Sarcs,
I will always be guilty of being Machiavellian, goes with the name...
But you ascribe a number of unfortunate traits to me that I fear are unjustified. My comments on Annex 19 were based on Attachments D and E to the ICAO State letter AN 8/3-13/30:
ATTACHMENT D to State letter AN 8/3-13/30
SOURCES OF ANNEX 19, FIRST EDITION
Note 1. ― This document tracks the sources of Annex 19 – Safety Management, first edition. For the purpose of clarity, coherence and understanding, the content of the SARPs in Annex 19 may have been
modified from the original text.
Note 2. ― “Transfer” to Annex 19 means that the provision no longer exists in the original Annex. “Duplication” means that the provision has been copied into Annex 19 and has been kept in the original Annex (with amendment, as needed).
Note 3. ― As a result of the adoption of Annex 19, consequential amendments to Annexes 1 (Amdt. 171), 6, Part I (Amdt. 37), II (Amdt. 32) and III (Amdt. 18), 8 (Amdt. 104), 11 (Amdt. 49), 13 (Amdt. 14) and 14,Volume I (Amdt. 11) have also been adopted.
and the table attached thereto contains only two new provisions, both for continuity. However, it is Attachment E that tells us what is happening:
ATTACHMENT E to State letter AN 8/3-13/30
CLARIFICATIONAND ROLL-OUT PLAN FOR ANNEX 19, FIRST EDITION
This attachment contains information regarding the creation of Annex 19 and its implementation. The States are invited to broadly distribute this document internally to their appropriate staff and externally to the industry, in order to efficiently support the roll-out of this new ICAO Annex and reach out the largest amount of stakeholders.
The ICAO Safety Management website, http://www.icao.int/SafetyManagement has been updated to provide valuable information on the implementation of Annex 19 and will be updated regularly with new developments. Any questions regarding Annex 19 or safety management provisions can be addressed to [email protected].
1. BACKGROUND
1.1 Safety management provisions were gradually introduced into the following ICAO Annexes beginning in 2001:
a) Annex 1 — Personnel Licensing;
b) Annex 6 — Operation of Aircraft, Part I — International Commercial Air Transport — Aeroplanes, Part II — International General Aviation — Aeroplanes and Part III — International Operations — Helicopters;
c) Annex 8 — Airworthiness of Aircraft;
d) Annex 11 — Air Traffic Services;
e) Annex 13 — Aircraft Accident and Incident Investigation; and
f) Annex 14 —Aerodromes, Volume I — Aerodrome Design andOperations.
1.2 In response to High-level Safety Conference 2010 (HLSC/2010) Recommendation 2/5, the ICAO Council supported a two-phased approach for the creation of a new safety management Annex:
a) the first phase to consolidate existing and overarching Standards and Recommended Practices (SARPS), currently contained in as many as six different Annexes, into a single new Annex; and
b) the second phase for the development of new safety management provisions.
1.3 On 25 February 2013, the ICAO Council unanimously adopted the first edition of Annex 19 with an applicability date of 14 November 2013.
2. SUMMARYOF ANNEX 19 CONTENTS
2.1 The first edition of Annex 19 is a consolidation of existing overarching safety management provisions. The sources of Annex 19, first edition, are described in Attachment D to this State letter.
2.2 Minor modifications were made as necessary for the purposes of clarity and consistency. In addition, the following amendments were made for harmonization purposes:
a) the four components of the SSP framework were elevated to a Standard in Chapter 3;
b) State safety oversight provisions (Appendix 1) were derived from Annex 6, Part I, Appendix5 and Annex 6, Part III, Appendix 1 and their applicability broadened to all service providers identified in Chapters 3 and 4;
c) Safety data collection analysis and exchange (Chapter 5) provisions were transferred from Annex 13. Legal guidance for protection of safety information (Attachment E to Annex13) is replicated as Attachment B to Annex 19; and
d) the SMS framework(Appendix 2) now applies to type design and manufacture of aircraft.
I'm not entirely sure what my research crime was 