sms and the easa rules effective management systems for ... · pdf fileeffective management...

AESA SMS/SSP Conference Madrid, 10 & 11 May 2012

SMS and the EASA rules

Effective management systems for

authorities and organisations

Régine Hamelijnck

Rulemaking Directorate Product Safety Department

Outline

01 – Current “state of play”

02 – Authority and Organisation Requirements

Authority and Organisation RequirementsMay 2012 2

Outline




Basic Regulation

Airworthiness

Regulation

Initial airworthiness

Regulation

Continuing airworthiness

Flight Standards

Regulation

Aircrew

Regulation

Air operations

Regulation

TCO

ATM/ANS

Regulation

ATCO

Regulation

SERA

Regulation

AUR

Regulation

ATM/ANS

Systems

Aerodromes

Regulation

ADR

Rule structure – the big picture


Basic Regulation

Airworthiness

Regulation


Regulation


Flight Standards

Regulation

Aircrew

Regulation

Air operations

Regulation

TCO

ATM/ANS

Regulation

ATCO

Regulation

SERA

Regulation

AUR

Regulation

ATM/ANS

Systems

Aerodromes

Regulation

ADR


ADR: Aerodromes

ATCO: licensing and medical certification of air traffic controllers

AUR: common airspace usage requirements and operating procedures

SERA: Standardised European Rules of the Air

Airworthiness

(initial Agency remit)


Airworthiness

Regulation 1702/2003 - Initial Airworthiness

• Scope:

• Design

• TC, restricted TC, changes to TC and restricted TC, STC

• Design Organisation Approval

• Manufacture

• Production Organisation Approval (POA)

• Production without POA

• EASA is the competent authority for:

• Product Certification,

• DOA,

• third country POA and single POA (Airbus)


Airworthiness

Regulation 1702/2003 - Initial Airworthiness

• SMS not yet implemented

• Will be introduced through Rulemaking Task MDM.060, which has just started

• SMS elements will be based on those developed for Flight Standards

• Proposed that all POAs as well as all DOAs implement a management system encompassing SMS (not only those designing/manufacturing aircraft, engines or propellers)

• NPA: end 2012/ beginning 2013

• Opinion/Decision: 1st Quarter 2014 (Regulation one year later)


Airworthiness

Regulation 2042/2003 - Continuing Airworthiness

• Scope:

• Maintenance (Part-145 / Part-M Subpart F)

• Continuing Airworthiness Management (“Part-M Subpart G”)

• Maintenance Training (Part-147)

• Aircraft Mechanics Licensing (Part-66)

• EASA is the competent authority for:

• third country organisations (Maintenance, Maintenance Training and Continuing Airworthiness Management Organisations)

• SMS not yet implemented

• Will be introduced through rulemaking Task MDM.055 (ToRs published 07/2011)

• SMS elements will be based on those developed for Flight Standards

• NPA: September 2012

• Opinion/Decision: 2nd Quarter 2013 (Regulation one year later)


Basic Regulation

Airworthiness

Regulation


Regulation


Flight Standards

Regulation

Aircrew

Regulation

Air operations

Regulation

TCO

ATM/ANS

Regulation

ATCO

Regulation

SERA

Regulation

AUR

Regulation

ATM/ANS

Systems

Aerodromes

Regulation

ADR


“FIRST EXTENSION”

first opportunity for EASA to

develop “SMS” rules


History EASA rulemaking in the area of SMS

EASA Rulemaking tasks: OPS.001 & FCL.001 – started in July 2006

•extend scope of EASA regulations to “flight crew licensing” and “air operations”, while implementing the relevant ICAO Standards on SMS

Proposal for Part “Authority Requirements” (AR) and Part “Organisation Requirements” (OR)

•NPA 2008-22 published in October 2008

•NPA 2009-02 published in January 2009

Opinion 03/2011 published in April 2011

•Part-ARA and Part-ORA for aircrew (Flight Crew & Cabin Crew)

•Regulation (EU) 290/2012 published in April 2012

•AMCs and GM recently published (see Decisions 2012/006/R and 2012/007/R)

