GM1 145.A.200 Management system

CAA ORS9 Decision No. 38

GENERAL

Safety management seeks to proactively identify hazards and to mitigate the related safety risks before they result in aviation accidents and incidents. Safety management enables an organisation to manage its activities in a more systematic and focused manner. When an organisation has a clear understanding of its role and contribution to aviation safety, it can prioritise safety risks and more effectively manage their resources and obtain optimal results.

The principles of the requirements in points 145.A.200, 145.A.202, 145.A.205 and the related AMC constitute the UK management system framework for aviation safety management. This framework addresses the core elements of the ICAO safety management system (SMS) framework defined in Appendix 2 to Annex 19, includes the elements of the compliance monitoring system, and promotes an integrated approach to the management of an organisation. It facilitates the introduction of the additional safety management components, building upon the existing management system, rather than adding them as a separate framework.

This approach is intended to encourage organisations to embed safety management and risk-based decision-making into all their activities, instead of superimposing another system onto their existing management system and governance structure. In addition, if the organisation holds multiple organisation certificates within the scope of Regulation (EU) 2018/1139, it may choose to implement a single management system to cover all of its activities. An integrated management system may not only be used to capture management system requirements resulting from Regulation (EU) 2018/1139, but also could cover other regulatory frameworks requiring compliance with Annex 19 or other business management systems such as security, occupational health and environmental management systems. Integration will remove any duplication and exploit synergies by managing safety risks across multiple activities. Organisations may determine the best means to structure their management systems to suit their business and organisational needs.

The core part of the management system framework (145.A.200) focuses on what is essential to manage safety, by mandating the organisation to:

(a) clearly define accountabilities and responsibilities;

(b) establish a safety policy and the related safety objectives;

(c) implement safety reporting procedures in line with just culture principles;

(d) ensure the identification of aviation safety hazards entailed by its activities, ensure their evaluation, and the management of the associated risks, including:

(1) taking actions to mitigate the risks;

(2) verifying the effectiveness of the actions taken to mitigate the risks;

(e) monitor compliance, while considering any additional requirements that are applicable to the organisation;

(f) keep their personnel trained, competent, and informed about significant safety issues; and

(g) document all the key management system processes.

Compared with the previous Part-145 quality system ‘framework’ (now covered by point (b) and (e)), the new elements that are introduced by the management system are, in particular, those addressed under points (c) and (d).

Points (a), (b) and (g) address component 1 ‘Safety policy and objectives’ of the ICAO SMS framework. Points (c) and (d)(1) address component 2 ‘Safety Risk Management’ of the ICAO SMS framework. Point (d)(2) addresses component 3 ‘Safety Assurance’ of the ICAO SMS framework. Finally, point (f) addresses component 4 ‘Safety Promotion’ of the ICAO SMS framework.

Point 145.A.200 introduces the following as key safety management processes; these are further specified in the related AMC and GM:

- Hazard identification;

- Safety risk management;

- Internal investigation;

- Safety performance monitoring and measurement;

- Management of change;

- Continuous improvement;

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

It is important to recognise that safety management will be a continuous activity, as hazards, risks and the effectiveness of safety risk mitigations will change over time.

These key safety management processes are supported by a compliance monitoring function as an integral part of the management system. Most aviation safety regulations constitute generic safety risk controls established by the ‘regulator’. Therefore, ensuring effective compliance with the regulations during daily operations and independent monitoring of compliance are fundamental to any management system for safety. The compliance monitoring function may, in addition, support the follow-up of safety risk mitigation actions. Moreover, where non-compliances are identified through internal audits, the causes will be thoroughly assessed and analysed. Such an analysis in return supports the risk management process by providing insights into causal and contributing factors, including human factors, organisational factors and the environment in which the organisation operates. In this way, the outputs of compliance monitoring become some of the various inputs to the safety risk management functions. Conversely, the output of the safety risk management processes may be used to determine focus areas for compliance monitoring. In this way, internal audits will inform the organisation’s management of the level of compliance within the organisation, whether safety risk mitigation actions have been implemented, and where corrective or preventive action is required. The combination of safety risk management and compliance monitoring should lead to an enhanced understanding of the end-to-end process and the process interfaces, exposing opportunities for increased efficiencies, which are not limited to safety aspects.

As aviation is a complex system with many organisations and individuals interacting together, the primary focus of the key safety management processes is on the organisational processes and procedures, but it also relies on the humans in the system. The organisation and the way in which it operates can have a significant impact on human performance. Therefore, safety management necessarily addresses how humans can contribute both positively and negatively to an organisation’s safety outcomes, recognising that human behaviour is influenced by the organisational environment.

The effectiveness of safety management largely depends on the degree of commitment of the senior management to create a working environment that optimises human performance and encourages personnel to actively engage in and contribute to the organisation’s management processes. Similarly, a positive safety culture relies on a high degree of trust and respect between the personnel and the management, and it must therefore be created and supported at the senior management level. If the management does not treat individuals who identify hazards and report adverse events in a consistently fair and just way, those individuals are unlikely to be willing to communicate safety issues or to work with the management to effectively address the safety risks. As with trust, a positive safety culture takes time and effort to establish, and it can be easily lost.

It is further recognised that the introduction of processes for hazard identification and risk assessment, mitigation and verification of the effectiveness of such mitigation actions will create immediate and direct costs, while related benefits are sometimes intangible, and may take time to materialise. Over time, an effective management system will not only address the risks of major occurrences, but also identify and address production inefficiencies, improve communication, foster a better organisational culture, and lead to a more effective control of contractors and suppliers. In addition, through an improved relationship with the authority, an effective management system may result in a reduced oversight burden.

Thus, by viewing safety management and the related organisational policies and key processes as items that are implemented not only to prevent incidents and accidents, but also to meet the organisation’s strategic objectives, any investment in safety should be seen as an investment in productivity and organisational success.