Safety Management Systems in Continuing Airworthiness Management Organisations and Alleviations for general aviation aircraft concerning maintenance and continuing airworthiness management
Authors Note
» This was laying the foundation for the Introduction of
o Part ML for aircraft below 2730 Kg
o Part CAMO – To Replace Part M Subpart G & Introduce SMS & Management System (Opinion No 05/2016)
o Part CAO – To Replace Part M Subpart F and introduce CAW management as an option
A Discussion Paper by Steve Bentley Group CEO of Sofema Aviation Services www.sassofia.com
Clearing up the Basic Stuff
SMS is not QMS by another name they are both separate and both significantly important QMS together with Quality Assurance (QA) strives to deliver a fully compliant product or process, whereas SMS considers the risk associated with any & all business risks. SMS is both subjective & forward looking. A fully functioning Safety Management System contributes to the viability of the organisation by addressing safety risk.
SMS should focus on real-time performance monitoring and reporting together with effective data analysis – a major challenge being to consider how to capture the required data across the business in a valid way.
Technical Implementation Procedures for Airworthiness and Environmental Certification under The Agreement on Civil Aviation Safety between The Government of Canada & the European Union (Revision 3 - 18 September 2017).
Purpose
The purpose of these Technical Implementation Procedures is to define the interface requirements and activities between Transport Canada Civil Aviation (TCCA) and the European Aviation Safety Agency (EASA) for the import, export, and continued support of civil aeronautical products.
TCCA and EASA shall conduct their certification and validation activities consistent with the Agreement on Civil Aviation Safety (hereafter referred to as the Agreement) and these Technical Implementation Procedures.
Considerations related to the delivery of Safety Systems
Where is your organisations current focus? Is it on compliance or Performance?
This is a significant question because whilst compliance is of course mandatory it is through performance related developments that we are able to optimise and drive significant savings within the organisation, whilst at the same time ensuring we deliver a safe and effective business environment.
Where does safety come from? People or Procedures?
Well simply implementing process and procedure is not in itself going to provide an effective solution to the needs of the organisation. We rely on people to deliver our safety management system and this in turn requires a specific and viable organisational culture and senior led behaviour.
Well firstly to understand the difference between Reactive Driven reporting and Proactive Driven Reporting. With the former clearly something has happened and we need to communicate with the authorities to advise them regarding what has happened. With the latter we have a situation whereby we are trying to proactively identify hazards and exposures where the risk may be considered a salient feature.
By identifying and measuring the risk in a meaningful way we can proceed to develop a greater understanding and as a consequence create appropriate mitigations which can lessen the exposure to the underling risk.
Creating the process
Step 1 then is to have an internal reporting system which meets the company’s needs – the focus should ideally be on the gathering of information (our SMS is heavily reliant on Data) rather than the complexity of the submitted documentation – often simple is better. We are trying to provide a simple mechanism which we will then encourage people to use in a meaningful way. A simpler system removes one of the barriers to avoid reporting (complaints that it is too bureaucratic).
