Gdansk International Air & Space
Law Conference
November 2013
Authority and Organisation Requirements
“effective management systems for authorities and
organisations”
John Vincent
Deputy Director for Strategic Safety
Introduction – ICAO Annex 19
SMS
(Service
Providers)
Safety
Oversight
(Authority)
State’s Safety Programme
(SSP)
Safety data collection, analysis and exchange
2
Introduction
European
Level
EASP
P = Programme or Plan
Two-way dialog
SSP 1
SSP 2
Two-way dialog
SMS 1
SMS 2
Two-way dialog
...
SMS n
SMS 1
SMS 2
State
Level
SSP n
...
Two-way dialog
...
SMS n
SMS 1
SMS 2
...
SMS n
Organisation
Level
ORGANISATIONS: Operators, Air Navigation Service Providers, Aerodromes, Maintenance, Design, Production, etc.
Safety Management is done at various levels.
ICF November 2013
3
EASA Rule structure – general approach
Implementing Rule
AR: Authority
Requirements
OR: Organisation
Requirements
SSP
Subpart GEN:
general
general
requirements
requirements
AMCs & GM
Subpart XXX:
Subpart XXX:
Specific, additional
requirements
Specific, additional
requirements
AMCs & GM
Requirements
SMS
Subpart GEN:
AMCs & GM
Technical
AMCs & GM
ICF November 2013
Subpart
ABC
AMCs & GM
Subpart
DEF
AMCs & GM
4
ARs & ORs: Regulatory references
access:
http://easa.europa.eu/regulations/regulations-structure.php
Implementing Rules
related AMCs & GM
amending Reg. (EU) No 290/2012 *
ARA: Decision 2012/006/R*
Subpart GEN
to Reg. (EU) 1178/2011
FCL – MED – CC – ARs & ORs for
Air Crew (FC & CC)
ORA: Decision 2012/007/R*
Subpart GEN
Regulation (EU) No 965/2012, as last
amended by Reg. 800/2013*
ARO: Decision 2012/016/R*
Subpart GEN
Air Operations
Commercial Air Transport,
ORO: Decision 2012/017/R *
Non-commercial CMPA
Non-commercial other than CMPA
Subpart GEN
* Subparts GEN of the Authority and Organisation Requirements respectively are fully aligned.
ICF November 2013
5
Authority Requirements
Implementing Rule
AR: Authority
Requirements
OR: Organisation
Requirements
SSP
Subpart GEN:
general
general
requirements
requirements
AMCs & GM
Subpart XXX:
Subpart XXX:
Specific, additional
requirements
Specific, additional
requirements
AMCs & GM
Requirements
SMS
Subpart GEN:
AMCs & GM
Technical
AMCs & GM
ICF November 2013
Subpart
ABC
AMCs & GM
Subpart
DEF
AMCs & GM
6
Authority Requirements & SSP
ARs do not explicitly refer to SSP
ARs support implementation of EASP/SSP, in particular by
focussing on the 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.
ICF November 2013
7
ARs supporting SSP implementation
dedicated Section: MANAGEMENT SYSTEM
ARX.GEN.200
Competent Authorities to establish management systems
including:
Internal audit & safety risk management
ARX.GEN.205
Procedures for allocation of tasks to qualified entities:
control of ‘contractors’
ARX.GEN.210
Management of changes in the management system and
information to the Agency
ARX.GEN.220
Record keeping requirements:
Storage, accessibility and traceability
Register of approved organisations
April 20
8
ARs supporting SSP implementation
OVERSIGHT, CERTIFICATION, ENFORCEMENT
ARX.GEN.300(c)
The scope of oversight shall consider safety priorities (as
per SSP – EASP)
ARX.GEN.300(d)
Oversight shall not be limited to the organisations the
authority has certified – link with safety priorities
ARX.GEN.300(e)
Authorities may agree to share audits when the activity
of an organisation involves more than one Member State
ARX.GEN.300 (c)
The 24-month oversight cycle to be extended (max: 48
months) or reduced depending on the safety performance
of the organisation
ARX.GEN.330
Changes to the organisation: The scope of changes not
requiring prior authority approval will depend on the
maturity of the organisation’s management system
April 20
9
OVERSIGHT: consider Risk & Performance
Prioritisation of
oversight
Significant Risks identified
Occurrences
April 20
Audit &
inspection
results
EASp
Etc…
10
OVERSIGHT: consider Risk & Performance
It is all about monitoring and
Significant Risks identified
managing safety
performance
Prioritisation of
oversight
Audit
programme
(frequency)
Inputs
(occurrences
etc…)
April 20
Audit
programme
(depth)
Mgt. of
changes
Safety performance/maturity of the organisation
11
Authority Requirements - Key points
Common, generally applicable requirements adopted for
Aircrew and Air Operations set the standard for other areas
Authority Requirements
•
•
•
•
mirror relevant organisation requirements
require a management system for competent authorities
support the implementation of EASP without explicitly regulating SSP
aim towards enhanced efficiency:
• optimal use of authority resources
• cooperation / exchange of information between authorities & with
the Agency
• risk & performance based oversight
Existing rules will be aligned with these Part-ARX
requirements
ICF November 2013
12
Organisation Requirements
Implementing Rule
AR: Authority
Requirements
OR: Organisation
Requirements
SSP
Subpart GEN:
general
general
requirements
requirements
AMCs & GM
Subpart XXX:
Subpart XXX:
Specific, additional
requirements
Specific, additional
requirements
AMCs & GM
Requirements
SMS
Subpart GEN:
AMCs & GM
Technical
AMCs & GM
ICF November 2013
Subpart
ABC
AMCs & GM
Subpart
DEF
AMCs & GM
13
SMS ./. Management system
There is no requirement to implement an SMS, but a
requirement to implement a
management system
with specific features.
