So what is going on
Well EASA issued NPA 2013 – 1 which was going to address the need to embed SMS within the 145 and Part M organisation in order to satisfy the obligation of the organisation to comply with State obligations in respect of meeting compliance with ICAO annex 19.
But – they withdrew the NPA and there is nothing currently concrete on the table – so there is no need then for SMS within either a Part 145 organisation or Standalone Part M ?
The reality
In respect of compliance with EASA it is true that such depth of SMS is not required to ensure regulatory compliance
Hоwever consider 2 issues:
a) In respect of the States Obligation to ensure that the country complies with UN
protocols the 145 organisation was obliged to have a proactive SMS from Jan 2009
b) To look inside our organisations and to understand our attitude towards Safety Management Systems – means do we have an SMS because we have too or because we want to !
Further Considerations
a) Consider that in some countries (which essentially follow EASA) recognizing the obligation to comply with ICAO is a dominant factor have implemented standalone SMS national obligations independent of EASA see UAE GCAA CAR X (CAR 10)
b) Where is the authority, moral or otherwise for all European Countries to ignore
the SMS obligations driven by the need of the state to show compliance with ICAO
c) For the European Operator it is a now a full obligation to implement an SMS, so what happens if you have a 145 within your organisation? will you exclude it from your SMS? And if the answer is yes – why ? again it comes back to the reason for the SMS
i/ If we have an SMS is it because we have to have it or we want it
ii/ how effective is a process where we are only implementing a performance system because of a perceived obligation (for sure the potential of a highly successful outcome is questionable to say the least)
d) For the operators CAMO we must have a fully implement SMS (not possible to exclude) how then will the oversight systems interface with a 145 organisation with a limited SMS.
Conclusion
By delaying the implementation of SMS within a 145 organisation EASA has not in any way helped the situation, nor in truth are they meeting the core obligations delivering an obligation 10 years late is disgraceful.
Part 145 Organisations which take a long hard look at their processes will no doubt understand that the only successful way ahead is to implement an ICAO compliant SMS whilst waiting for the sleepy behemoth which is EASA to get its act together and to deliver the ICAO equipment within the framework of the EASA Implementing Rule Structure.
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