EHSIT/ST meeting Marignane, 27 & 28 October 2011
The future EASA rules on Management Systems
Régine HamelijnckRulemaking Officer – Product Safety
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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Outline
Introduction
• rule structure
• current status
The EASA approach
• main features
The draft rule
• ORO.GEN.200
• AMCs & GMs
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
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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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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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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.
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)
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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
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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
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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)
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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)
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12
Organisation Requirements & SMSthe EASA approach
Total system approach
Integrated approach
Proportionality & flexibility
Management System28 Oct. 2011
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
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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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
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.
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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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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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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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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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
• 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)
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AMC1-ORO.GEN.200(a)(1)(2)(3)(5)
Management System
• 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)
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AMC1-ORO.GEN.200(a)(1)(2)(3)(5)
Management System
proportionate means of
compliance for non-complex
organisations
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.
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ORO.GEN.200 (extract)
Management System
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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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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
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
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.
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GM1-ORO.GEN.200(a)(2)
Management System
starting point
for the
organisation’s
MS
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.
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AMC1-ORO.GEN.200(a)(2)
Management System
Organisation
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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)
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.
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Safety Manager AMC1-ORO.GEN.200(a)(1)
Management System
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.
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Safety Review BoardAMC1-ORO.GEN.200(a)(1)
Management System
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
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Safety Action GroupGM1-OR.GEN.200(a)(1)
Management System
• 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
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SAFETY RISK MANAGEMENT AMC1-ORO.GEN.200(a)(3)
Management System
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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
• 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
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SAFETY RISK MANAGEMENT AMC1-ORO.GEN.200(a)(3)
Management System
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
• 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
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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
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
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AMC1-ORO.GEN.200(a)(4)
Management System
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
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AMC1-ORO.GEN.200(a)(5)
Management System
Organisations may
adopt any title for
this document
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
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.
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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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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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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
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
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
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
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)
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
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
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 ?
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Compliance & safety management
Management System
If the same person acts as
SM and CM, he/she cannot
audit SM processes
� 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.
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
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
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Safety management implementation
Challenges
Management System
What comes next?
28 Oct. 2011 54
SMS
Management System
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
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
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
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 !