AMC1 145.A.200(a)(3) Management system

CAA ORS9 Decision No. 38

SAFETY MANAGEMENT KEY PROCESSES

(a) Hazard identification processes

(1) A reporting scheme should be the formal means of collecting, recording, analysing, acting on, and generating feedback about hazards, events and the associated risks that may affect safety.

(2) The hazards identification should include in particular:

(i) hazards that may be linked to human factors issues that affect human performance; and

(ii) hazards that may stem from the organisational set-up or the existence of complex operational and maintenance arrangements (such as when multiple organisations are contracted, or when multiple levels of contracting/subcontracting are included).

(b) Risk management processes

(1) A formal safety risk management process should be developed and maintained that ensures reactive, proactive and predictive approach composed by:

(i) analysis (e.g. in terms of the probability and severity of the consequences of hazards and occurrences);

(ii) assessment (in terms of tolerability);

(iii) control (in terms of mitigation) of risks to an acceptable level.

Note: The severity of the consequence should be evaluated to the best knowledge and engineering judgement of the organisation, and this evaluation may require collecting information from the CAA, incident/accident investigation reports, the design approval holder, etc.

(2) The levels of management who have the authority to make decisions regarding the tolerability of safety risks, in accordance with (b)(1)(ii), should be specified.

(c) Internal investigation

(1) In line with its just culture policy, the organisation should define how to investigate incidents such as errors or near misses, in order to understand not only what happened, but also how it happened, to prevent or reduce the probability and/or consequence of future recurrences (refer to AMC1 145.A.202). This approach should avoid concentrating the analysis on who was directly or indirectly concerned by the events.

(2) The scope of internal investigations should extend beyond the scope of the occurrences required to be reported to the CAA in accordance with point 145.A.60, to include the reports referred to in 145.A.202(b).

(d) Safety performance monitoring and measurement

(1) Safety performance monitoring and measurement should be the processes by which the safety performance of the organisation is verified in comparison with the safety policy and the safety objectives.

(2) These processes may include, as appropriate to the size, nature and complexity of the organisation:

(i) safety reporting, which may also address the status of compliance with the applicable requirements;

(ii) safety reviews, including trend reviews, which would be conducted during the

(iii) safety audits that focus on the integrity of the organisation’s management system, and on periodically assessing the status of safety risk controls;

(iv) safety surveys, examining particular elements or procedures in a specific area, such as identified problem areas, or bottlenecks in daily maintenance activities, perceptions and opinions of maintenance management personnel, and areas of dissent or confusion; and

(v) other indicators relevant to safety performance, which may be generated by automated means.

(e) Management of change

Changes may introduce new hazards or threaten existing safety risk controls. The management of change should be a documented process established by the organisation to identify external and internal changes that may have an adverse effect on the safety of its maintenance activities.

It should make use of the organisation’s existing hazard identification, risk assessment and mitigation processes.

(f) Continuous improvement

The organisation should continuously seek to improve its safety performance and the effectiveness of its management system. Continuous improvement may be achieved through:

(1) audits carried out by external organisations;

(2) assessments, including assessments of the effectiveness of the safety culture and management system, in particular to assess the effectiveness of the safety risk management processes;

(3) staff surveys, including cultural surveys, that can provide useful feedback on how engaged personnel are with the management system;

(4) monitoring the recurrence of incidents and occurrences;

(5) evaluation of safety performance indicators and reviews of all the available safety performance information; and

(6) the identification of lessons learned.

(g) Immediate safety action and coordination with the operator’s Emergency Response Plan (ERP)

(1) Procedures should be implemented that enable the organisation to act promptly when it identifies safety concerns with the potential to have an immediate effect on flight safety, including clear instructions on who to contact at the owner/operator/CAMO, and how to contact them, including outside of normal business hours. These provisions are without prejudice to the occurrence reporting required by point 145.A.60.

(2) If applicable, procedures should be implemented to enable the organisation to react promptly if the ERP is triggered by the operator and it requires the support of the Part-145 organisation.