Implementation of Safety Management System (SMS) for ATO

[Mickey Kaye]

Just read IN-2013/028

And I have to say that I can't really make head or tail of it but the bit that caught my eye. Was;

3. Scope

3.1 For those ATO and registered facilities that have not yet done so, they must complete and submit to the CAA by 8 April 2013 the following


.....,,,, A draft safety management system

Now I thought RF had until 2015 to comply? (or more likely close down cause there no longer commercially viable) so why have they issued this?

[Whopity]

This further illustrates how out of control things have become! Just ignore it!

[Nikon744]

I think the small RF that I am involved with as an FI will just complete the Non-Complex Organisation Stage 1 SMS form answering 'No' to most questions (if being truthful!), or 'Partial' (slight fib), or 'Yes' (big fib), and a Draft SMS can be a simple one-page affair comprising some bureaucratic nonsense pinched off the internet. A more sensible SMS can then be sorted out over the next few months.

As the CAA suggest in the IN, it takes a year to get an SMS 'matured', so respond as suggested above to keep them off your backs for now. I don't suppose the CAA have got the staff to properly analyse all the responses anyway, and they will all end up in a big pile somewhere, along with all the other EASA paperwork!

[mad_jock]

Unfortunately most schools if they answered it truthfully the answer would mostly be

"I don't have a clue"

[bylgw]

Does the pilot order book for any part of a SMS?

[Whopity]

No such thing under EASA; they require an Operations Manual which will specify all operational details.

[ZFT]

There most certainly is.

[BEagle]

IN-2013/028 just about puts the lid on the ridiculous nonsense the CAA, alleging the big boys at EASA are bullying them, has inflicted on the private pilot training world.....

There is absolutely no need for all the cr@p now appearing from the Belgrano's orifice - as Whopity infers, it just shows how ridiculous and out of touch with reality they are at Gatwick these days.

[Mickey Kaye]

But BEagle we are talking about peoples careers and livelihoods here. The CAA may well be out of touch with industry but where does that leave those who are effected by their actions?

What is needed is answers to all these problems.

Can rf/ATO that are based in the UK register with a different country for instance?

I know for a fact that the recently imposed changes have already had a negative impact on the flight training industry.

[Whopity]

The following statement is from FAQ 31 on the CAA Website:31. How will the new rules affect Registered Facilities (PPL training)?

The EU regulations include a transition period in that Registered Facilities that are registered before the implementation of Part-ORA may continue training for the PPL under their existing arrangements up to 8th April 2015. Therefore there is no reason to get involved in EASA requirements until the RF applies to become an ATO. It would seem the reference in the IN is probably there in error.

[BEagle]

Whopity, quite correct.

AOPA has just been advised by the CAA that this Information Notice will be 'corrected and re-issued this week to target only the current ATOs and not the RFs'.

:\

[Whopity]

Yet another document that has been released without being checked!!!!

[Capot]

Regardless of who must instal Safety Management and who need not do so (to comply, at least) I get increasingly irritated that so few people understand what the EASA requirement really is, as stated in Part ORO.GEN.200.

The UK CAA is determined to make an industry of of Safety Management, for reasons that we all know.

EASA does NOT require a "Safety Management System".

Can we please have that emblazoned all over Aviation House before we all get swamped by the tsunami of advice and guidance, consultants, etc etc about setting up a "Safety Management System".

I will now repeat the entire requirement of Part ORO.GEN.200 so far as Safety Management is concerned. (The rest is a few short sentences about other management functions, eg personnel management.)

ORO.GEN.200 Management System

The operator shall establish, implement and maintain a management system that includes;

http://i243.photobucket.com/albums/ff141/picshooter/EASA200_zpsd916e88b.jpg


You will have spotted immediately what’s missing; it’s the words “Safety Management System”. This is because a separate SMS is not required.

EASAQuote #1. “There is no requirement to implement an SMS, but (there is) a requirement to implement a Management System with specific features.”

EASA Quote #2 “ EASA Framework does not require a separate Safety Management System Manual (can be integrated with the other management system documentation, MOE, CAME etc…). »

Those quotes come from EASA Presentation material, used last December at a Workshop where they stressed that a separate system is NOT what's wanted.

So the most that any Operator has to do is incorporate into its Management System the Safety Policy and the features listed in Part ORO.GEN.200 (2), to the extent that they are not there already.

To EASA's credit the introduction of Safety Management was intended to be a simple, do-able improvement to the existing Management System that every Operator must have to support its AOC. The improvement is one that any company, large or small, would find easy to do and would benefit from. Aviation Safety would improve.

