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EHSIT/ST meeting Marignane, 27 & 28 October 2011 The future EASA rules on Management Systems Régine Hamelijnck Rulemaking Officer – Product Safety

EASA ORO SMS - TRACECA€¦ · EASA Rulemaking tasks: ... ADR Rule structure –the big picture 28 Oct. 2011 4 ADR: Aerodromes ATCO: licensing and medical certification of air traffic

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Page 1: EASA ORO SMS - TRACECA€¦ · EASA Rulemaking tasks: ... ADR Rule structure –the big picture 28 Oct. 2011 4 ADR: Aerodromes ATCO: licensing and medical certification of air traffic

EHSIT/ST meeting Marignane, 27 & 28 October 2011

The future EASA rules on Management Systems

Régine HamelijnckRulemaking Officer – Product Safety

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28 Oct. 2011 2

History

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 air crew (Flight Crew Licensing)

• Passed EASA Committee – Regulation expected March 2012

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 Summer 2012

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

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28 Oct. 2011 3

Outline

Introduction

• rule structure

• current status

The EASA approach

• main features

The draft rule

• ORO.GEN.200

• AMCs & GMs

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Basic Regulation

Airworthiness

Regulation

Initial airworthiness

Regulation

Continuing airworthiness

Flight Standards

Regulation

Air crew

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

28 Oct. 2011 4

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

First

extension

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28 Oct. 2011 5

Rule structure Air Operations

Regulation

Air operations

Annex I

DEF

Annex II

Part-ARO

.GEN

.OPS

.RAMP

Annex III

Part-ORO

.GEN

.AOC

.DEC

.MLR

.SEC

.FC

.CC

.TC

.FTL

Annex IV

Part-CAT

.GEN

.OP

.POL

.IDE

Annex V

Part-SPA

.GEN

.PBN

.MNPS

.RVSM

.LVO

.ETOPS

.DG

.NVIS

.HHO

.HEMS

Annex VI

Part-NCC

.GEN

.OP

.POL

.IDE

Annex VII

Part-NCO

.GEN

.OP

.POL

.IDE

Annex VIII

Part-SPO

.GEN

.OP

.POL

.IDE

.SPEC

Aligned with Air Crew

Opinion

not yet published

SPA: specific Approvals (ETOPS, PBN etc…)

SPO: specialised Operations (aerial work)

NCC: non-commercial with CMPA

NCO: non commercial other than CMPA

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28 Oct. 2011 6

Transition measures

The European Commission is currently negotiating the different

transition measures with Member States. The above information is

therefore to be considered PROVISIONAL:

• implementation of JAR-OPS 3 with varying degrees of compliance

• conversion procedure is foreseen for CAT helicopter AOCs issued before the new

rules will apply

• no opt-out from the new rules.

• Conversion process starts from date of entry into force of the OPS-CAT Regulation.

• Regulation does not set a deadline for completion of the conversion process (at the

discretion of each Member State)

Competent authorities to prepare a conversion report indicating among other things

how and when the holders of CAT helicopter AOCs under their regulatory control will be

required to move to full compliance with of Parts ORO, CAT and, if applicable, SPA.

The conversion report shall be established in consultation with the Agency.

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Organisation Requirements: GEN & OPS

7

• ORO.GEN contains the general provisions that are applicable to all

approved organisations (Operators, ATOs, AeMCs, )

• Section 1: GENERAL

• Section 2: MANAGEMENT SYSTEM

• These are complemented with OPS specific provisions

• ORO.AOC

• ORO.DEC (non-commercial with CMPA)

• ORO.MLR

• ORO.SEC

• ORO.FC/CC/TC

• ORO.FTL (still in progress – task OPS.055)

28 Oct. 2011

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8

Part-ORO GEN Sec.1 - corresponding ARs

Management System

Ref. Part-OR Title Corresponding AR

ORO.GEN.115 Application for an organisation certificate

ARO.GEN.310(a)

ORO.GEN.120 Means of compliance ARO.GEN.120

ORO.GEN.125 Terms of approval and privileges of an organisation

ARO.GEN.310(b)

ORO.GEN.130 Changes to organisations ARO.GEN.330

ORO.GEN.135 Continued validity ARO.GEN.310(b)

ORO.GEN.140 Access ARO.GEN.350

ORO.GEN.150 Findings ARO.GEN.350

ORO.GEN.155 Immediate reaction to a safety problem

ARO.GEN.135

ORO.GEN.160 Occurrence reporting ARO.GEN.135

28 Oct. 2011

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9

Part-ORO Subpart GEN Section 2

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

Management System28 Oct. 2011

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10

Organisation Requirements & SMS

• ORs do not explicitly refer to SMS. Section 2 of Part-ORO

Subpart GEN deals with “management system”.