Opinion 04/2011 published in June 2011

•Part-ARO, Part-ORO and technical requirements for air operations (Commercial Air Transport)

•Passed EASA Committee – Regulation expected 2nd semester 2012

See: http://easa.europa.eu/agency-measures/opinions.php


Basic Regulation

Regulation

Aircrew

Annex I

Part-FCL

Annex IIConversion of national licences

Annex III Licences of non-EU states

Annex IV

Part-MED

Annex V

Part-CC

Annex VI

Part-ARA

Annex VII

Part-ORA

Rule structure – Aircrew


Regulation 1178/2011 Regulation 290/2012

Flight Standards: Aircrew

Regulation 1178/2011 – “Civil Aviation Aircrew” initially covered Part-FCL, conversion of licences, non-EU licences and Part-MED

• amending Commission Regulation (EU) 290/2012 of 30 March 2012

• Annex V: Part-CC “Cabin Crew”

• Annex VI: Part-ARA “Authority Requirements for Aircrew”

• Annex VII: Part-ORA “Organisation Requirements for Aircrew”

SMS is addressed in Part-ORA


Flight Standards: Aircrew

The following organisations will be required to implement a management system to comply with Part-ORA (SMS):

• Approved Training Organisations (ATOs)

• All organisations providing pilot training for ATPL, CPL, PPL, LAPL, BPL, SPL (= all professional and private pilot licences)

• Holders of an FSTD qualification certificate

• Aero-medical Centres (AeMCs)

EASA is the competent authority for:

• foreign ATOs, foreign AeMCs

• FSTDs located outside the territory of the EASA States

• FSTDs located within EASA States when the organisation operating them is established in a third country.


Basic Regulation

Regulation

Air Operations

Annex I

DEF

Annex IIPart-ARO

Annex III Part-ORO

Annex IV

Part-CAT

Annex V

Part-SPA

Annex VI

Part-NCC

Annex VII

Part-NCO

Annex VIII

Part-SPO

Rule structure: Air Operations

CAT: Commercial Air Transport

SPA: Specific Approvals (e.g. PBN, LVO, ETOPS

NCC: Non-commercial OPS with CMPA

NCO: Non commercial OPS with other than CMPA

SPO: Specialised Operations (Aerial Work)


“OPS I” package

Flight Standards: Air Operations

Draft EU Regulation on Air Operations, will supersede currentlyapplicable EU-OPS and national rules based on JAR-OPS 1 and 3

• First regulation will only cover Commercial Air Transport with aeroplanes and helicopters – publication expected second Semester 2012:

• Annex I: Definitions

• Annex II Part-ARO “Authority Requirements for Air Operations”

• Annex III Part-ORO “Organisation Requirements for Air Operations”

• Annex IV Part-CAT “Commercial Air Transport” - technical rules

• Annex V Part-SPA “Specific Approvals”

• Part-ORO will include management system requirements

SMS elements will be in Part-ORO


Basic Regulation

Regulation

Air Operations

Annex I

DEF

Annex IIPart-ARO

Annex III Part-ORO

Annex IV

Part-CAT

Annex V

Part-SPA

Air operations: OPS I (Opinion 04/2011)

Scope: Commercial Air Transport with aeroplanes and helicopters

excluded: “A to A” flights:

CAT operations starting and ending at the same aerodrome/operating site with

Performance class B aeroplanes or non-complex helicopters


Flight Standards: Air Operations

In the future, the Regulation will be amended to also cover:

• Commercial Air Transport (CAT) with sailplanes and balloons

• CAT A to A flights

• Non-Commercial operators of complex-motor-powered aircraft: Part-NCC, so called “Business Aviation”

• Non-Commercial operators of other-than complex-motor-powered aircraft: Part-NCO

• Aerial Work operators - commercial and non-commercial: Part-SPO “Specialised Operations”

• Rules concerning flight time limitations: FTL


Air Operations – OPS I: transition

General “Opt-Out” provision:

• Member States may decide not to apply the provisions of Annexes I to V until up to two years after the entry into force of the Regulation.

• Entry into force: third day following publication in the EU Official Journal (date tbd).



