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Comments by Steve Bentley MD Sofema Aviation Services www.sassofia.com

Introduction

As a precursor to the introduction of Regulation 376/2014 EASA identified shortcomings related to Aviation Occurrence Reporting and proposed in 2010 a new regulation which in compliance with ICAO objectives moved the focus from a ‘reactive’ system to a pro-active, risk and evidence based system.  It also acknowledges that safety occurrence data is vital to allow for the timely identification and management of potential safety hazards and acts upon this before these hazards turn into an actual accident. 

EASA introduced EU Regulation 376/2014, (repealing EU directive 2003/42/EC), which came into force on 15th Nov 2015. The regulation provides additional safeguards to address the lack of protection of the reporters, the lack of harmonisation in the occurrence data collection and integration (leading to low quality reports and incomplete information), as well as insufficient requirements regarding safety analysis and the resulting recommendations.

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Introduction

Effective safety reporting of hazards by operational personnel is an important cornerstone of the management of safety. Therefore, an operational environment in which operational personnel have been trained and are constantly encouraged to report hazards is the prerequisite for effective safety reporting.

The ICAO requirements require that aviation service providers develop and maintain, within the scope of their SMS, a formal process for collecting, recording, acting on and generating feedback about hazards in operations. The process shall be based on a combination of reactive, proactive and predictive methods of safety data collection. 

Best Practice Considerations

Consider the following as best practice objectives regarding the delivery of an optimize and effective Safety Management System.

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Sofema Aviation Services www.sassofia.com looks at the ICAO Data Reporting System

ADREP Introduction

The Accident/Incident Data Reporting (ADREP) is operated and maintained by ICAO.

The ADREP system receives, stores and provides States with occurrence data that will assist them in validating safety.

In this context, the term ‘occurrence’ includes both accidents and incidents.

The system was established in 1976 but has evolved to meet changes in information technology and the aviation industry. The version of the ADREP system in current use is ADREP 2000.

Annex 13 to the Chicago Convention — Aircraft Accident Investigation - contains Standards which require Contracting States to report to the International Civil Aviation Organisation (ICAO) information on all aircraft accidents which involve aircraft of a maximum certificated take-off mass of over 2 250 kg.

The Organisation also gathers information on aircraft incidents considered important for safety and accident prevention.

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Risk Assessment

Driven by ICAO Annex 19 Identifying, Assessing, and Mitigating Risk is at the epicentre of an effective Aviation Safety Management System (SMS).

The challenge is to ensure that Safety Risk Assessment is performed in a genuine way with tangible benefits as a measurable outcome. The consequence of a risk can usually be expressed in several ways and these will affect the assessment of severity and likelihood, requiring care competence and diligence on the part of the analysts. 

Delivering Effective Risk Assessment Requires?

When considering Risk the challenge will always be related to the subjectivity of the perceived exposure. Therefore a broad range of contributors to the Risk Assessment Process is highly beneficial including.

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Considering ICAO Definition of Safety

ICAO Annex 19 defines safety as ‘the state in which risks associated with aviation activities, related to, or in direct support of the operation of aircraft, are reduced and controlled to an acceptable level’ and safety performance as ‘a service provider’s safety achievement as defined by its safety performance targets and safety performance indicators’.

Challenges to Establish Confidence in Safety Performance?

Whilst it is usual for safety metrics to focus on serious incidents and accidents it is also possible to gain a false impression regarding the overall level of safety due in part to a system with a low number of high consequence negative outcomes, means the low frequency of such outcomes may give the wrong impression that your system is safe.

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Sofema Aviation Service www.sassofia.com looks at SMS reporting from the EASA perspective

What do we mean by Safety Occurrence Reporting?

We use the term Safety Occurrence to identify as a collective term which is used to embrace all events which have, or could have significance in the context of aviation safety.

Events identified may in fact range from minor events which are deemed to have a potential for an impact on safety through to incidents or events that should be reported to more serious events including serious incidents and accidents.

Building a Reporting Culture

The willingness to report, safety related exposures is a significant measure when we are considering the effectiveness of Safety Management System.

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One of the biggest barriers to an effective Safety Management System (SMS) depends on the willingness of the employees to engage with the organisational system and for the managers to support such a program in a positive and tolerant way.

