Sofema Aviation Services (SAS) www.sassofia.com considers the challenge which faces an EASA Part 145 Aircraft Maintenance Organisation (AMO) to build a useable Risk Register.
Introduction ā Why Risk Register?
The Risk Register is an essential tool when developing a Safety Management System within a Part 145 Organisation ā We will use the Risk Register as a focal to understand our most significant exposures which can then be brought to the attention of the leadership team.
In addition, the Risk Register supports the focusing of the attention of the safety expert group to analyze key exposures to enable appropriate analysis and the development of mitigation proposals which are passed to the leadership team ā through the Safety Action Group (SAG) and Safety Review Board (SRB).
What is Risk?
Risk is a subjective measure regarding the exposure of a particular hazard. Hazards are an unavoidable part of the aviation industry, and the assessment of the associated risks helps us to interpret the level of uncertainty, as well as awareness of the degree to which this uncertainty can impact our business & systems.
It is not generally possible to fully anticipate in a repeatable & reliable manner āHF driven variation to expected behavioursā. As a result, such exposures will result in an unavoidable deviation from planned system performance, resulting in a negative impact on performance.
By taking into consideration the limitations related to a rule-based defense strategy it is possible to develop an SMS which is particularly suited to our organisations’ operational environment.
Summary of EASA Requirements
EASA has issued Commission Implementing Regulation (EU) 2021/1963 which becomes effective on December 2nd, 2021.
- A management system should be introduced for all maintenance organisations falling within the scope of Annex II to Regulation (EU) No 1321/2014 (āPart-145 maintenance organisationsā) in order to comply with the International Civil Aviation Organisation (āICAOā) International Standards and Recommended Practices established in Annex 19 to the Chicago Convention.
- All Part-145 maintenance organisations are required to establish an occurrence reporting system. Therefore, the provisions of Annex II to Regulation (EU) No 1321/2014 should be amended to ensure that the occurrence reporting system is established as part of the organisationsā management system and that the requirements are aligned with those of Regulation (EU) No 376/2014 of the European Parliament and of the Council.
- To account for Part-145 maintenance organisations that are also approved as Part-CAMO organisations, it is appropriate to harmonise the general provisions as well as the requirements for competent authorities set out in Annex II (Part-145) of Regulation (EU) No 1321/2014 with those set out in Annex Vc (Part-CAMO) to that Regulation.
Understanding the Risks Faced by an EASA 145 Organisation
The correct identification of hazards is the first step on the road to establishing the risk picture across all business areas.
The hazard identification process is highly subjective, and the competence and skill level of the assessment team is of paramount importance.
The 80/20 Rule
As general guidance, Part 145 Organisations will find that some 80% of identified events and exposures will be classed as low risk. By using the Risk Register as part of the filtering process, the remaining 20% of identified exposures should be subjected to a Qualitative analysis with ideally the support of a safety expert group to remove as much subjectivity as possible from the assessment process.
Next Steps
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Sofema Aviation Services www.sassofia.com & Sofema Online www.sofemaonline.com offer classroom, webinar, and online training to support the implementation of SMS within your 145 organisation. Please see the following link or email team@sassofia.com for additional details.
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Aircraft Maintenance Organisation (AMO), aviation, Aviation Risk, Aviation Safety Management System, Aviation SMS, Commission Implementing Regulation (EU) 2021/1963, EASA 145 organisation, EASA Part 145, EASA requirements, Risk Register, SAS blogs
