EASA 6 Step Risk Assessment Process Review

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Sofema Online (SOL) www.sofemaonline.com reviews the EASA recommended process for moving through the risk assessment process.

Introduction

Managing the safety risks related to a change is a standard component of SMS, as specified in multiple EASA regulations for a Management System (AMC1 ORO.GEN.200(a)(1);(2);(3);(5) Management system

Note – This process was developed in a covid world, however, has validity related to general operational activities.

AMC1 ORO.GEN.200(a)(3) Management system (complex operators — safety risk management)

The management of change should be a documented process to identify the external and internal changes that may have an adverse effect on safety. It should make use of the operator’s existing hazard identification, risk assessment, and mitigation processes.

EASA Six-Step Process:

1/ Structure your list of changes by phases of disruption

» Changes to operations (for example repatriation flights),
» Long-term storage of aircraft,
» Return to Normal Operations (RNO) with initial recovery and sustained growth.

2/ Identify which change can create conditions that may affect the safety of your operations

» Start by identifying issues or disruptors caused by the change that may affect safety (being, therefore, safety issues). – See the following examples:

o Distancing in operational areas
o Manpower Considerations (reduced personnel)
o Changes to traffic patterns
o Decreasing the frequency of or completely postponing certain inspections, checks, or maintenance activities
o Operational measures (for example flying with a mask)
o Transport of cargo and mail in the passenger cabin

» lack of recency in pilots, ATCOs, maintenance engineers and other categories of staff which may affect competence
» concerns about staying healthy
» concerns about staying in the
» business or becoming redundant, etc.
» consider issues induced by changes within your own and external organisations (service providers),

3/ Cross-check your list of safety issues with the ones you potentially identified and addressed during previous crises

Examples of Major Events include:

» Covid – Ongoing
» The volcanic ash eruption of the Icelandic volcano Eyjafjallajökull in April 2010
» The 2008 financial crash
» Twin Towers (9/11)

Note the opportunity to learn from these previous events, in particular, which safety issues were identified during the various phases of disruption, and which actions were taken to safely return to normal operations.

4/ Consolidate your list of safety issues with the ones identified in published guidance from the aviation communities

» Review your list of safety issues against the ones already identified in various published guidance or other relevant documents from collaborative organisations or Authorities, to see what you may have missed.
» Check safety promotion material, directives, guidelines, articles, videos, tutorials, discussions on social media, conference proceedings, etc.
» Note to also consider contributing factors, which can provide valuable information on the type of disruptors that can be expected.

5/ Focus on the issues where a direct impact on operational safety was identified

» To avoid a disproportionate level of work being spent on redundant risk assessments, focus your effort on the issues where a direct impact on operational safety was identified.
» This is most probably where you should prioritise efforts in reviewing risk assessments.
» Safety issues having a direct impact on operational safety must be risk assessed, in order to quickly determine if any actions should be taken.

6/ Identify and address possible risk transfers

» Example, wearing a medical face mask on the flight deck can affect Crew Resource Management (CRM) and crew communication, both verbal communication as it is more difficult to speak, and non-verbal as facial expressions are less easy to identify.

o Wearing a medical facemask can also complicate donning the oxygen mask in the case of an emergency. Measures such as reducing cabin crew staff, wearing medical facemasks, and social distancing in the cabin can also slow down the evacuation.
o Social distancing can also affect the work of ATCOs, maintenance personnel, and ground staff.

» In case of conflicting risks and mitigation measures, risks must be compared and prioritised. (In case of a drop in cabin pressure, for instance, hypoxia is a more serious risk than transmitting COVID-19)

o Wearing oxygen masks, therefore, takes precedence over wearing medical facemasks.
o In emergencies, emergency procedures prevail and in unforeseen situations for which no SOPs exist, professional judgment should be used, considering risk-based reasoning and good common sense.

Once the affected/not valid risk assessments have been identified, follow your standard Risk Management process in order to re-assess the risk and, where applicable, also the relevant mitigating actions to maintain the risk at the required acceptable level.

Monitor your safety performance to confirm or revise your updated risk assessment  

» Use your SMS Safety Performance Monitoring and Measurement process to ensure that the mitigations remain effective and the risks acceptable, and that the overall safety performance remains in line with the objective.

o This may require regular continuous oversight activity by safety assurance and compliance monitoring personnel

Roles of Competent Authorities

» As part of their surveillance activities, Competent Authorities should ensure that the organisations apply their change management process (Including within the context of COVID-19), and update their risk assessments and mitigations, where relevant, as well as monitor and measure safety performance in order to detect any negative trend early-on and to take action at an organisational level.
» As part of their SMS activities, Competent Authorities should also review their own risk management process and make sure their risk assessments are up to date, in order to detect early any negative trend and take action at CA’s level, for instance by adapting safety promotion material or increasing oversight during this period in time.
» Competent authorities should as well try to maintain a systemic view on the capacity of suppliers and service providers to continuously provide essential services.

o The organisations depending on these services could suffer from a significant impact if they are disrupted, however, relevant information from an assessment of this risk may be available to the competent authority but not to the organisation that is the customer of such suppliers or service providers. 

Next Steps

Sofema Aviation Services (SAS) Provides Safety Management System Consultancy, Classroom, Webinar, and Online Training including a 3-Day SMS Safety Risk Management course.

For additional details, please visit our websites www.sassofia.com and www.sofemaonline.com or email team@sassofia.com

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