Considering the EASA Part 145 Management of Change Obligations following the introduction of NPA 2019-05 (C)

SofemaOnline takes a look at what SMS related Change Management Processes are coming into EASA 145 Management Systems 

Introduction

Unless they are properly managed, changes in organisational structure, facilities, the scope of work, personnel, documentation, policies, and procedures, etc. can result in the inadvertent introduction of new hazards and expose the organisation to new or increased risk.

Effective organisations seek to improve their processes, with conscious recognition that changes can expose the organisation to potentially latent hazards and risks if they are not properly and effectively managed.

Regardless of the magnitude of a change, large or small, its safety implications should always be proactively considered. This is primarily the responsibility of the team that proposes and/or implements the change. However, a change can only be successfully implemented if all the personnel affected by the change are engaged, are involved and participate in the process.

The magnitude of a change, its safety criticality, and its potential impact on human performance should be assessed in any change management process.

The process for the management of change typically provides principles and a structured framework for managing all aspects of the change. Disciplined application of the management of change can maximise the effectiveness of the change, engage the staff, and minimise the risks that are inherent in a change.

The introduction of a change is the trigger for the organisation to perform their hazard identification and risk management processes. 

Some examples of change include, but are not limited to: 

1. Changes to the organisational structure
2. The inclusion of a new aircraft type in the terms of approval
3. The addition of aircraft of the same or a similar type
4. Significant changes in personnel (affecting key personnel and/or large numbers of personnel, high turn-over)
5. New or amended regulations
6. Competition (e.g. new competitor)
7. Changes to the customer base (e.g. loss of major customer)
8. Changes to the security arrangements
9. Changes in the financial status of an organisation
10. New schedule(s), location(s), equipment, and/or operational procedures
11. The addition of new subcontractors

Change Driven Hazards - Considering Human Factors 

A change may have the potential to introduce new, or to exacerbate pre-existing, human factor issues. For example, changes in computer systems, equipment, technology, personnel changes, including changes in management personnel, procedures, work organisation, or work processes are likely to affect performance.

The purpose of integrating human factors (HF) into the management of change is to minimise potential risks by specifically considering the impact of the change on the people within a system.

Special consideration, including any HF issues, should be given to the ‘transition period’. In addition, the activities utilised to manage these issues should be integrated into the change management plan.

Effective management of change should be supported by the following: 

1. Implementation of a process for formal hazard identification/risk assessment for major operational changes, major organisational changes, changes in key personnel, and changes that may affect the way maintenance is carried out
2. Identification of changes that are likely to occur in business which would have a noticeable impact on: 

i. Resources - material and human
ii. Management direction - policies, processes, procedures, training
iii. Management control

3. Safety cases/risk assessments that are aviation-safety focused
4. The involvement of key stakeholders in the change management process, as appropriate

i. During the management of change process, previous risk assessments and existing hazards are reviewed for possible effect

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