Grandfathering of existing AOCs

• applies to AOCs issued in accordance with Regulation (EC) No 3922/1991 as last amended (EU-OPS)

• applies to AOCs of aeroplane operators only

• AOC holders shall adapt their management system (SM), trainingprogrammes, procedures and manuals to be compliant with the new rulesno later than two years after the entry into force of the Regulation

• AOC holders shall begin to adapt their management system (SM), trainingprogrammes, procedures and manuals to be compliant with the new rulesfrom the date of entry into force!



Existing AOCs - helicopter operators

• No automatic grandfathering due to varying degrees of compliance withJAR-OPS 3!

• AOCs shall be converted into AOCs compliant with the new Regulation inaccordance with a conversion report established by the Member Statethat issued the AOC, in consultation with the Agency.

• The conversion report will also need to describe how the operator willcomply with new management system provisions (SM).

• Conversion process must be completed by the end of the opt-outperiod chosen by the Member State issuing the AOC.


Air Operations – Third Country Operators

Current status: CRD

• Comment Response Document (CRD) 2011-05 on ImplementingRules on Third Country Operators (TCO) published in January2012.

•Scope:

• Technical rules for TCOs performing commercial air transportoperations (CAT) into, within or out of the EU (Part-TCO),

• rules for the initial authorisation, continuous oversight and thefollow-up of findings (Part-ART) for those TCOs

• all relevant developments related to the Authorisation of TCOs are published here: TCO - Latest news.


Outline




Outline


02 – Authority Requirements


Authority Requirements OPS – Structure

Authority and Organisation Requirements 25

Authority Requirements (ARs)

• To “regulate” in the area of Safety Management we need to

“regulate” both authorities and organisations.

• ARs support the European Aviation Safety Programme (EASP)

and SSP/SMS, in particular by focussing on specific ICAO

critical elements of an oversight system:

CE-3: State civil aviation system and safety oversight functions

CE-4: Technical personnel qualification and training

CE-5: Technical guidance, tools and the provision of safety-critical

information

CE-6: Licensing, certification, authorisation and/or approval obligations

CE-7: Surveillance obligations

CE-8: Resolution of safety concerns.


Authority Requirements (ARs)

ARs establish requirements for:

the administration and management system to befulfilled by the Agency and Member States for theimplementation and enforcement of Regulation (EC) No216/2008 and its Implementing Rules.

ARs:include new provisions addressed to Member States toensure proper oversight capabilities.

support the implementation of EASP/SSP withoutexplicitly regulating SSP (refer to Communication fromthe EC, the Council and the EU Parliament Com(2011)670).


Authority Requirements OPS

Part-ARO

Air Operations

Subpart GEN: General

Requirements

Section II: Management System


Authority Requirements OPS (the same apply for aircrew)

AR0.GEN.200 Management system (extract)

Competent authorities shall implement a management system,including as a minimum:

(a) documented policies and procedures,

(b) sufficient number of personnel, qualified to perform their tasks,

(c) a system to plan the availability of personnel,

(d) adequate facilities and office accommodation to perform the allocated tasks,

(e) a function to monitor compliance including:

� internal audit process

� safety risk management process.

(f) procedures for participation in a mutual exchange of all necessary information and assistance with other competent authorities

…..

…..Authority and Organisation RequirementsMay 2012 29

Outline


02 –Organisation Requirements


Organisation Requirements & SMS

May 12 Authority and Organisation Requirements

EASA Organisation Requirements (ORs)developed for Flight Standards (Aircrew and AirOperations) mandate the implementation of a“management system” with specific features.

These requirements (IRs) and related AMCs/GMset out what is needed in terms of theorganisation’s management system.

These, together with the relevant provisions ofthe Basic Regulation (Regulation 216/2008) fullycover the existing ICAO Annex 1 and Annex 6SMS Standards.

