Implementation of Safety Management System (SMS) for ATO

[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

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.

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Bharat Davé
GAAC
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[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!!!

[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?).

[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