The UK CAA has managed, of course, to turn it into a bureaucratic exercise of staggeringly unnecessary, monumental proportions. This will keep their bureaucrats (and ex-bureaucrats in their favourite training companies) in gainful employment for years. It will do nothing for Aviation Safety.

No-one should accept this. If a FoI demands more than EASA intended, it must be challenged. If not, you will have for ever more a huge administrative burden that need not be there.

[BillieBob]

Given the fact that the original question related to ATOs and Registered Facilities rather than AOC holders, the comments are even more apposite. The requirements of ORA.GEN.200 are identical to that of their Air Ops equivalent but the mismatch between the actual EASA requirements and the current CAA (mis)interpretation is even more pronounced.

The people who are driving the SMS bandwagon in the Belgrano have, for the most part, a 'big aeroplane' background and know nothing whatever about the realities of small ATOs and RTFs. The best advice is to read only those AMCs that relate to non-complex organisations (only a few of the largest ATOs will fall into the complex category) and comply with the letter of the requirements. Any attempt by CAA inspectors to impose anything more onerous should be met with, "Show me where that requirement is published".

[BEagle]

The corrected version of IN-2013/028 has now been released.

See http://www.caa.co.uk/docs/33/srg_lts_ImplementationOfSMS_IN2013_028.pdf

[Capot]

BTW, the information in my post above all came from a piece of CBT called SMS Demystified, done on line, that we bought for £40 or so. In an hour or two it gets across the same Safety Management knowledge that you get on a 3-day residential course (£1,500 plus) run by the CAA or its associates.

PM if you want any info, I'd like to support their stand against the Belgrano!

[Capot]

I've just read the CAA notice kindly linked by BEagle...

In it the CAA says that Part ARO requires a Safety Management System for ATOs. This is simply untrue. The requirement (Part ARO.GEN.200) is exactly the same as ORO.GEN.200, quoted above, and EASA is taking a lot of trouble to say they do not want an "SMS".

TheCAA's tip of the hat to the actual Regulation is as follows

"...must complete and submit.....a draft Safety Management System Manual (this could form part of a Management System Manual including Compliance Monitoring) or a compliance matrix demonstrating where they have detailed SMS proceses and procedures into existing approved Manuals".

I have underlined the EASA requirement. EASA specifically does not want a "Safety Management System Manual", which just creates another silo.

We must be grateful that, ignoring the appalling English of that sentence, the CAA will allow an ATO to simply add safety management processes to its existing company manual, as EASA wishes.

But the CAA's instinct to make it as bureaucratic as possible, and give their staff something to do, shines through. They want (1) a "Phase 1 Gap Analysis" and (2) a "Compliance Matrix" by 8th April 2013 from anyone with the temerity to take that route.

Why? A Gap Analysis is a compliance matrix; it shows where there's no compliance, ie the gaps. Where there is a gap, there needs to be another column for the action taken to fill the gap. Nothing more is needed!

But hey, that's too simple.

[Treadstone1]

I have just sent off, what i think is a reasonable attempt at complying with the CAA's latest IN regarding requirements for an SMS.....i have not got a scoobie really.....:confused::confused::confused:

I am begining to loose the will to live with all this foo king nonsense....lets see what reply i get before "End Ex" and they move the goalposts again. :ugh::ugh::ugh:

[timprice]

I thought the CAA are only suppose to regulate now!
EASA makes the rules, the CAA just enforce them!:*

[BigEndBob]

I plan on doing sod all until i get in writing exactly what we have got to do. They are quick enough to tell us our £100 is due to remain a RF, not so quick to tell me what the hells going on re; EASA!
I shouldn't have to read these forums!

[BillieBob]

I think that is a forlorn hope. The UK CAA has taken a corporate decision that it will NOT lead the industry or individuals through these changes. The attitude is that all of the requirements are published on-line and it is the 'stakeholder's' responsibility to read, interpret and comply with them. Any organisation that fails to comply by the due date(s) will either not be approved or will have its existing approval revoked.

There are whispers of some kind of guidance being produced for Registered Facilities but beyond that you're likely to be on your own.

[Whopity]

For those who might wish to rub a little salt into the wound and make a stand against the new bureaurocracy this appeared on another site:
The GAAC has arranged a meeting with the Rt Hon Grant Shapps MP to address elimination of unnecessary‘red-tape’ and ‘regulation’ affecting General Aviation.

