Need to establish Safety Management Systems (SMS) within Part-145 organizations

Linked to the objective of further improving the safety level of EASA Part-145 approved Maintenance Organizations (AMOs), the introduction of a new legal basis will introduce a management system for all MROs falling within the scope of Annex II of Regulation (EU) No 1321/2014 (Part-145, Maintenance Organizations). This aims to comply with
relevant International Civil Aviation Organization (ICAO) requirements, international standards and recommended practices in Annex 19 of the Chicago Convention. The safety risks introduced by the aviation industry must result in an Acceptable Level of Safety (ALoS). Acceptable means that a system as open and dynamic as commercial civil aviation is considered safe as long as safety risks and operational failures are kept within reasonable limits. In other words, safety risks and operational errors that are controlled to a reasonable degree are acceptable in an inherently safe system.
At the legislative level, the safety objectives to be achieved through essential requirements will be defined. These requirements have been developed to mitigate all probable risks associated with civil aviation activities within their scope. For this reason, EASA has adopted Commission Implementing Regulation (EU) 2021/1963, which will enter into force in December 2022. In addition, a Notice of Proposed Amendment (NPA) 2019-05 (C) and the Official Statement on the inclusion of SMS requirements in Annex II (Part-145) of Regulation (EU) No. 1321/2014 and in Annex I (Part-21) of Regulation (EU) No. 748/2012 were published as a source for the update of the implementing regulation and the decision to provide the required acceptable means of compliance (AMC) and guidance material (GM).
All AMOs being approved in accordance with Part 145 are required to establish an occurrence reporting system. Therefore, the provisions of Annex II of Regulation (EU) No. 1321/2014 have been amended to ensure that the occurrence reporting system is established as part of the organizations’ management system and that the requirements are consistent with those of Regulation (EU) No. 376/2014. The implementation of an SMS in an approved maintenance organization will not only improve safety, but will also lead to continuous improvement of operations and recurring common cause accidents will be essentially eliminated. This goal can only be achieved if AMOs move from a reactive to a proactive and predictive approach to safety risks.

Safety will be improved by following means:

  • Promotion of safety
  • Establishment and continuous development of safety strategies and
    objectives, linked to sufficient resources.
  • A systematic approach regarding the identification of potential hazards and a
    risk management system.
  • A system for ensuring safety, including consideration of safety performance.
    The core part of the management system framework (in accordance with 145.A.200)
    focuses on what is essential for safety management by imposing on the organization:
  • Clearly define responsibilities and accountabilities
  • Develop and establish a safety policy and associated safety objectives
  • Establish a safety reporting system following a just culture approach
  • Ensure the identification of aviation safety hazards associated with their
    activities, their assessment and the management of associated risks, including
    the adoption of mitigation measures and the systematic review of the
    effectiveness of the mitigation measures taken
  • Continuous compliance monitoring while taking into account additional
    requirements applicable to the organization
  • Documentation of all key management system processes
  • Personnel must be trained, competent, and knowledgeable about key safety
    issues

ASMS has many years of extensive experience in the establishment and ongoing development of Safety Management Systems (SMS) and is therefore happy to support you with comprehensive expertise as part of a service package tailored to your organization.

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