Steve Bentley MD Sofema Aviation Services Considers the need for Human Factors Training for Part M Staff and notes EASA have not acted since the issue of NPA 2013-01 (B) more than 5 years ago.
The potential for human error is ever present and best practice organizationally driven behaviours, together with enhanced personal understanding can only add to the overall safety in a positive way so the message to all CAMO Accountable Managers is not to wait for EASA – Act now!
Aviation Human Factors Training should not be one size fits all – means that the exposure to the potential of Human error is different depending on the role and responsibility of the individual within the organisation.
For example, the potential of the worker to commit an error is different to the potential of the manager to create an environment where the worker falls into a trap (inadvertently set by the managers behaviour) and commits an error.
The European Human Factors Advisory Group (EHFAG) has evaluated the Part-M requirements against good human factors principles that have been developed within the Part-145 requirements and implemented in Part-145 maintenance organisations in the past decades.
The EHFAG has concluded that the current Part-M requirements lack a good basis of human factors requirements.
Problems in human performance within the Part-M Subpart G Organisation and its interactions with contracted maintenance organisations have frequently been identified as contributing factors in accidents and serious incidents.
Means that just like the manager is potentially able to create an environment where the worker commits an error. So too can the Maintenance Planning Department of the Continuing Airworthiness Management Organisation (CAMO) also be responsible for a pre-cursor which can become the source of an error for the Aircraft Maintenance Organisation (AMO)
The material addressing EHFAG recommendations where proposed for implementation in EASA NPA 2013-01 (B) however some 5 years later no formal embodiment action has been proscribed.
The original intention was that recommendations embodied in NPA 2013-01 (B) should form an integral part of a management system for safety, specifically in the following areas:
a. Internal occurrence reporting
Currently, Part-M lacks clear and specific rules on this subject. As internal safety reporting and error management form an important part of safety management, new provisions, aligned with the equivalent of Part-145, have been introduced.
b. Personnel requirements
A lack of human factors competence can result in errors being made by staff within the Part-M Subpart G organisation and in poor decision making. HF competence, the understanding of human error and the consequences of human and organisational behaviour, is acknowledged as the basis for prevention of making errors.
Therefore, to align with Part-145, human factors training requirements are established, both for initial and continuation training, to understand the application of human factors and human performance issues and to harmonise human factors competence standards between the CAMO and maintenance organisations.
This improved rule is proposed to only apply to organisations managing complex motor-powered aircraft or aircraft used for commercial air transport.
Guidance on the HF training to be delivered and the qualification and competence of HF trainers to be managed to an acceptable standard.
c. Continuing Airworthiness management:
Continuing airworthiness management should also consider human factors and human performance limitations for ensuring good continuing airworthiness management practices.
This should include the development of maintenance programmes and how they are delivered and used by the maintenance organisation.
The new material (Currently whilst presented as an NPA has not been formally issued as of July 2018)
The requirement essentially focuses on raising awareness, increasing human reliability, hence reducing potential for error.
Considering the key role that Part-M Subpart G organisations play in the management of safety critical airworthiness factors and in shaping the maintenance control structure within which the maintenance organisation intervenes.
Conclusion & Next Steps
Organisations who fully understand the potential HF exposure will take steps as part of the competence management obligations related to the management of CAMO staff will take proactive steps to implement training rather than wait to be told by EASA