SMS Interfaces Operator - CAMO - Maintenance
SMS interfacesOperator - CAMO - Maintenance16/May/2017Jorge LeiteVP Quality & SafetyTAP Maintenance & Engineering16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Abstract Relying safety requirements to the CAMO and AMOs: theOperator’s perspective SMS integration: bridging the gap between Operator,CAMO and AMO Contracted maintenance and occurrence reporting: thelack of occurrence reports from AMOs Interfaces and challenges among players: 16 May 2017Risk classification integrationMaking safety objectives and targets compatibleOccurrence reporting and safety data sharingSM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Summary1. SMS Regulatory Update2. SMS Interfaces3. Interface Threats4. Conclusions16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
1. SMS Regulatory UpdateWhat is being done by the Authorities to implement andharmonize a comprehensive set of Safety managementregulatory tools ?16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Regulatory Update ICAO Annex 19 “Safety Management”, Ed. 1 (July 2013), 14/Nov/2013 16 May 2017Integrates safety management provisions contained before in: Annex 1 - Personnel Licensing Annex 6 - Operation of Aircraft Annex 8 - Airworthiness of Aircraft Annex 11 - Air Traffic Services Annex 13 - Aircraft Accident and Incident Investigation Annex 14 - AerodromesAnnex 19, Amendment 1: Adopted 02/Mar/2016 Effective 11/Jul/2016 Applicable by 07/Nov/2019SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Regulatory Update ICAO 16 May 2017(i.a.w. Annex 19, Ed. 1) each State shall implement an SSP andshall require that the following service providers under itsauthority implement an SMS: Approved Training Organisations (ATPL, CPL, ATCO) Operators (aeroplanes & helicopters, authorised to conduct international CAT) Approved Maintenance Organisations Organisations responsible for the type Design or Manufacture (aircraft) Air Traffic Services Providers Operators of Certified Aerodromes International General Aviation operators of large or turbojet aeroplanesSM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Regulatory Update ICAO Annex 19, Amendment 1 - main changes: Harmonization of 8 Critical Elements (CE) of State Safety Oversight (SSO), i.a.w.State Safety Program (SSP) Enhanced Guidance and Applicability of SMS 16 May 2017 Applicability extended to engine and propeller type designers and/or manufacturers Accountabilities vs. Responsibilities Safety Culture Scalability for large & small service providers IGA Recommendation elevated to StandardEnhanced Protection of Safety Data / Safety Information and Related SourcesSM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Regulatory Update ICAO16 May 2017 Doc. 9859 “Safety Management Manual (SMM)”Ed. 3, 08/May/2012 Development of SMM Ed. 4 Currently under way Publication of Ed. 4 expected in Jul/2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Regulatory Update IATA IOSA, “Standards Manual”, Ed. 10, 01/Sept/2016 (Ed. 11 published Apr/2017, effective date 01/Sept/2017) EU16 May 2017 EASP “European Aviation Safety Programme”2nd edition, 07/Dec/2015 EPAS “European Plan for Aviation Safety”6th edition, EPAS 2017-2021, 24/Jan/2017 SSP “State Safety Program” of each Member StateSM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Regulatory Update EASA Air Operations Commission Regulation (EU) No 965/201205/Oct/2012, OPS.ORO.GEN.200 EASA Initial Airworthiness16 May 2017 Task RMT.0262 (MDM.060) “Embodiment of Level ofInvolvement (LOI) requirements into Part-21”, ref NPA 2015-03Opinion 07/2016, 23/May/2016 Task RMT.0550 (MDM.060) “Embodiment of SMS requirementsinto Part-21” (Decision initially expected 4Q 2016)supersededSM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Regulatory Update EASA Continuing Airworthiness Task RMT.0251 (MDM.055) “Embodiment of SMS requirementsinto Regulation (EU) No 1321/2014 for the implementation of aState Safety Plan” (covers NPA 2013-01 and NPA 2013-19) NPA 2013-01 “Embodiment of SMS requirements intoCommission Regulation (EC) No 2042/2003”, 21/Jan/2013(A) – Explanatory note and RIA(B) – Part M(C) – Part 145 16 May 2017NPA 