Concerning Implementation of Safety Management Systems within an EASA Part 145 Organisation

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Sofema Online (SOL) (www.sofemaonline.com) considers the information issued by EASA concerning the various implementation deadlines for compliance with EASA Part 145 Safety Management System Requirements.

» When do I need to Implement SMS within my Part 145 Organisation?
» What are the SMS Deadlines Regarding EASA Part 145 Approval?
» Implementation of Safety Management System in Part-145 Maintenance Organisations in accordance with Regulation (EU) 2021/1963.

Introduction

Regulation EU 2021/1963 which amends Regulation (EU) 1321/2014, introducing Safety Management System (SMS) requirements for Part-145 Maintenance Organisations.

» Regulation (EU) 2021/1963 shall apply from 2 December 2022.
» Organisations already holding a valid approval at this date, shall correct any finding for non-compliance related to Part-145 requirements introduced by this regulation before the 2 December 2024 at the latest.

Concerning Organisations holding a valid Part-145 approval before 2 December 2022

» Need to implement SMS complying with Section A of Regulation (EU) 2021/1963 before 2 December 2024.

Application for SMS implementation by Approval Holders

» Via Application Package (EASA provided to Third Countries – for EASA Countries consult with your Competent Authority).
» EASA Form 21 which contains a clear statement in block 6.3 “Application Type”, e.g., “change for SMS implementation i.a.w. Regulation (EU) 2021/1963”.
» To include the following:

o Implementation plan including timelines for compliance with Regulation (EU) 2021/1963;
o Revised MOE reflecting the amended organisation procedures i.a.w. Regulation (EU) 2021/1963;

Note - It is recommended that this application is not combined with other changes.

Effective 2 December 2022 until 2 December 2024:

» The oversight of the Part-145 approval is performed according to Regulation (EU) 1321/2014 as amended by Regulation (EU) 2021/1963;
» At the time of the first audit (intermediate, change or continuation) of an Organisation not yet compliant with Regulation (EU) 2021/1963, EASA will raise a generic transition finding (within the “SMS change phase”), instead of raising non-compliances against each individual regulatory paragraphs introduced by the new Regulation. The due date of this finding will be set by default on 2 June 2024, to allow EASA the necessary timeframe to assess any corrective actions before the end of the transition period.
» For requirements which were not impacted by the new Regulation, standard findings will be raised as necessary in case of identified non-compliances;
» Any application for change received after 2 December 2023 will not be processed, if EASA has not yet received an acceptable SMS application package as above.

Concerning Organisations Applying for a New EASA Part-145 approval after 2 December 2022

As of 2 December 2022, a new Part-145 certificate can only be issued for Organisations which are in compliance with Regulation (EU) 2021/1963. The following cases may be considered:

» In the case of Initial investigations already ongoing (July 2022) can be completed before 2 December 2022 and old rules apply
» In the case of a New Application, the initial investigation process will have to be supplemented to include verification for compliance with Regulation (EU) 2021/1963.

Recommendation from EASA regarding applications which are submitted post-July 2022 – should target directly compliance with the “new Part-145” (SMS Obligations) as amended by Commission Regulation (EU) 2021/1963.

Next Steps

Sofema Aviation Services (SAS) www.sassofia.com and Sofema Online (SOL) www.sofemaonline.com offer multiple EASA regulatory compliant and vocational courses covering all aspects of EASA Part 145 approval including SMS implementation and HF & SMS compliant training Initial & Recurrent Training.

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