MO Management System

The new Part 145 Management System
by Sally Anderson

Through safety management, the proactive identification and mitigation of potential hazards aim to prevent aviation accidents and incidents. It empowers organizations to methodically and precisely conduct their operations. With a comprehensive grasp of their responsibility in aviation safety, maintenance organizations can prioritize risk factors, optimize resource allocation, and achieve superior outcomes.

The essence of the new requirements in points 145.A.200, 145.A.202, 145.A.205, and their corresponding AMC forms the foundation of the EU's aviation safety management system framework. Aligned with the ICAO's safety management system (SMS) framework in Appendix 2 to Annex 19, this structure encompasses compliance monitoring elements and advocates for an organization-wide integrated management approach. It supports the incorporation of supplementary safety management aspects, augmenting the current management system instead of establishing them as an independent framework.

This strategy aims to integrate safety management and risk-based decision-making seamlessly into an organization's operations, rather than imposing an additional system atop its existing management structure. Moreover, for entities holding multiple organization certificates under Basic Regulation (EU) 2018/1139, the option exists to implement a unified management system covering all their activities. This integrated system not only fulfills the management system requirements stemming from Regulation (EU) 2018/1139 but can also encompass compliance needs from Annex 19 or other business management systems like security, occupational health, and environmental management. By integrating these systems, redundancies can be eliminated, and synergies exploited, effectively managing safety risks across various activities. Organizations have the flexibility to structure their management systems in ways that best align with their business and organizational requirements.

The core part of the management system framework 

The core part of the management system framework (145.A.200) focuses on what is essential to manage safety, by mandating the organisation to:

(a) clearly define accountabilities and responsibilities;

(b) establish a safety policy and the related safety objectives;

(c) implement safety reporting procedures in line with just culture principles;

(d) ensure the identification of aviation safety hazards entailed by its activities, ensure their evaluation, and the management of the associated risks, including:

(1) taking actions to mitigate the risks;

(2) verifying the effectiveness of the actions taken to mitigate the risks;

(e) monitor compliance, while considering any additional requirements that are applicable to the organisation;

(f) keep their personnel trained, competent, and informed about significant safety issues; and

(g) document all the key management system processes.

Compared with the previous Part-145 quality system ‘framework’ (now covered by point (b) and (e)), the new elements that are introduced by the management system are, in particular, those addressed under points (c) and (d).

Points 145.A.200 a) 

2) address component 1 ‘Safety policy and objectives’ of the ICAO SMS framework. 

3) address component 2 ‘Safety Risk Management’ of the ICAO SMS framework. 

3) addresses component 3 ‘Safety Assurance’ of the ICAO SMS framework. 

4) and 5) addresses component 4 ‘Safety Promotion’ (including Eductation & Training) of the ICAO SMS framework.

Point 145.A.200 introduces the following as key safety management processes; these are further specified in the related AMC and GM:

− Hazard identification;

− Safety risk management;

− Internal investigation;

− Safety performance monitoring and measurement;

− Management of change;

− Continuous improvement;

− Immediate safety action and coordination with the aircraft operator’s Emergency Response Plan (ERP).

It is important to recognise that safety management will be a continuous activity, as hazards, risks and the effectiveness of safety risk mitigations will change over time.

 Harmonization of
Safety Risk Management and Compliance Monitoring

The foundation of these critical safety management procedures is reinforced by an integral compliance monitoring function within the management system. Most aviation safety regulations lay down general safety risk controls established by regulatory bodies. Therefore, ensuring consistent compliance with these regulations in day-to-day operations, along with independent monitoring, forms the bedrock of any safety-oriented management system. 

Moreover, the compliance monitoring function can assist in overseeing the implementation of safety risk mitigation measures. Additionally, when internal audits uncover non-compliance, a comprehensive assessment and analysis of the underlying causes follow suit. This analysis aids the risk management process by shedding light on causal and contributing factors, encompassing human, organizational, and environmental elements within the operational landscape. Consequently, the insights derived from compliance monitoring serve as significant inputs to safety risk management functions. Conversely, the outcomes of safety risk management processes help determine focal areas for compliance monitoring. 

This dynamic interplay ensures that internal audits inform the organization's management about its internal compliance status, the implementation of safety risk mitigation strategies, and areas necessitating corrective or preventive actions. The harmonization of safety risk management and compliance monitoring fosters a comprehensive understanding of end-to-end processes and their interfaces, uncovering opportunities for improved operational efficiencies that extend beyond safety considerations.

 Human actions influence an organization's safety outcomes

In the intricate and complex landscape of aviation, numerous organizations and individuals collaborate, placing the primary emphasis of pivotal safety management processes on organizational procedures. However, these processes are also inherently intertwined with human involvement within the system. 

The structure and operations of an organization hold substantial sway over human performance. Consequently, safety management intricately considers the ways in which human actions, whether positive or negative, influence an organization's safety outcomes. It acknowledges the intricate interplay between human behavior and the organizational environment, recognizing that the organizational setting significantly shapes human actions within aviation operations.

The effectiveness of safety management is significantly reliant on the commitment level of senior management in fostering a workplace environment that optimizes human performance. This includes encouraging active participation of personnel in the organization’s management processes. A positive safety culture, in turn, hinges on establishing a foundation of trust and respect between personnel and management, an initiative that must originate and be bolstered from the senior management tier. When management fails to consistently treat individuals reporting hazards and adverse events fairly, it hampers their willingness to communicate safety concerns or collaborate effectively to address risks. 

Establishing a positive safety culture is a gradual process demanding continuous effort, yet it remains fragile and can be easily compromised.

 Crucial role in supporting Maintenance Organizations

Recognizing that implementing processes for hazard identification, risk assessment, and mitigation entails immediate costs and that the benefits might be less tangible and take time to materialize, Steia Aviation understands the crucial role in supporting Maintenance Organizations. While such systems directly address major risks, they also have broader-reaching advantages over time. 

An effective management system not only mitigates major occurrences but also 

Additionally, it can lead to a more collaborative relationship with regulatory authorities, potentially reducing oversight obligations. 

By perceiving safety management and associated organizational policies not just as preventive measures for incidents but as contributors to the organization's strategic goals, investments in safety translate into productivity enhancements and overall organizational success. Steia Aviation stands ready to assist Maintenance Organizations in aligning safety measures with broader strategic objectives, thereby ensuring a holistic approach towards operational efficiency and success.

STEIA AVIATION supports PART 145 Safety Promotion Management