2013-19 “Embodiment of SMS requirements intoCommission Regulation (EC) No 2042/2003: Part 66 & Part 147”,10/Oct/2013SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Regulatory Update EASA Continuing Airworthiness In 2015, EASA decided to adopt a two-phased approach for taskRMT.0251 (MDM.055) and to include the SMS part of taskMDM.060: Phase I: Embodiment of SMS requirements in Part M and creation of Part CAMO,Opinion 06/2016, 12/May/2016 (Decision expected 2Q 2017)Phase II: Embodiment of SMS requirements in Part 145, Part 21J and Part 21G SMS elements to be added to Part 66 training syllabi ToR RMT.251(b) (issue 1) expected May 2017, NPA expected 1Q 2018, Opinionexpected 2Q 2019, Decision expected 1Q 2021Note: Part 147 will not have an SMS16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Regulatory Update EASA Continuing Airworthiness Opinion 06/2016 “Part CAMO”: Introduces SMS in Continuing Airworthiness Management throughthe creation of new Annex Vc “Part CAMO” to Regulation1321/2014 Part CAMO approval will be needed for continuing airworthinessmanagement of aircraft 16 May 2017 Operated by licensed air carriers CMPA (twin-turboprops 5700 kg MTOM exempted)Opinion 06/2016 prepares the grounds for allowing licensed aircarriers to contract a CAMO (objective of RMT.0209 (M.014))SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Regulatory Update EU Occurrence Reporting16 May 2017 Regulation (EU) No 376/2014 of the European Parliament and ofthe Council on “Reporting, analysis and follow-up of occurrencesin civil aviation”, 24/Apr/2014, due by 15/Nov/2015 Commission Implementing Regulation (EU) 2015/1018 on a “Listclassifying occurrences in civil aviation to be mandatorilyreported”, 30/Jun/2015, due by 15/Nov/2015SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
2. SMS InterfacesEven when organisations run well organised and efficient(internal) Management Systems, they repeatedlyencounter hidden and unexpected hazards in theinterfaces16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
ICAO SMS: implementation status by EASAICAO Annex 19 “Safety Management”ICAO Doc. 9859, Ed. 3EU and EASA RegulationsSMS oversightImplementedImplementation soon required by EASARequired by ICAO, not yet implemented by EASACompetentAuthoritiesNot required by ICAO, will not be implemented by EASANot requiredTrainingATOEASA Air CrewATCOATC TrainingOperatorEASA Air OperationsCAMOPart MSubpart GAMOPart AMT TrainingPart 66syllabus16 May 2017DOAPart 21JDesigners andManufacturersAerodromesEASA ADRATM/ANSAerodromesATCSM ICG – Industry DayPOAPart 21G Jorge Leite @ TAP Maintenance & Engineering
EASA Regulatory InterfacesState of DesignOwners &LessorsDOAPart 21JPOAPart 21GAMTOPart 147State of ManufactureProviders& SuppliersState of OperatorState of RegistryCAA 3AMOPart 145CAA 4AMOPart 1452ndtierContract2nd tierContractAOC OperatorEASA Air OperationsEASA Part MCAA 1AMOPart 145CAA 2AMOPart 1451st tierContract1st tierContractManufacturersCAMOPart M Subpart GCAMOQualified entityAMOQualified entityOtherATOEASA Air CrewAMOCAA 5“Independent”CAMOEtc.SubcontractsCAA 6“Independent”CAMOEtc.Subcontracts16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Operator-CAMO-AMO: SMS Expectation?SSPCAA?SSPCAASSP ?CAAVery LowAverageOperatorEASA Air OpsAnotherOperatorCAMOPart MSMS rmometer”SMS ?DesignOrganization orManufacturerSMS ?1st tierContractedAMOSMS ?2nd tierContractedAMO16 May 2017SMS ?ContractingAMOSMS.?SMS ?SubcontractedAMOVery HighSMS ?2nd tierContractedAMOSM ICG – Industry DaySMS requirements to MROSMS requirements from MRO Jorge Leite @ TAP Maintenance & Engineering
3. Interface ThreatsClear lines of Safety accountability connect the Operator,through its CAMO to the many AMOs used. What canbreak those lines?16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
