EASA Part 145 Safety Management System (SMS) Considerations

Sofema Online (SOL) www.sofemaonline.com reviews SMS objectives to comply with EASA Part 145 requirements.

Introduction

Point 145.A.200 introduces the following as key safety management processes; these are further specified in the related AMC and GM:

» Hazard identification

» Safety risk management

» Internal investigation

» Safety performance monitoring and measurement

» Management of change

» Continuous improvement

» Immediate safety action and

» Coordination with the aircraft operator’s Emergency Response Plan (ERP)

It is further recognised that the introduction of processes for hazard identification and risk assessment, mitigation, and verification of the effectiveness of such mitigation actions will create immediate and direct costs, while related benefits are sometimes intangible, and may take time to materialise.

Over time, an effective management system will not only address the risks of major occurrences, but also identify and address production inefficiencies, improve communication, foster a better organisational culture, and lead to more effective control of contractors and suppliers.

In addition, through an improved relationship with the authority, an effective management system may result in a reduced oversight burden. Thus, by viewing safety management and the related organisational policies and key processes as items that are implemented not only to prevent incidents and accidents, but also to meet the organisation’s strategic objectives, any investment in safety should be seen as an investment in productivity and organisational success.

AMC1 145.A.200(a)(3) Management system - Safety Management Key Processes

Hazard identification processes:

» A reporting scheme should be the formal means of:

o Collecting,
o Recording,
o Analysing,
o Acting on, and
o Generating feedback about hazards, events, and the associated risks that may affect safety.

» The hazards identification should include in particular:

o Hazards that may be linked to human factors issues that affect human performance; and
o Hazards that may stem from the organisational set-up or the existence of complex operational and maintenance arrangements (such as when multiple organisations are contracted, or when multiple levels of contracting/subcontracting are included).

Risk management processes:

» A formal safety risk management process should be developed and maintained that ensures reactive, proactive, and predictive approaches composed by:

o Analysis (e.g. in terms of the probability and severity of the consequences of hazards and occurrences);

- Assessment (in terms of tolerability);
- Control (in terms of mitigation) risks to an acceptable level.

Note: The severity of the consequence should be evaluated to the best knowledge and engineering judgment of the organisation, and this evaluation may require collecting information from the competent authority, incident/accident investigation reports, the design approval holder, etc.

» The levels of management who have the authority to make decisions regarding the tolerability of safety risks, in accordance with (b)(1)(ii), should be specified.

» Internal investigation In line with its just culture policy, the organisation should define how to investigate incidents such as errors or near misses, in order to understand not only what happened, but also how it happened, to prevent or reduce the probability and/or consequence of future recurrences (refer to AMC1 145.A.202).

» This approach should avoid concentrating the analysis on who was (were) directly or indirectly concerned by the events.

» The scope of internal investigations should extend beyond the scope of the occurrences required to be reported to the competent authority in accordance with point 145.A.60, to include the reports referred to in 145.A.202(b).

» Safety performance monitoring and measurement:

o Safety performance monitoring and measurement should be the processes by which the safety performance of the organisation is verified in comparison with the safety policy and the safety objectives.
o These processes may include, as appropriate to the size, nature, and complexity of the organisation:

- Safety reporting, which may also address the status of compliance with the applicable requirements;
- Safety reviews, including trend reviews, which would be conducted during the introduction of new products and their components, new equipment/technologies, the implementation of new or changed procedures, or in situations of organisational changes that may have an impact on safety;
- Safety audits that focus on the integrity of the organisation’s management system, and on periodically assessing the status of safety risk controls;
- Safety surveys, examining particular elements or procedures in a specific area, such as identified problem areas, or bottlenecks in daily maintenance activities, perceptions and opinions of maintenance management personnel, and areas of dissent or confusion; and
- Other indicators relevant to safety performance, which may be generated by automated means.

Next Steps

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