SMS Introduction to EASA Part CAMO - Concepts & Philosophy

Introduction & Considerations - Steve Bentley CEO of Sofema Aviation Services (www.sassofia.com) & Sofema Online (www.sofemaonline.com)

Introduction

EASA as the representative of the European Aviation Community has the responsibility to develop a set of regulations that can be embraced by the European Aviation Community to demonstrate compliance with the requirements of ICAO Annex 19.

EASA has focused on the introduction of the additional safety management components, building upon the existing management system, rather than adding them as a separate framework.

Additionally, if the organization holds multiple organization approvals related to Regulation (EU) 2018/1139, it may choose to implement a single management system to cover all of its activities.

Such a management system can meet all needs & obligations across several business systems such as security, occupational health and environmental management systems.

The core part of the management system framework (CAMO.A.200) focuses on what is essential for safety management, by mandating the organization to:

(a) Clearly define accountabilities and responsibilities

(b) Establish safety policy and the related safety objectives

(c) Implement safety reporting procedures in line with just culture principles

(d) Ensure the identification of aviation safety hazards entailed by its activities, ensure their evaluation, and the management of associated risks, including:

(1) Taking actions to mitigate the risks

(2) Verifying the effectiveness of the actions taken to mitigate the risks

(e) Monitor compliance, while considering any additional requirements that are applicable to the organization

(f) Keep their personnel trained, competent, and informed about significant safety issues, and

(g) Document all the key management system processes.

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

a) Hazard identification

b) Safety risk management

c) Internal investigation

d) Safety performance monitoring and measurement

e) Management of change

f) Continuous improvement

g) Immediate safety action and coordination with the aircraft operator’s Emergency Response Plan (ERP)

 

General Notes Related to SMS within Part CAMO

1/ It is important to recognize that safety management will be a continuous activity, as hazards, risks and the effectiveness of safety risk mitigations will change over time.

2/ These key safety management processes are supported by a compliance monitoring function as an integral part of the management system for safety.

3/ Most aviation safety regulations constitute generic safety risk controls established by the ‘regulator’.

4/ Therefore, ensuring effective compliance with the regulations during daily operations and independent monitoring of compliance are fundamental to any management system for safety.

5/ The compliance monitoring function may, in addition, support the follow-up of safety risk mitigation actions.

6/ Where non-compliances are identified through internal audits, the causes will be (SHOULD BE *) thoroughly assessed and analyzed. - HOW?

Such an analysis in return supports the risk management process by providing insights into causal and contributing factors, including HF, organizational factors and the environment in which the organization operates.

Note 1: The outputs of compliance monitoring become some of the various inputs to the safety risk management functions.

Note 2: The safety risk management processes may be used to determine focus areas for compliance monitoring.

Developing Metrics

Internal audits will inform the organization’s management of the level of compliance within the organization, whether safety risk mitigation actions have been implemented, and where corrective or preventive action is required.

The combination of safety risk management and compliance monitoring should lead to an enhanced understanding & exposing opportunities for increased efficiencies, which are not limited to safety aspects.

The primary focus of the key safety management processes is on the organizational processes and procedures, but it also relies on the humans in the system.

The organization and the way in which it operates can have a significant impact on human performance.

Therefore, safety management necessarily addresses how humans can contribute both positively and negatively to an organization’s safety outcomes, recognizing that human behavior is influenced by the organizational environment.

Management Commitment

1/ The effectiveness of safety management largely depends on the degree of commitment of the senior management to create a working environment that optimizes human performance and encourages personnel to actively engage in and contribute to the organization’s management processes.

2/ A positive safety culture relies on a high degree of trust and respect between the personnel and the management, and it must therefore be created and supported at the senior management level.

3/ If the management does not treat individuals who identify hazards and report adverse events in a consistently fair and just way, those individuals are unlikely to be willing to communicate safety issues or to work with the management to effectively address the safety risks. As with trust, a positive safety culture takes time and effort to establish, and it can be easily lost.

4/ It is further recognized 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 materialize.

5/ 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 organization culture, and lead to more effective control of contractors and suppliers.

6/ In addition, through an improved relationship with the authority, an effective management system may result in a reduced oversight burden.

Conclusion - The Way Forward!

Thus, by viewing safety management and the related organizational policies and key processes as items that are implemented not only to prevent incidents and accidents but also to meet the organization’s strategic objectives, any investment in safety should be seen as an investment in productivity and organizational success.

Next Steps

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