In order that we may present facts to the Cabinet Office in a way that enables us to reduce the many petty restrictions that add cost without benefit to GA, please would you provide examples with Chapter and Verse of those impositions in the ANO or other that are felt to be without merit.

This is a unique opportunity to brief the Minister (who is himself a Pilot) and your responses are needed by Thursday March 15….so please treat the matter as both urgent and important.

Charles Henry FRAeS

Chairman GAAC

Red Tape Challenge - Home (http://www.redtapechallenge.cabinetoffice.gov.uk/home/index/)

The GAAC is acting as a focal point for developers wishing to advise the General Aviation community of structures that may affect them.The GAAC does not verify the information provided and accepts no responsibility. Eachorganisation receiving this e-mail should therefore check the information and take such action as they may see fit to advise their own contacts.

Should you wish not to receive these updates, please inform the GAAC and your name will be removed from the circulation list.

Bharat Davé
GAAC
RAeS House
4 Hamilton Place
London
W1J 7BQ
UK

Tel: +44 (0)20 7670 4371

Email: [email protected]

Web: GAAC (http://www.gaac.org.uk)

[2close]

At a time when the UK government is reducing the onerous burden on SMEs to comply with over-restrictive Health & Safety Law and local authority despots, the CAA, in its typical demand for even more pointless bureaucracy, introduces a requirement for all operators, even the small ones, to have some form of SMS in place, even though EASA doesn't actually require this.

Have I got this right?

This being the case, then surely the issue must be brought to the attention of the Secretary of State for Transport - your government is telling us we need to do less and in blatant disregard of those instructions, one of your quangoes (!) is telling us we need to do more.

Please explain....oh...and before your say "It's not us, it's EASA" (employ pathetic, bleating voice) EASA doesn't want it!!!

:mad:

[Capot]

Have I got this right?
Not exactly; the essential EASA requirement is indeed that Safety Management procedures are incorporated into an ATO's (among other forms of organisation) management procedures, alongside QA etc.

But it is expressed in simple language and is not intended to create a huge bureaucratic burden. Full marks to EASA.

The UK CAA will allow that to be done, but they are already demanding more paperwork than is necessary.

They are also using the expression Safety Management System wherever possible, as though what is wanted is a discrete System with its own SMS Manual. This is directly contrary to EASA's intention.

But they will accept procedures incorporated into a management manual, as shown in a previous post. What the industry must do is challenge any suggestion that a separate system and manual must be installed.

Incidentally, Safety Management procedures are all about pro-actively seeing where things could go wrong (Hazards) and fixing them. Properly designed and scaled to a business, and properly managed, they can remove the holes in the cheese before they line up to kill you. I have little sympathy with those who think they have no holes in their business operations; this is self-delusion.

I'm just irritated by the way that the UK CAA is leaping on the bandwagon with paperwork, guidance documents, evaluation tools, blah blah, the whole nine yards, all the usual bureaucratic substitutes for knowledge and common-sense. They are busily turning the whole thing into yet another box-ticking exercise with no effect whatsoever.

There is no, repeat no, requirement for anyone in an organisation to attend a training course run by CAA (or an associated training company). This suggestion has been made to several organisations as a pathway to their system being "signed off", and is not true. A management system must be assessed for compliance with EASA requirements on its merits, not on whether the organisation has paid several thousands of pounds to the CAA's favourite organisation(s), such as CAAi, for "training".

[2close]

Thanks for the reply. I should have clarified that what I meant was that EASA does NOT require a separate SMS, completely independent of any other Management System.

Of course it is sensible to have safe working practices and an effective top-down hierarchy of safety management but the creation of paperwork for the sake of creating paperwork is nothing less than an exercise in making oneself seem more vital to the effective running of 'the system' (therein lies another discussion - is the CAA employing role creation and protectionism?).

:ugh:

[212man]

The EASA viewpoint is that an SMS should not be a stand alone process but integrated into the overall management system.:

Organisation Requirements include consolidated general requirements for management systems, designed to embed the ICAO SMS SARPs in a way as to ensure compatibility with existing management systems and to encourage integrated management. The Agency believes that SMS should not be implemented through an additional requirement superimposed onto the existing rules: Imposing a safety management system as a separate element could be interpreted as yet another prescriptive requirement, with the risk that organisations seek to satisfy their competent authority by showing that they have added in their organisation all required prescriptive elements, without effectively embedding safety management into all their processes. The EASA management system requirements fit various organisations, whatever their size, nature or complexity of activities and whatever business model they follow, thus catering for proportionate application