• ORO.GEN Sec. 2 and related AMCs/GM set out what is

needed in terms of management system. These, together

with the relevant provisions of the Basic Regulation, provide

for compliance with the relevant ICAO SARPS on SMS.

See Annex III to the Explanatory Note to

the CRD Part-OR

Safety Management Requirements for

organisations - Comparison between the

ICAO standards and Part-OR & Basic

Regulation (Essential requirements)

28 Oct. 2011 Management System

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11

Organisation Requirements & Safety Management

Who will be required to implement a management system as

defined in ORX.GEN.200?

• First extension (Air Crew and Air Operations) :

• Air Operators: commercial and non-commercial if operating complex motor-

powered aircraft (CMPA)

• Approved Training Organisations - Pilots

• Holders of an FSTD qualification certificate

• Aero-medical Centres

• In a second stage (Airworthiness - RM tasks MDM.055 and MDM.060):

• Design organisations and Production organisations (Part-21)

• Maintenance organisations (Part-M Subpart F and Part-145)

• Continuing Airworthiness Management Organisations (Part-M Subpart G)

• Maintenance Training Organisations (Part-147)

28 Oct. 2011 Management System

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12

Organisation Requirements & SMSthe EASA approach

Total system approach

Integrated approach

Proportionality & flexibility

Management System28 Oct. 2011

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EASA remit: towards a total system

13

Current remit

•Initial airworthiness & environmental(Regulation 1702/2003)

•Continuing airworthiness (Regulation 2042/2003)

First extension

•Flight crew licensing

•Cabin crew

•Medical

•Air Operations

•Third Country Operators

Second extension

•Air Traffic Management

•Air navigation Services

•Aerodromes

Management System28 Oct. 2011

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EASA remit: towards a total system

14

Current remit

•Initial airworthiness & environmental(Regulation 1702/2003)

•Continuing airworthiness (Regulation 2042/2003)

First extension

•Flight crew licensing

•Cabin crew

•Medical

•Air Operations

•Third Country Operators

Second extension

•Air Traffic Management

•Air navigation Services

•AerodromesEASA total aviation system approach:

common logic & semantics of rules

Management System28 Oct. 2011

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15

Total system approach in terms of SMS

Facilitate streamlined implementation of the ICAO standards, in particular for organisations holding

approvals in different areas

Facilitate the identification of hazards stemming from the interactions between service providers

Ensure all service providers « speak the same language » when it comes to safety management

Management System28 Oct. 2011

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Integrated approach

16

Management System

Safety management

Compliance monitoring

Responsibilities & Accountability

Human Resources

Facilities

Contracting

Finance & Budget

Management System28 Oct. 2011

Integrated management shall

enable managers to

recognise and take into

account all significant

influences on their

organisation.

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Integrated approach

17

Management System

Safety management

Compliance monitoring

Responsibilities & Accountability

Human Resources

Facilities

Contracting

Finance & Budget

Management System28 Oct. 2011

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18

Integrated approach

Safety, as well as compliance with rules, should be a concern for all personnel and for all activities of an organisation.

Safety management should include every facet of management that may impact aviation safety

(financial, operational, health and safety, etc…).

SMS should not be implemented through an additional management system requirement superimposed onto the existing rules, but be fully integrated in the organisation’s

existing management system.

Management System28 Oct. 2011

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28 Oct. 2011 19

Flexibility

Management System

Principles of performance-based rules

• Essential safety elements are defined at the level of implementingrules, non-essential implementation aspects are included as AMC.

• Details of safety management implementation are defined in formof AMCs – this opens the possibility to apply for an alternativemeans of compliance (i.a.w. ORO.GEN.120).

