reactive evaluations in order to verify the effectiveness of the system for control and mitigation of risk.
Emergency Response Plan (ERP)
- Actions to be taken by the organisation or specified individuals in an emergency.
- Should reflect the size, nature and complexity
- The ERP should ensure:
o An orderly and safe transition from normal to emergency operations;
o Safe continuation of operations or return to normal operations as soon as practicable.
Training and Communication on Safety
Training
- Appropriate for their safety responsibilities.
- Adequate records of all safety training provided should be kept.
Communication
- Should establish communication about safety matters that:
o Personnel are aware of the safety management activities as appropriate for their safety responsibilities;
o Conveys safety critical information, especially relating to assessed risks and analyzed hazards;
o Explains why particular actions are taken and why safety procedures are introduced or changed.
- Regular meetings with personnel where information, actions and procedures are discussed may be used to communicate safety matters.
- The safety training programme may consist of self-instruction via a media (newsletters, flight safety magazines), class-room training, e-learning or similar training provided by training service providers.
Non Complex Organisations
ATOs Providing Training Only For LAPL, PPL, SPL AND BPL & Associated ratings or Certificates – Organisational Review ref AMC1 ORA.GEN.200(c) ED Decision 2015/011/R
The primary objective of the organisational review is to enable the organisation to ensure that its management system remains effective by verifying that it:
- Continually identified its aviation safety hazards;
- Has effectively mitigated the associated risks; and
- Monitors compliance with the applicable requirements.
Safety risk management should:
- Be performed using internal safety or occurrence reports, hazard checklists, risk registers or similar risk management tools or processes, integrated into the activities of the organisation;
- In particular address safety risks related to a change; making use of the existing hazard identification, risk assessment and mitigation tools or processes; and
- Include provisions for emergency response or a formal Emergency Response Plan (ERP).
Note 1 – As part of the management system documentation required by ORA.GEN.200(a)(5), the organisation should describe the organisational review programme and related responsibilities. Persons responsible for the organisational review should have a thorough knowledge of the applicable requirements and of the organisation’s procedures.
Note 2 – The status of all corrective and risk mitigation actions should be monitored by the person responsible for the organisational review programme and implemented within a specified time frame. Action closure should be recorded by the person responsible for the organisational review programme, along with a summary of the action taken.
The results of the organisational review, including all non-compliance findings and new risks identified during the review, should be presented to the accountable manager and the person or group of persons nominated in accordance with ORA.GEN.210(b) prior to notification to the competent authority.
- All level 1 findings in the sense of ARA.GEN.350 should be immediately notified to the competent authority and all necessary actions immediately taken.
- Based on the results of the organisational review, the accountable manager should determine the need for and initiate, as appropriate, further actions to address deficiencies in or further improve the organisation’s management system.
Next Steps
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Tags:
SMS, SAS blogs, Safety Policy, Safety Review Board, Safety Manager Role, EASA Safety Management System Complex, SRB, Safety Action Group, SAG, Safety performance monitoring and measurement, ORA.GEN.200, ORA.GEN.210