31

Organisation Requirements - SMSEASA approach – main features

Total system approach

Integrated approach

Proportionality

Flexibility

Authority and Organisation Requirements


Organisation Requirements OPS – Structure

Authority and Organisation Requirements 33

Organisation Requirements OPS

Part-ORO

Air Operations

Subpart GEN: General

Requirements

Section II: Management System


Part-ORO Subpart GENSection II “Management System”

Paragraph Title

ORO.GEN.200 Management system

ORO.GEN.205 Contracted activities

ORO.GEN.210 Personnel requirements

ORO.GEN.215 Facility requirements

ORO.GEN.220 Record-keeping


Part-ORO Subpart GENSection II “Management System”

Paragraph Title

ORO.GEN.200 Management system

ORO.GEN.205 Contracted activities

ORO.GEN.210 Personnel requirements

ORO.GEN.215 Facility requirements

ORO.GEN.220 Record-keeping See explanatory note to Part-ORA:

Decision (2012/007/R)

Safety Management Requirements for

organisations - Correspondence

between ICAO SMS and Part-ORO &

Basic Regulation (Essential

requirements)


(a) An operator shall establish, implement and maintain a managementsystem that includes:

(1) clearly defined lines of responsibility and accountability throughout theorganisation, including a direct safety accountability of the accountablemanager;

(2) a description of the overall philosophies and principles of the organisationwith regard to safety, referred to as the safety policy;

(3) the identification of aviation safety hazards entailed by the activitiesof the organisation, their evaluation and the management ofassociated risks, including taking effective actions to mitigate therisk;

(4) maintaining personnel trained and competent to perform their tasks;

(5) documentation of all management system key processes, including aprocess for making personnel aware of their responsibilities, and itsamendment procedure;

(6) a function to monitor compliance of the organisation with the relevantrequirements. Compliance monitoring shall include a feedback system offindings to the accountable manager to ensure effectiveimplementation of corrective actions as necessary.

Management System most relevant IR: ORO.GEN.200 (extract)


AMCs and GM to ORO.GEN.200

Reference Applies to Subject

AMC1-

ORO.GEN.200(a)(1)(2)(3)(5)non-complex

- Responsibility and accountability

- Safety policy

- Hazard identification, risk management

- Documentation of management system key

processes

- Safety manager

- Emergency response plan

AMC1-ORO.GEN.200(a)(1) complex

Organisation and accountabilities:

- Safety manager

- Safety review board (SRB)

GM1-ORO.GEN.200(a)(1) complex Safety action group (SAG)

AMC1-ORO.GEN.200(a)(2) complex Safety policy and management commitment

GM1-ORO.GEN.200(a)(2) all Definition of safety policy

AMC1-ORO.GEN.200(a)(3) complex

Safety risk management:

- Risk management

- Management of change

- Continuous improvement

- Emergency response plan


AMCs and GM to ORO.GEN.200

Reference Applies to Subject

GM1-ORO.GEN.200(a)(3) all Internal occurrence reporting scheme

AMC1 -ORO.GEN.200(a)(4) all Training and communication on safety

AMC1-ORO.GEN.200(a)(5) all Organisation management system documentation

GM1-ORO.GEN.200(a)(5) all Organisation management system documentation

AMC1-ORO.GEN.200(a)(5) complexOrganisation management system documentation –Safety management manual (SMM)

AMC1-ORO.GEN.200(a)(6) all

Compliance monitoring - general- Designation of a compliance monitoring manager - Compliance monitoring documentation - Training

AMC2-ORO.GEN.200(a)(6) non-complex Compliance monitoring - audit checklist

GM1.ORO.GEN.200(a)(6) complex Compliance monitoring - typical subjects

AMC1-ORO.GEN.200(b) all Size, nature and complexity of the activity


SAFETY POLICY

The safety policy is the means whereby theorganisation states its intention to maintain and,where practicable, improve safety levels in all itsactivities and to minimise its contribution to the riskof an aircraft accident as far as is reasonablypracticable.

GM1-ORO.GEN.200(a)(2)


SAFETY POLICY (endorsed by the accountable manager)

• establish safety objectives and performance standards

• reflect organisational commitments regarding safety and itsproactive and systematic management;

• enforce safety as one primary responsibility of all managers

• to be communicated throughout the organisation

• senior management should continually promote the safety policy to all personneland demonstrate their commitment to it

• should include safety reporting principles

• commitment not to blame someone for reporting something which would not havebeen detected otherwise.