• Performance based rules are necessary to ensure that safetymanagement may deploy its full potential: The organisationshould be allowed flexibility to implement specific means tomitigate safety risks as it sees fit.

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28 Oct. 2011 20

Proportionality

How is this achieved?

different sets of AMCs for “complex” and “non-complex”

organisations

details of SMS implementation are included as AMC

(altMOC possible)

The management system shall correspond to the size of the organisation and the complexity of its activities, taking into account the hazards and associated risks inherent in these

activities.

(see also ICAO Annex 6 Appendix 7)

Management System

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28 Oct. 2011 21

Proportionality

Definition of organisational complexity - three sets of criteria :

Size, in terms of staffing

Complexity of the activitiesnumber of operating sites,

number and type of contractors,

Risks involved type of operations, e.g. specialised operations (helicopter hoist)

type of aircraft, variety of aircraft types operated

operating environment (mountainous areas, offshore ….)

Some organisations are non-complex by default Cf. AMC1-ORO.GEN.200(b)

Management System

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• Possibility to use hazard checklists for safety, integrated intothe activities of the organisation

• Management of safety risks related to a change

• Safety manager to be identified, may be the accountablemanager or other operational person within the organisation

• Responsibilities need to be identified for hazardidentification, risk assessment and mitigation

• Safety policy to include a commitment to improve safetyand to comply with requirements

• Organisation to develop & maintain an Emergency Responseplan (ERP)

28 Oct. 2011 22

AMC1-ORO.GEN.200(a)(1)(2)(3)(5)

Management System

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• Possibility to use hazard checklists for safety, integrated intothe activities of the organisation

• Management of safety risks related to a change

• Safety manager to be identified, may be the accountablemanager or other operational person within the organisation

• Responsibilities need to be identified for hazardidentification, risk assessment and mitigation

• Safety policy to include a commitment to improve safetyand to comply with requirements

• Organisation to develop & maintain an Emergency Responseplan (ERP)

28 Oct. 2011 23

AMC1-ORO.GEN.200(a)(1)(2)(3)(5)

Management System

proportionate means of

compliance for non-complex

organisations

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An organisation 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 activities ofthe organisation, their evaluation and the management of associatedrisks, including taking effective actions to mitigate the risk;

(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 effective implementationof corrective actions as necessary.

28 Oct. 2011 24

ORO.GEN.200 (extract)

Management System

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28 Oct. 2011 25

Overview of 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 (OPTIONAL - to assist the SRB)

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

Management System

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28 Oct. 2011 26

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)

GM1-ORO.GEN.200(a)(5) allDevelopment of new / amendment of Standard Operating Procedures

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 - Inspection 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

Management System

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Management System building blocks

28 Oct. 2011 27

Safety Policy

Responsibilities &

accountabilities

Hazard identification & risk management

Training and communication

Documentation

Monitoring

(compliance & performance)

system &

process analysis

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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.

28 Oct. 2011 28

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

Management System

starting point

for the

organisation’s

MS

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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.

28 Oct. 2011 29

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

Management System

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Organisation

28 Oct. 2011 30

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

Management System

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)

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Functions of the safety manager:1. facilitate 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.

28 Oct. 2011 31

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

Management System

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high level committee, chaired by the AM - considersmatters of strategic safety & ensure appropriateresources are allocated to achieve safety objectives

Main functions of the SRB:

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

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

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

28 Oct. 2011 32

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

Management System

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optional

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

• 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

28 Oct. 2011 33

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

Management System

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• Hazard identification processes

• reactive : incidents and accidents

• proactive : intrinsic threats and potential failures

• 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, safetysurveys.