SMS Interfaces: some Threat DomainsPolicies andProceduresManagement ofChangeSafetyAssuranceHazardIdentificationIt is not possibleto impose manceMeasurement16 May 2017OccurrenceReporting &Safety DataRiskManagementSM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Policies and Procedures Different Countries - different Safety Cultures Players with different levels of Safety maturity Not all organisations equally prepared Systems/software do not communicate Not all CAAs equally prepared Coordination among CAAs Prescriptive vs. risk based oversight CAA oversight proficiency16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Hazard Identification Some CAMOs and AMOs have not identified their hazards AMOs difficulty to correlate own hazards with undesirableend states (risks) of each Operator s safety scenarios16 May 2017 Some CAMOs and AMOs lack enoughdata to identify their hazards Insufficient uniformity in hazardidentification tools, logs and analysis Pushing SMS practical implementation inAMOs (E.U.) to 2023 is also a hazard !SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Occurrence Reporting & Safety Data Competition hinders data sharing Confidentiality issues impair data sharing Occurrences not treated or not transmitted16 May 2017 Reports within AMO typically lessthan among Operator Investigations not coordinated withthe Operator Conclusions not shared Communication channels not workingSM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Risk Management Some players cannot answer:What are my main risks? How does my organisation know that? What am I doing about that? Is it working? Risk models vary among players and arenot harmonized (should they be?):Risk perception and classification Risk acceptance and tolerability criteria Action strategies and implementation periods There is no risk management plan16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Performance Measurement SPIs are they used? Which type? How to correlate different SPIsamong players? How to compare different targetsand alert criteria? Insufficient focus on Safety performance SPIsSafety trend monitoringSafety performance continuous improvement plansResources for continuous improvemnentNo contract provisions about Safety performance16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Safety Assurance Different levels of Safety oversight among players Despite of AMO being certified, shortcomings in Safetyassurance are only revealed during maintenance work16 May 2017 Maintenance workaccomplished differently fromcontract, with impact on Safety Responsibilities andcommunication channels donot work as agreedSM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Management of Change Players do not know which changes may create new risks New hazards are identified but risk is underestimated AMO and/or CAMO do not have contingency plans Contingency plan does notwork or is not guaranteed Operator not informedabout significant changes16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
4. Conclusions16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Conclusions Full SMS implementation is taking a long time, particularlyin the E.U. (OPS in 2014, CAMO in 2019?, AMO in 2023?) SMS interfaces are becoming increasingly more complex Attention must be payed to hazards hidden in the interfaces Compliance is not easy, especially on 2nd tier contracts,entities outside Annex 19 and due to cultural differences Clear lines of Safety accountability must exist, from one ormore AMOs, through the CAMO, to the Operator Safety data sharing needs to be increased16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
Thank you !Jorge LeiteTAP Maintenance & EngineeringVP Quality and Safetydleite@tap.ptwww.tap-mro.comwww.flytap.pt16 May 2017SM ICG – Industry Day Jorge Leite @ TAP Maintenance & Engineering
EASA Air Crew Operator EASA Air Operations ICAO SMS: implementation status by EASA CAMO Part M Subpart G AMO Part 145 ATCO ATC Training DOA Part 21J POA Part 21G Aerodromes EASA ADR ATM/ANS GA International Operator Competent Authorities ICAO Annex 19 “Safety Management” ICAO Doc. 9859, Ed. 3 EU an
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AMP The AMP document must be approved by the contracted CAMO/CAO(-CAM). If there is no CAMO/CAO(-CAM), the AMP must be declared by the owner. If there is a contracted CAMO/CAO(-CAM), the AMP must be approved by the CAMO/CAO(-CAM). If ML.A.302(e) conditions are met, producing an AMP document is not required.
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