Implementation of Safety Management System (SMS) for ATO
Thread Starter
Join Date: Jan 2008
Location: York
Age: 53
Posts: 797
Likes: 0
Received 0 Likes
on
0 Posts
Implementation of Safety Management System (SMS) for ATO
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?
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?
Last edited by Mickey Kaye; 28th Feb 2013 at 21:44.
Join Date: Oct 2007
Location: UK
Age: 64
Posts: 8
Likes: 0
Received 0 Likes
on
0 Posts
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!
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!
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.
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.
Thread Starter
Join Date: Jan 2008
Location: York
Age: 53
Posts: 797
Likes: 0
Received 0 Likes
on
0 Posts
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.
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.
Last edited by Mickey Kaye; 3rd Mar 2013 at 18:47.
The following statement is from FAQ 31 on the CAA Website:
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.
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.
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.
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'.
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'.
Join Date: May 2007
Location: Europe
Posts: 1,416
Likes: 0
Received 0 Likes
on
0 Posts
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;
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.”
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.
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;
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.
Last edited by Capot; 6th Mar 2013 at 11:49.
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".
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".
Join Date: May 2007
Location: Europe
Posts: 1,416
Likes: 0
Received 0 Likes
on
0 Posts
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!
PM if you want any info, I'd like to support their stand against the Belgrano!
Join Date: May 2007
Location: Europe
Posts: 1,416
Likes: 0
Received 0 Likes
on
0 Posts
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.
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.
Last edited by Capot; 6th Mar 2013 at 17:05.
Join Date: Jul 2010
Location: UK
Posts: 128
Likes: 0
Received 0 Likes
on
0 Posts
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.....
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.
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.
Join Date: Jul 2003
Location: uk
Posts: 1,042
Likes: 0
Received 0 Likes
on
0 Posts
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!
I shouldn't have to read these forums!