AMC1-ORO.GEN.200(a)(2)


Organisational set-up

AMC1-ORO.GEN.200(a)(1) AMC1-ORO.GEN.200(a)(6)

Accountable Manager (AM)

Safety Manager

(SM)

Compliance Monitoring Manager (CMM)

Safety Review Board (SRB)

Accountable Manager plus Heads of functional areas

Safety Action Group (SAG)


Functions :1. facilitate & coordinate hazard identification, risk analysis

and management;

2. monitor the implementation of actions taken to mitigaterisks, as listed in the safety action plan;

3. provide periodic reports on safety performance;

4. ensure maintenance of safety managementdocumentation;

5. ensure that there is safety management training availableand that it meets acceptable standards;

6. provide advice on safety matters; and

7. initiate and participate in internal occurrence / accidentinvestigations.

Safety Manager AMC1-ORO.GEN.200(a)(1)


• high level committee, chaired by the AM.

• considers matters of strategic safety.

FUNCTIONS:

1. monitor safety performance against the safety policy and objectives;

2. ensure safety actions are taken in a timely manner;

3. ensure the organisation’s safety management processes remain effective.

Safety Review BoardAMC1-ORO.GEN.200(a)(1)


optional

• May be established as a standing group or as an ad-hoc group toassist or act on behalf of the Safety Review Board.

• More than one safety action group may be established dependingon the scope of the task and specific expertise required.

• A safety action group should report to and take strategic directionfrom the Safety Review Board and should be comprised ofmanagers, supervisors and personnel from operational areas.

e.g. to assess impact on safety of operational changes, such as:

introduction of a new type of aircraft

use of a new contractor

implementation of new software for component tracking

Safety Action GroupGM1-OR.GEN.200(a)(1)


• Hazard identification processes

• reactive & proactive

• Risk assessment and mitigation processes

• analysis, assessment and control of risks

• Internal safety investigation following occurrences

• Not limited to occurrences required to be reported

• Safety performance monitoring and measurement

• Combination of safety reporting, safety studies, safety reviews,safety audits, safety surveys.

• Management of change

• Identify changes that may adversely affect safety

• Use existing tools and mechanisms to assess and manage relatedrisks

SAFETY RISK MANAGEMENT AMC1-ORO.GEN.200(a)(3)


• Continuous improvement

• reactive and proactive evaluation of facilities, equipment,documentation, procedures (audits and surveys)

• Evaluation of individual’s performance in terms of safetyresponsibilities

• Reactive evaluation of effectiveness of risk controls

• Emergency Response Plan

• Actions to be taken in case of an emergency

• Ensure orderly and safe transition from normal to emergencyoperation

• Need to co-ordinate with ERPs of other organisations whereappropriate

SAFETY RISK MANAGEMENT AMC1-ORO.GEN.200(a)(3) - continued


• one important element of the hazard identification process, improve the safety performance without attributing blame

• to identify instances where routine procedures have failed

• assessment of safety implications to determine need for action

• dissemination of relevant safety information stemming fromincidents and accidents

• allows reactive evaluation of effectiveness of risk controls


Internal Occurrence Reporting scheme


TRAINING AND COMMUNICATION ON SAFETY

• All personnel to receive safety training as relevant to their responsibilities

• Communication on safety matters:

• Raise awareness on safety management activities.

• Convey safety critical information on risks identified.

• Explain why actions are taken, why procedures are introducedor changed.



ORGANISATION MANAGEMENT SYSTEM DOCUMENTATION• General items to be covered (minimum required for all organisations)

• Statement by the accountable manager “organisation will continuouslywork in accordance with the applicable requirements and theorganisation’s documentation”

• Scope of activities

• Names of nominated post holders

• Organisation chart with lines of responsibility

• Procedures specifying how compliance with requirements is ensured(auditing)

• Management system documentation amendment procedure


Organisations may

adopt any title for this

document


SAFETY MANAGEMENT MANUAL

key instrument for communicating the approach to safety for thewhole of the organisation, to document all aspects of safetymanagement:

1. scope of safety management

2. safety policy and objectives

3. safety accountability of the accountable manager

4. safety responsibilities of key safety personnel

5. hazard identification and risk management schemes

6. safety action planning

7. safety performance monitoring

8. incident investigation and reporting

9. emergency response planning

10. management of change

11. safety promotion



ORGANISATION MANAGEMENT SYSTEM DOCUMENTATION

The information may be contained in any of the organisation manuals

• safety management manual,

• operations manual,

• training manual

• …

These manuals may also be combined, e.g. the SMM can be one chapter of the operations manual or the operations manual can be integrated with the SMM.