Without the willingness to engage with the Safety Management System (SMS) the level of data capture will lead to the creation of barriers.

Full engagement by the Management Team is an essential first step on the journey and without doubt. If we are going to maintain a healthy safety management systems (SMS) we require an open process of hazard reporting which allows us to understand the exposure and to reduce the operational risk.

How we are impact the various organisational barriers is in turn impacted by cultural and other behaviours which are often routed in mistrust.

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Safety is defined as “The condition to which risks are managed to acceptable levels.”

Whenever Humans and Machines are involved there will always be potential for accident and incident. Safety management is based on the premise that hazards, risks and threats will always exist.

With a Safety Management System (SMS) we focus on the real possibility of reducing the organisations exposure across a range of business areas – we do this by delivering a systematic approach to risk management.

It is possible to promote transparent processes which establish clear lines of accountability and aid decision-making and to use this as a tool to drive positive change.

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Sofema Aviation Services www.sassofia.com  & www.sofemaonline.com looks at the bigger picture driven by the recent changes to the EASA Basic Regulation 1139/2018.

Introduction

On 11th September this year entered in force the new EASA Basic Regulation No 1139/2018 which repeals existing Regulation (EU) 216/2008.

The European Aviation Safety Agency (EASA) welcomes the adoption by the Council of the European Union of updated aviation safety rules for Europe which include a new mandate for EASA.

The so-called new Basic Regulation formalises EASA’s role in the domain of drones and urban air mobility, enabling the Agency to prepare rules for all sizes of civil drones and harmonize standards for the commercial market across Europe.

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Within the workplace the consequences of human failure can be significant, unfortunately, we are all capable of error regardless of our training or motivation.

A human error is an action or decision which was not intended, however it is important to consider that human failure is not random. There are two main types of human failure: errors and violations.

Errors often occur highly trained procedures where the person carrying them out does not need to concentrate on what they are doing (Improved design can reduce their likelihood and provide a more error tolerant system).

Violations are rarely malicious (sabotage) and usually result from an intention to get the job done as efficiently as possible. Getting to the root cause of any violation is the key to understanding and hence preventing the violation.

Organisation Obligations

The potential for Human Error should be managed proactively and should be addressed as part of a wider risk assessment process.

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There are a number of ways we can assess the integrity of a Vendor/Supplier with the objective of improving the supplier performance.

Understanding the purpose of Receipt Discrepancy Processes and Component Reliability Assessment including warranty issues.

Why would we carry out a Vendor Survey?

Essentially it is a process which sits alongside the Supplier Evaluation Procedures and enables an ongoing assessment of the effectiveness of the supply chain arrangement with a given vendor.

What do we want to know concerning our vendors?

We want to know how effective is the product which is received from a particular supplier, and we measure this in a number of ways:

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Certain Parts will require special attention due to the size for example Aircraft Landing Gears and Engines. To ensure adequate inspection techniques are followed the following should be included.

a) Written procedures?

b) Internal quality audit procedures?

c) Signature procedures?

d) Procedures for checking for physical damage and defects?

e) Preservation procedures?

f) Procedures for quantities received controls?

g) Verification procedures for part/model/serial numbers?

h) Documentation matches part(s)/material(s) received?

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Sofema Aviation Services www.sassofia.com looks at the basic requirements related to an effective EASA Compliant Aviation Stores

Regulatory Drivers

Storage, Tagging and Release of Aircraft Components and Materials to Aircraft Maintenance

[Part 145.A.25 (d), AMC 145.A.25 (d) 1, 2, 3 - Part 145.A.40 (a) - AMC 145.A.42 (b) - Part 145.A.70 (a) 12] 

Concerning Storage

Stores shall provide the necessary capacity to stock aircraft components, consumable and raw material in the manner recommended by manufacturer’s instructions and in accordance with the relevant regulations and safety precautions.

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EASA Regulations Provide for EASA Part 145 Organisational Theoretical & Practical Training in support of Task Training for CAT A and CAT B2 Aircraft Engineers.

In Addition, EASA Regulations provide for On the Job Training (OJT) following completion of the First Type Training in each Category.