• Management of change

• Identify changes that may adversely affect safety

• Use existing tools and mechanisms to assess and manage related risks

28 Oct. 2011 34

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

Management System

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28 Oct. 2011 35

RISK ASSESSMENT GUIDANCEGM2-ORO.GEN.200(a)(5)

Management System

Planning (what, when how, who)

Analysis of causes/contribu-ting factors

& probability

Analysis of consequences

Risk description (severity/probability)

Risk evaluation (acceptability/

mitigation)

Conclusion (for decision-making &

prioritising)

Risk mitigation

Documentation (records –

procedures to be amended)

Monitoring & Review

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• Continuous improvement

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

• Evaluation of individual’s performance in terms of safety responsibilities

• 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 emergency operation

• Need to co-ordinate with ERPs of other organisations where appropriate

28 Oct. 2011 36

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

Management System

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Some recommendations

Adopt a phased approach: start with a basic outline and addsophistication as your management system matures

e.g. start with process indicators first, then outcome indicators

Make use of existing templates, guidance, tools

BUT: adapt them to your organisation (complexity – specificity)

e.g.:

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

also has an Operators Guide to Human Factors in Aviation (OGHFA)

• ESSI – (ECAST – EGAST – EHEST) lots of guidance, including advancedmethodology for operational risk assessment

http://easa.europa.eu/essi/documents/Methodology.pdf

ICAO SMM:

Note that ICAO is currently reviewing the manual; do not rely on it tooextensively.

28 Oct. 2011 37

SAFETY RISK MANAGEMENT

Management System

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• 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 information regarding relevant incidents and accidents

• reactive evaluation of effectiveness of risk controls

• All reports to be retained, as significance may only become obvious at a laterstage

28 Oct. 2011 38

GM1-ORO.GEN.200(a)(3)

Internal Occurrence Reporting scheme

Management System

Example of occurrence :

Temporary exceedance of aircraft operating

limitations /flight envelope during a training

flight

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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 introduced or changed

• Communication - How?

Possible options:

• Regular meetings with personnel where information, actions and procedures arediscussed

• Safety newsletters

28 Oct. 2011 39

AMC1-ORO.GEN.200(a)(4)

Management System

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ORGANISATION MANAGEMENT SYSTEM DOCUMENTATION

• General items to be covered (minimum required for all organisations)

• Statement by the accountable manager “organisation will continuously work inaccordance with the applicable requirements and the organisation’sdocumentation”

• 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

28 Oct. 2011 40

AMC1-ORO.GEN.200(a)(5)

Management System

Organisations may

adopt any title for

this document

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SAFETY MANAGEMENT MANUAL complex organisations

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

28 Oct. 2011 41

AMC1-ORO.GEN.200(a)(5)-Complex

Management System

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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.

28 Oct. 2011 42

GM1-ORO.GEN.200(a)(5)

Management System

It is not required to duplicate

information in several manuals,

however the organisation must

be able to demonstrate that all

items are covered

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28 Oct. 2011 43

SAFETY MANAGEMENT MANUAL

Management System

Some recommendations (1/2)

• Ensure uniformity in terminology used • staff – personnel – employee

• manager - post-holder

• forerunner event – precursor event

• likelihood – probability

• gravity - severity

• Provide definitions in a separate section

• Keep forms separate to minimise need for updates

• Simplify manual administration (e-version, may be printed but only the master copy is to serve as reference)

• Limit the use of jargon, avoid proliferation of advanced SMS terminology or models

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28 Oct. 2011 44

SAFETY MANAGEMENT MANUAL

Management System

Some recommendations (2/2)

• Clearly describe the management system key processes and how they interface with each other and with your operational processes (process mapping)• Hazard identification

• Safety risk management

• Safety performance measurement

• Compliance monitoring

• Documentation

• Etc…

• Do not mix up conceptual information with the description of the organisation and its safety management processes

• Do not duplicate the ICAO SMM – describe how SM works in your organisation

• Check other manuals / procedures to be updated to consider SM

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Additional requirements on the operational elements are defined in:

28 Oct. 2011 45

DOCUMENTATION – OPS

Management System

ORO.MLR – Manuals, Logs and Records

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

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

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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

28 Oct. 2011 46

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

Management System

Organisations may

adopt a different

title for this function

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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))

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

28 Oct. 2011 47

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

Management System

The same person may act as CMM

and SMM (BUT: need to ensure

independent audits)

Non-complex ORG: AM can be

the CMM

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

the allocation of duties and responsibilities (coordination & auditing)

procedures to ensure regulatory compliance

the compliance monitoring programme, reflectingschedule of the monitoring programme;

audit procedures;

reporting procedures;

follow-up and corrective action procedures;

training on compliance monitoring ;

recording system.

