SMS being migrated by CAAs to all sectors
EASA proposes to bring Repair Stations to the regimen
Good data on Benefits and Costs
The business of aviation safety regulation holds many of the same responsibilities. Yes, some of the requirements assessed on air carriers in a tropical environment may vary from operations conducted in a more arid climate. As to processes, methods of seeking adherence to safety standards, the transnational lessons may be more apparent and meaningful.
Here is a prime example of learning from a peer Civil Aviation Authorities (CAAs). ICAO has set a global goal for implementing Safety Management Systems (SMS). The FAA, EASA, Transport Canada, ANAC, Japan CAB, etc. are all working diligently to include SMS in all regulated sectors. It appears that the experiences of other CAAs may provide valuable insights to their colleague CAAs.
In the below rulemaking, which appears to have been initiated three years ago, EASA did a very through job of assessing the impact of Safety Management Systems (SMS) on its Part 145 operators (MROs). Here are quotes about the process:
For the preparation of the related regulatory impact assessment (RIA) for RMT.0251 Phase II, EASA conducted a survey which was addressed to competent authorities and industry. The aim of the survey was to gather evidence to support the impact assessment and applicability of the safety management system (SMS), and to identify the cases where proportionality is needed, as well as to collect data on potential impacts, difficulties/challenges and opportunities as regards the implementation of SMS.
Following the survey, a Focus Consultation Group (FCG) was established that comprised subject matter experts from industry and national aviation authorities (NAAs) who were asked to provide advice to EASA on the preparation of the related notice of proposed amendment (NPA 2015-09 (A)(B)(C) ‘Embodiment of safety management system (SMS) requirements into Part-145 and Part 21’ 5 ) as well as on the preparation of the proposed amendments that are presented in this Opinion.
2 651 comments were received from interested parties, including industry, NAAs, and social partners.
That process resulted in some data which may be of value to the FAA as it moves forward in its effort to disseminate the gospel of SMS to repair stations and airports
The bars on this chart (“better safety culture”, “better hazard identification leading to better risk control”, etc.) confirm that the SMS regimen can and does benefit safety. The most common complaint about this new discipline focuses on costs of administering the program
And here is where these numbers drove proportionality:
The proportionality approach limits the economic impact as implementation costs are reduced by the following:
— The acceptance that the management system shall correspond to the size of the organisation, as well as to the nature and complexity of its activities, taking into account the hazards and associated risks that are inherent to them;
— AMC and GM related to SMS shall be developed, proportionate to the size and complexity of the organisation’s activities (e.g. a full-time equivalent (FTE) safety manager is not necessary as long as the ‘safety manager’ function is properly discharged; the same applies for a formal safety review board);
— It is planned to recognise an industry association ‘international SMS industry standard’ via an AMC to the SMS requirements for design and production organisations, which will allow for a level playing field with the SMS approach followed by other major authorities such as the FAA, the TCCA or ANAC because that international SMS industry standard will be also recognised by these major authorities. The implementation costs could be further reduced by encouraging the implementation of common tools and data-sharing agreements for safety management at the level of industry associations; and
— By reducing the complexity and the volume of changes, an organisation may decide to build its SMS on its existing exposition manual, or to produce a separate SMS manual, which limits the impact on the organisation’s documentation.
Interesting data and observations which the FAA might consider plagiarizing?
– January 6, 2021, 8:34 AM
Following up on a notice of proposed amendment (NPA) published for comment last year, the European Union Aviation Safety Agency (EASA) issued an official regulatory opinion with its plan to adopt regulations requiring certain Part 145 repair stations to have safety management systems (SMS). The rules would apply to maintenance organizations that maintain airliners and turbine business aircraft.
The final rules are slightly revised, based on EASA’s consideration of some 2,650 comments submitted in response to the NPA this summer. To limit the impact on small Part 145 facilities, the application of SMS provisions would be commensurate with the size of the organization and the complexity of the operations.
Some respondents, mainly from the U.S. (where repair station SMS is currently applicable only on a voluntary basis), would have liked to see SMS not mandatory and are concerned about its impact on bilateral agreements. The agency expressed disappointment that “A significant number of comments did not address the safety management principles although this was the very essence of this rulemaking project.”
Compliance would be required within one year after the date the final rule is published.
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