EASA Regulatory Background Guidance

66.A.45 Endorsement with aircraft ratings

In addition to the requirement of point (b), the endorsement of the first aircraft type rating within a given category/sub-category requires satisfactory completion of the corresponding On the Job Training, as described in Appendix III to Annex III (Part-66)

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Equip yourself as an instructor and be able to provide training in support of both EASA 145 & EASA 147.

Support the delivery of training to the highest possible standard of technical and behavioural instructional skill.

Engage with continues professional development and commit to continuous improvement as an instructor.

Available Now! – Online Training to Prepare you for the Instructor Role

SofemaOnline EASA Part 145 / 147 Instructor Techniques Course Train the Trainer course is waiting for you now here.

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Management system audit requirements may include reference to documents such as policies, objectives, processes, procedures, instructions, quality plans, which can when combined with an audit scope statement, deliver internal audits which can be either wide-ranging or focused on any aspect of the organization or part thereof and which has the potential to address risk performance.

ISO 19011 considers that there is a risk associated with delivering an audit program which addresses all the requirements of the various standard or the management system are covered within a year.

Why does this method of scheduling create a risk?

Essentially audit programs which are fitted into an annual 12-month calendar program rarely take risk into consideration.

Tagged in: Audit Program Quality Risks
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Changing the Audit Focus to a Performance Based System where the audits are driven by needs related to both System Performance and Management Objectives rather than by simple schedule.

For maximum benefit the internal management systems audits should connect with an overarching objective to evaluate "risk".

IS031000, defines risk as: "An undesirable situation or circumstance that has both a likelihood of occurring and a potentially negative consequence" or the "effect of uncertainty on objectives".

It is increasingly understood that the explicit and structured management of risk brings benefits.

It is common for internal audit programs to be developed on an annual calendar that predicts which aspects of the Quality Management System are going to be audited.

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Issues and observations made by Steve Bentley MD SAS (www.sassofia.com

EASA Clearly identifies roles and responsibilities of the Role of EASA Part 147 Practical Trainer and Practical Assessor. However EASA has omitted to clearly identify the Role of EASA Part 145 Trainer “Supervisor / LAE”

Following the amendment of EC 1149/2011 EASA Part 145 has NOT been updated to include either AMC or Guidance material required to ensure standardisation of the OJT / OJE Process – rather it is left as an open obligation of each organisation to individually develop a procedure which is then accepted by the local Competent Authority (CA) (potential weakness and exposure).

Appendix III to AMC defines On-the-job-Experience as requiring a particular skill set to be present with the role of Supervisor related to the role of OJT “trainer” – this requires both training to an organisational standard & authorisation (see highlighted area above).

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Sofema Aviation Services www.sassofia.com looks at several Organisational Challenges related to the Management of  on the Job Training within an EASA Part 145 Environment

Regulatory Background

Driven by changes in EASA regulations in accordance with EC 1149/2011 EASA introduced unique terms for Practical Training which is the responsibility of the 147 Organisation and “On the Job Training (OJT) which typically sits with the 145 organisation.

Note 2 – Whilst EASA Part 147 Contains multiple references to roles and responsibilities in respect of the role of Practical Assessor and Practical Trainer – There is an absence of guidance within EASA Part 145 - Clearly this is a challenge.

EASA References within Part 66 provide for very limited guidance material related to 145 – Ref appendices to Annex III 

Appendix III - 4.2 Point 6 On the Job Training (OJT) shall be approved by the competent authority who has issued the licence.

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Steve Bentley MD of Sofema Aviation Service (www.sassofia.com) looks at issues related to Part 66 OJT

This document is additionally supplied as an appendix to the Sofema Aviation Services / SofemaOnline “Going it alone” document.

What is Basic Experience? 

Basic Experience is the number of years you have to be able to demonstrate prior to being accepted for the issue of an AMEL. 

From EASA FAQ - Where do I gain the required basic maintenance experience? Is it mandatory to gain the required maintenance experience in an EASA approved Part-145 organisation? 

According to the AMC 66.A.30(a)(4), aircraft maintenance experience gained within different types of maintenance organisations (under Part-145, M.A. Subpart F, FAR-145, etc.) or under the supervision of independent certifying staff may be accepted by the competent authorities.

Tagged in: EASA Part 66
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