Regulatory Drivers for Safety Management System (SMS) Root Cause Analysis Processes
SofemaOnline (www.sofemaonline.com) considers SMS RCA Obligations
Introduction
All elements of your business should share the same SMS as well as the same process of engagement, in addition, all elements and processes need to be promoted and educated throughout the organization.
The transition from a traditional SMS to the ICAO Annex 19 “Risk Managed Model”, required many changes throughout the organization process and procedures as well as physical within the workplace.
The real SMS solution requires an integrated approach within the organization with commitment from the senior management and an understanding of the need and importance throughout the organization. (It is essential that the entire management team is fully committed).
Note - When we consider root cause associated with SMS related or identified issues it is often related to competence, process, procedures, training as well as the interaction of several different cultures at work within the organization.
Considering ICAO RCA Expectations
International Civil Aviation Organisation (ICAO) Safety Management Manual (SMM) identifies the following guidelines and expectations:
a) To contribute to the continuous improvement of the aviation system by providing the root causes of accidents/ incidents and lessons learned.
b) To ensure appropriate follow-up action is expected, such as further analysis to determine source and root cause of the abnormal incident.
c) To require quality and safety practitioners to be trained on various analysis methods including root cause analysis and statistical trending analysis.
d) To provide an SMS system which is supported by Quality Management System (QMS) processes such as auditing, inspection, investigation, root cause analysis, process design, statistical analysis, and preventive measures.
What does European Aviation Safety Agency (EASA) say about RCA?
a) Existing systems quite often fail to properly establish the root cause or causes (as well as the various contributing factors, which consequently leads to ineffective corrective actions).
b) To ensure a thorough analysis of causes and contributing factors will enhance an organization’s capability to perform proper risk assessment.
c) Providing for proper understanding of past problems is important when considering the exposure related to hazards and risks.
Root Cause within Regulation 1321/2014 Elements for Consideration
a) M.A.905(c) appropriate corrective action to prevent reoccurrence of the finding and its root cause;
b) AMC M.A.403(b) analysis necessary to identify the root cause of the defect;
c) AMC M.B.104(f) to determine the root cause;
d) M.A.619(c) - M.A.716(c) - M.A.905(c) - 145.A.95(c) - 147.A.160(c) - 21.A.125B(c) - 21.A.158(c) corrective action to the satisfaction of the competent authority;
e) M.A.712(a) ensure corrective action as necessary;
f) M.B.605(a) - M.B.705(a) - 145.B.50(a) until successful corrective action has been taken by the organization subject to a satisfactory corrective action plan;
g) M.B.903 shall require appropriate corrective action;
h) 145.A.60(b) corrective actions taken or to be taken by the organization;
i) 145.A.65(c) ensures proper and timely corrective action is taken in response to reports.
Occurrence Reporting Regulation (EU) No 376/2014 – Comments
The follow-up requirements are not intended to jeopardize the quality and thoroughness of an occurrence analysis.
Note - It may be detrimental to safety if rushed in order to be completed within the encouraged three months period without properly establishing root cause and determining relevant remedial action.
Further Guidance
Sofema Aviation Services (SAS) and SofemaOnline (SOL) is pleased to offer a range of EASA compliant regulatory training courses in support of Aviation Safety Management System (SMS) Hazard Identification, Risk Assessment, Root Cause Analysis & Mitigation Implementation.
For details please see www.sassofia.com www.sofemaonline.com or email: office@sassofia.com or online@sassofia.com