This is aligned with the essential requirements of the
Basic Regulation
(see Annex I Art. 3.a.2).
‘The organisation must implement and maintain a
management system to ensure compliance …
and aim for continuous improvement of the
system.’
Existing management systems within the scope of
Reg. (EC) 2042/2003 mainly focus on compliance
(quality system)
ICF November 2013
14
Organisation Requirements - SMS
EASA approach – main features
Total system approach
•Same general management system features for all approved
organisations, with the same core requirements
Integrated approach
•A holistic approach to management will result in more effective
operations and safety management.
Proportionality
•The management system shall correspond to the size, nature
and complexity of the organisation.
Flexibility
•Allow the use of alternative means of compliance by placing
implementation aspects at AMC level.
Authority and Organisation Requirements
ICF November 2013
15
Existing management system & SMS
Safety Risk
Management
Safety
Assurance
Safety Policy
and
Objectives
Human
Resources
SMS
Facilities
Documentatio
n & records
Compliance
monitoring
Safety
Promotion
Contracting
Management
System
Finance &
Budget
ICF November 2013
16
ICF November 2013
Contracting
Facilities
Safety Promotion &
Training
Human Resources
Doc. & records
Safety Assurance
Compliance monitoring
Safety risk management
Safety policy and
objectives
Finance & Budget
Integrated approach to management
Management System
17
Part-ORX Subpart GEN
Section II “Management System”
Paragraph
Title
ORX.GEN.200
Management system
ORX.GEN.205
Contracted activities
ORX.GEN.210
Personnel requirements
ORX.GEN.215
Facility requirements
ORX.GEN.220
Record-keeping
ICF November 2013
18
Management System requirements
core elements
clearly defined lines of responsibility and accountability
safety policy
identification of aviation safety hazards
evaluation and the management of associated risks,
mitigate the risk and verify effectiveness;
maintaining personnel trained and competent
management system documentation
“The management system shall correspond to the size of the organisation and
the nature and complexity of its activities, taking into account the hazards and
associated risks inherent in these activities.”
ICF November 2013
19
From ‘Quality system’ to ‘Management system’:
Some new obligations for the organisation:
(1)
Review the safety policy to ensure it addresses all new elements related to safety
management.
(2)
Identify a person who will fulfil the role of safety manager
(3)
Establish a Safety Review Board (complex organisations)
(4)
Implement the new safety management processes:
•
hazard identification,
•
risk assessment and mitigation,
•
performance monitoring, etc….
(5)
Document the new safety management processes.
(6)
Extend the scope of internal auditing to the new processes.
(7)
Keep records of the output of those new processes.
(8)
Plan for emergencies « Emergency Response Planning ».
ICF November 2013
20
Organisation Requirements - Key points
SMS is addressed as part of the Section A Organisation Requirements
in a dedicated rule § ‘Management System’ and related AMCs/GM.
These organisation requirements:
•build upon the existing quality system provisions
•address all elements of the ICAO SMS framework
•are compatible with existing management systems
They ‘set the standard” for implementing SMS in the other areas within the
Agency’s remit.
•total system approach
•encourage integrated management
•provide flexibility & proportionality
ICF November 2013
21
Thank you for your
attention!
Questions?