28 Oct. 2011 48

AMC1-ORA.GEN.200(a)(6)

Management System

No fixed audit

planning cycles –

according to size of the

organisation and its

complexity – dynamic

planning (performance

based)

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OPS COMPLIANCE MONITORING PROGRAMMEcomplex organisations

Typical subject areas for compliance monitoring inspections:actual flight operations;

ground de-icing/anti-icing;

flight support services;

load control; and

technical standards.

Operators should monitor compliance with the operational procedures they have designed to ensure safe operations. In doing so, they should, where appropriate, additionally monitor:

operational procedures;

flight safety procedures;

operational control and supervision;

aircraft performance;

all weather operations;

communications and navigational equipment and practices;

mass, balance and aircraft loading;

Etc. ……

28 Oct. 2011 49

GM1-ORO.GEN.200(a)(6)

Management System

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Without compliance no effective safety management, but compliance alone does not mean the organisation is safe.

28 Oct. 2011 50

Compliance & safety management

Management System

•Safety performance

Policies, objectives hazard identification and risk management

•Compliance

Compliance monitoring and effective

implementation of corrective actions

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Compliance monitoring shall also look into the requirements onidentification of aviation safety hazards and management ofassociated risks.

� Are policies and procedures in place and adhered to?

� Are hazard identified and risks assessed ?

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 ?

28 Oct. 2011 51

Compliance & safety management

Management System

If the same person acts as

SM and CM, he/she cannot

audit SM processes

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� QMS and SMS may use the same tools and techniques� e.g. performance monitoring – KPIs

� management of business risks

� process analysis

� auditing

� an effective QMS will clearly support the implementation of an effective safety management

BUT

� Processes designed to produce a quality product/service will notguarantee a safe product.

More on this topic:

Steven C. McNeely, Manager, Safety Management Systems, Jet Solutions, L.L.C, publishedby "Flight Safety Information February 12, 2010 No.034", Lessons Learned from Toyota –2010-QMS vs SMS (FAA website).

28 Oct. 2011 52

QMS and SMS

Management System

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Culture

• takes time to change

• how to influence contractors?

• how to get buy-in from non-operational areas?

• how to measure safety culture?

Commercial environment

• competitive environment (protection versus production)

• return on SM investment may take time

Oversight (CAA) & monitoring the application of rules (EASA)

• how to assess safety performance?

• “just culture” in oversight

28 Oct. 2011 53

Safety management implementation

Challenges

Management System

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What comes next?

28 Oct. 2011 54

SMS

Management System

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28 Oct. 2011 55

Future Rulemaking on SM

Task MDM.094 Safety Management

“Review of Part-ORX and Part-ARX following publication of ICAO Annex 19”

• consider latest developments at ICAO and SM-International Collaboration Group (SM-ICG)

• provide further guidance on:

• the management of safety risks stemming from interactions withother organisations

• safety performance monitoring & measurement

Management System

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28 Oct. 2011 56

KEY POINTS: Organisation Requirements & SM

SM is addressed in Organisation Requirements “Part-ORO” – Subpart GEN Section 2 “Management”

Organisation Requirements

are ICAO SMS compliant

are compatible with existing management systems

encourage integrated management

provide flexibility (details in AMC)

provide proportionality (complex versus non-complex organisations)

Part-ORO Management system requirements set thestandard for implementing SM in other areas withinEASA’s remit not yet addressing SM.

Management System

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28 Oct. 2011 57

KEY POINTS: Enablers to effective SM

Leadership (actions speak louder than words)

Integration into day-to-day business

System approach identifying, understanding and managing interrelated processes as a system

Ability to transform data into safety information for management

Safety culture covering the full rangeFlexible culture

Just culture

Learning culture

Informed culture

Reporting culture

Management System

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28 Oct. 2011 58

KEY POINTS: Enablers to effective SM

Leadership (actions speak louder than words)

Integration into day-to-day business

System approach identifying, understanding and managing interrelated processes as a system

Ability to transform data into safety information for management

Safety culture covering the full rangeFlexible culture

Just culture

Learning culture

Informed culture

Reporting culture

Management System

There is no

no standard

formula !

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- end of presentation -

Thank you for your attention!

[email protected]