Identifying Change Processes in an EASA Part 145 SMS

January 26, 2026

Blog

Sofema Aviation Services (SAS) Looks at Processes to ensure we are able to Identify change throughout the organisational system.

Introduction

For any medium to large EASA Compliant Part 145 Organisation, the SMS must shift from the “informal” oversight possible in small shops to formalized, data-driven processes.

Typically with limited resources we need to avoid the impact within distinct departments which can lead to SILO behaviour and mentality

Best Practices for Identifying Change

To effectively capture change before it becomes a hazard, the following practices are recommended:

Integrate MoC into Existing Business Processes:

Do not treat Management of Change (MoC) as a separate “safety exercise” done after the fact. Embed “Change Triggers” into standard operating procedures.

- Example: The purchase order process for new tooling should have a mandatory checkbox: “Does this introduce new technology or training requirements?” If yes, an MoC risk assessment is automatically triggered.
Define “Change Triggers” Clearly:

Staff need to know what constitutes a change. Create a “Trigger List” relevant to your specific scope (e.g., “Loss of more than 10% of certifying staff in a shift,” “Introduction of a new aircraft variant,” “Change in shift patterns”).

Utilize “Leading Indicators” from Safety Reporting:

Use your Internal Safety Reporting Scheme (145.A.202) to detect unplanned change. A spike in reports regarding “lack of tooling,” “time pressure,” or “fatigue” is a leading indicator that the operating environment has changed (e.g., increased workload or reduced resources) even if no formal change was announced.

The “Transition Period” Focus:

Explicitly monitor the “transition period” (the time between the old state and the fully implemented new state). This is often the most risky phase where procedures are hybrid and confusion is high. Assign increased supervision during this specific window.

Cross-Functional Safety Committees:

Use your Safety Review Board (SRB) or Safety Action Groups (SAG) to discuss upcoming business changes. Production managers should brief the Safety Manager on commercial changes (e.g., “We are taking on a new customer next month”) so safety impacts can be assessed before the contract is signed.

Challenges for Medium to Large Sized Organisations

Employees face a “middle-ground” complexity that creates specific hurdles:

The “Clay Layer” of Middle Management:

Senior management may define safety policy, and technicians may report hazards, but middle managers (Shift Leaders, Base Managers) often feel the conflict between “production targets” and “safety administration.”

They may suppress the identification of change (e.g., rushing a roster change without assessment) to meet deadlines.

Siloed Information:

Unlike small teams, the Avionics Bay might not talk to the Engine Shop. A change in one area (e.g., borrowing staff from one shop to another) might introduce hazards (lack of competency/familiarity) that are missed because the departments don’t share resource planning data effectively.

“Creeping Change” (Normalization of Deviance):

Gradual changes—such as the slow degradation of ground equipment or the gradual loss of experienced staff—are harder to identify than sudden changes. In a medium-sized org, these slow shifts often go unnoticed until an audit or incident occurs because daily oversight is distributed across many supervisors.

Bureaucratic Burden vs. Agility:

There is a risk of making the MoC process so complex that staff avoid it. If identifying a change requires filling out a 10-page form, staff will pretend the change is “minor” to avoid the paperwork.

Dealing with Reluctance and Pushback

Resistance often comes from the perception that SMS is “extra work” or a “policing tool.”

Reframe Change as “Operational Readiness”:

Move away from safety jargon. Instead of asking “Have you done the Safety Risk Assessment for this roster change?”, ask “Are we operationally ready for this new shift pattern? Do we have the people and tools?” This engages production staff on their terms while fulfilling the safety requirement.

Simplify the Process (Keep it proportional):

Ensure your MoC process is scalable. A “Simple Change” (e.g., swapping a drill brand) should have a simple checklist. A “Complex Change” (e.g., opening a new line station) requires full analysis. If you force complex analysis for simple changes, you will generate pushback.

Demonstrate “Just Culture” in Action:

Reluctance to report unplanned changes (errors/violations) often stems from fear. You must visibly demonstrate that reports of “we didn’t follow the new procedure because it doesn’t work” are met with system improvements (fixing the procedure), not punishment.

Feedback Loops:

Nothing kills engagement faster than a “black hole.” If staff identify a change/hazard, they must see a result. Even if the answer is “we accept this risk,” communicate that decision back to the floor.

Other Relevant Factors – Contractors

Contractors and Subcontractors:

If you rely on any contract labour or subcontractors (e.g., NDT, specialized repairs). The SMS must identify changes within these external providers. Do you know if your NDT provider has lost their Level 3 engineer? Your system must require them to notify you of such changes.

Human Factors (HF) Competency:

Train your supervisors to identify human changes. A technician going through a divorce or experiencing financial stress represents a “change” in human performance capabilities. While sensitive, a mature SMS culture allows supervisors to identify these HF risks and manage work allocation accordingly.

Next Steps

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