It is not required to duplicate

information in several manuals,

however the organisation must

be able to demonstrate that all

items are covered


Additional requirements are defined in the Subparts:

DOCUMENTATION – OPS

ORO.MLR – Manuals, Logs and Records

• ORO.MLR.100 Operations manual – General & related AMCs

• ORO.MLR.101 Operations manual – Structure & related AMCs


COMPLIANCE MONITORING FUNCTION Accountable manager to designate a compliance monitoring manager (CMM)

Functions of the CMM:

• verify that all applicable standards are complied with

• verify that the organisation’s own requirements (policies and procedures) are complied with

• ensure that a compliance monitoring programme is implemented and continually reviewed & improved


Organisations may

adopt a different

title for this function


COMPLIANCE MONITORING FUNCTION

Position of the CMM:

• direct access to the accountable manager

• not one of those nominated to be responsible for the operational areas (referred to in ORO.GEN.210(b))

• access to all parts of the organisation and as necessary, to contracted organisations


The same person may act as CMM

and SM (under certain conditions)

Non-complex ORG:

AM can be the CMM


COMPLIANCE MONITORING DOCUMENTATIONIntegrated with organisation’s management system documentation, to describe :

the allocation of CM duties and responsibilities (coordination & auditing)

procedures to monitor regulatory compliance

the compliance monitoring programme, reflecting

schedule of the monitoring programme;

audit procedures;

reporting procedures;

follow-up and corrective action procedures;

training on compliance monitoring;

recording system.


No fixed audit planning

cycles – according to

size of the organisation

and its complexity –

dynamic planning

(performance based)


Compliance monitoring shall also cover processes for the identificationof aviation safety hazards and management of associated risks.

� Are policies and procedures in place and adhered to?

� Are hazard identified, risks assessed and managed?

The verification of the effectiveness of the hazard identificationprocess and mitigation actions is within the remit of the safetymanagement function (safety manager – SRB – SAG)

� How effectively have risks been mitigated ?

� Has overall safety performance increased ?

Compliance Monitoring ./.

Safety Management

If the same person acts as SM

and CM, he/she cannot audit

any of the SM processes


• ESSI – (ECAST – EGAST – EHEST)

see for example: advanced methodology for operational riskassessment http://easa.europa.eu/essi/documents/Methodology.pdf

• SKYBRARY http://www.skybrary.aero/index.php/Main_Page

see for example:

Operators Guide to Human Factors in Aviation (OGHFA)

• ICAO Doc. 9859 “Safety Management Manual”

Edition 3 is about to be released

Additional guidance material


EASA Organisation Requirements & SMS KEY POINTS

SMS is addressed as part of “Organisation Requirements – Management System”

Organisation Requirements

• are compatible with existing management systems

• encourage integrated management

• provide proportionality (complex versus non-complex organisations)

• provide flexibility (details in AMC)

These Organisation Requirements set the standard for implementing SMS in the other areas within EASA’s remit.


What comes next?


Future Rulemaking on SMS

Task MDM.094 Safety Management

“First review of Organisation and Authority Requirements”

� consider latest developments:� ICAO Annex 19

� new SMM

� Safety Management International Collaboration Group (SM-ICG)*deliverables

� provide further guidance material, e.g. :� management systems for small (“non-complex”) organisations

� safety risk management

� measuring safety performance

* ICG: promotes a common understanding of SMS and SSP principles and requirements,

strives to harmonise SMS efforts, collaborates on common topics of interest, shareslessons learned, and ensures the progression of a harmonised SMS.


- fin -

Muchas gracias por suatención!

[email protected]

sms and the easa rules effective management systems for ... · pdf fileeffective management...

Documents