Considerations Related to the Competence of the Part CAMO Safety Manager

Background related to Air Carrier (AC) operating Commercial Air Transport

Since the introduction of regulation 965/2012 European Operators have been working within the guidelines of a Safety Management System.

With the introduction of EASA Part CAMO, the SMS will be extended to cover also CAMO activities. An immediate challenge relates to the competence of existing Airline SMS Managers.

Ensuring Competence of the Part CAMO Safety Manager

CAMO.A.305 Personnel requirements

Regulation (EU) 2019/1383

g) The organisation shall establish and control the competency of personnel involved in compliance monitoring, safety management, continuing airworthiness management, airworthiness reviews or recommendations, and, if applicable, issuing permits to fly, in accordance with a procedure and to a standard agreed by the competent authority. In addition to the necessary expertise related to the job function, competency must include an understanding of safety management and human factors principles appropriate to the person’s function and responsibilities in the organisation.

AMC1 CAMO.A.202 Internal safety reporting scheme

ED Decision 2020/002/R

5) initial and recurrent training for staff involved in internal investigations;

What the UK CAA says about this?

The UK Civil Aviation Authority (the UK CAA) recognises that a considerable number of airline Safety Managers previously approved under the air operation rules (Regulation (EU) No 965/2012, as amended) are unlikely to meet the qualification requirements of Part CAMO.

Many existing Safety Managers may not fulfil the requirements in terms of satisfactory experience related to aircraft continuing airworthiness management.

 

Following is an alternative to the first paragraph of paragraph (e) of AMC1 CAMO.A.305(c), Personnel Requirements.

 

As an existing Safety Manager already approved by the CAA under the Regulation (EU) No 965/2012 for air operations and assisted by additional safety personnel in accordance with GM1 CAMO.A.305(a)(5), in order to meet the requirement of Part CAMO, the person should demonstrate they have successfully completed the following:

 

1. A recognised course covering all aspects of Annex l of Regulation (EU) No 1321/2014, as amended (Part M);

 

2. Training within a CAMO department for a minimum of two weeks gaining a comprehensive knowledge of the following: 

• Development of Aircraft Maintenance Programme (AMP),
• Aircraft Reliability Programmes, 
• Maintenance Steering Group methodology, 
• Maintenance Review Board process,
• Continuing airworthiness tasks and general principles,
• Continued airworthiness concepts and principles,
• Maintenance standards;

3. Thorough knowledge of:

Organisation's CAME,

Maintenance methods,

Applicable regulations; 

4. A relevant aviation qualification that demonstrates the applicant's adequate understanding/knowledge of engineering principles, e.g. ATPL.

The relationship between the Safety Manager and the additional safety personnel shall be clearly defined in the exposition with a clear outline of the delegated responsibilities. The Safety Manager remains the unique focal point.

Any change to the personnel structure applied under this alternative means of compliance shall be notified to the authority in line with CAMO.A.130(a)(5).

 

What Steps Should you take related to Part CAMO SMS Managers Competence?

Whilst the UK CAA does not speak for EASA however where the contribution clearly has merit – you should discuss with your regulatory authority to determine an acceptable course of action.

Additional Guidance

AMC1 CAMO.A.305(a)(4);(a)(5) Personnel requirements

ED Decision 2020/002/R

SAFETY MANAGEMENT AND COMPLIANCE MONITORING FUNCTION

(a) Safety management

If more than one person is designated for the development, administration and maintenance of effective safety management processes, the account manager should identify the person who acts as the unique focal point, i.e. the ‘safety manager’.

The functions of the safety manager should be to:

(i) facilitate hazard identification, risk assessment and management;

(ii) monitor the implementation of actions taken to mitigate risks, as listed in the safety action plan, unless action follow-up is addressed by the compliance monitoring function;

(iii) provide periodic reports on safety performance to the safety review board (the functions of the safety review board are those defined in AMC1 CAMO.A.200(a)(1));

(iv) ensure the maintenance of safety management documentation;

(v) ensure that there is safety training available and that it meets acceptable standards;

(vi) provide advice on safety matters; and

(vii) ensure the initiation and follow-up of internal occurrence investigations.

Next Steps

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