M14 - Amo - SMS

AIRWORTHINESS INSPECTOR TRAINING
MODULE 14. AMO Safety Management
SALVADOR ALEPUZ ROMAGUERA

Aeronautical Consultant. Airworthiness Expert
Bangkok (Thailand), October 7th – 18th, 2019)
EU-South East Asia Aviation Partnership Project (EU-SEA APP)

This project is funded by the European Union and implemented by
Your safety is our mission.
An Agency of the European Union 1
the European Union Aviation Safety Agency - EASA
Module 14
ICAO & EASA

Requirements

M14. AMO Safety Management
ICAO Requirements.
Annex 6, Part I, Chapter 8, requires States, as part of their State safety

programme, to ensure that a maintenance organization implements a safety
management system acceptable to the State.
Annex 6, Part I, Appendix 7, provides the framework for a safety management
system of an AMO. The framework should include: safety policy and objectives,
safety risk management, safety assurance and safety promotion.
3
EASA Requirements.
Notice of Proposed Amendment 2019-05 (C) (NPA 2019-05), related to
“Embodiment of safety management system (SMS) requirements into Part-145”
has been published.
This NPA 2019-05:
Introduce safety management principles that implement ICAO Annex 19; and
Foster an organisational culture for effective safety management and effective
occurrence reporting in accordance with Commission Regulation (EU) No 376/2014.
The NPA 2019-05 (C) includes the draft implementing rules (IRs) as well the draft
Acceptable Means of Compliance (AMC) and Guidance Material (GM) for Part-
145. NPA 2019-05 (A) includes:
the procedural information pertaining to the regulatory proposal;
the explanatory note to the proposed amendments;
the regulatory impact assessment; and
a detailed summary of the proposed amendments
4
Acceptable Experience. Nature.
EASA Requirements
Some articles of the Part 145 standard
are to be modified while others
are to be added:
5
Acceptable Experience. Nature.
EASA Requirements
Some articles of the Part 145 standard
are to be modified while others
are to be added:
6
145.A.200 Management System.
The organisation shall establish, implement, and maintain a management system
that includes:
Clearly defined lines of responsibility and accountability throughout the organisation,
including a direct safety accountability of the accountable manager;
A description of the overall philosophies and principles of the organisation with regard to
safety, referred to as the safety policy, and the related safety objectives;
The identification of aviation safety hazards entailed by the activities of the organisation,
their evaluation and the management of the associated risks, including taking actions to
mitigate the risks and verify their effectiveness;
Maintaining personnel trained and competent to perform their tasks;
Documentation of all management system key processes, including a process for making
personnel aware of their responsibilities and the procedure for amending this
documentation;
7
145.A.200 Management System.
The organisation shall establish, implement, and maintain a management system
that includes:
A function to monitor the compliance of the organisation with the relevant
requirements. Compliance monitoring shall include a system to feed back findings to the
accountable manager to ensure the effective implementation of corrective actions as
necessary;
Any additional relevant requirements that are laid down in this Regulation
The management system shall correspond to the size of the organisation and the
nature and complexity of its activities, taking into account the hazards and the
associated risks inherent in these activities.
If the organisation holds one or more additional organisation certificates, the
management system may be integrated with that required under the additional
certificate(s) held.
8
145.A.202 Internal safety reporting scheme.
As part of its management system, the organisation shall establish an internal
safety reporting scheme to enable the collection and evaluation of such
occurrences that are to be reported under point 145.A.60 (Occurrence
reporting).
The scheme shall also enable the collection and evaluation of those errors, near
misses, and hazards reported internally that do not fall under point (a).
Through this scheme, the organisation shall:
Identify the causes of, and contributing factors to, any errors, near misses, and hazards
reported, and address them as part of their safety risk management;
Ensure an evaluation of all the known, relevant information relating to errors, the
inability to follow procedures, near misses, and hazards, and a method to circulate the
information as necessary.
9
145.A.202 Internal safety reporting scheme.
The organisation shall make arrangements to ensure the collection of any safety
issues related to subcontracted activities.
The organisation shall cooperate on safety investigations with any other
organisation that makes a significant contribution to the safety of its own
maintenance activities.
10
145.A.205 Contracting and subcontracting
The organisation shall ensure that when contracting or subcontracting any part of
its maintenance activities, or when purchasing equipment or services:
These maintenance activities conform to the requirements of Part 145; and
Any aviation safety hazards associated with such contracting, subcontracting or purchase
are considered as part of the organisation’s management system.
If the organisation subcontracts any part of its maintenance activities to another
organisation, the subcontracted organisation shall work under the approval of
the organisation. The organisation shall ensure that the competent authority is
given access to the subcontracted organisation to determine whether there is
continued compliance with the applicable requirements.
11
Module 14
Example of AMO SMS

State Regulation

Article 1. Scope of work.
This resolution affects the approved maintenance organizations for which CAA has
issued the AMO approval, which perform maintenance work for aircraft engaged in
commercial air transport activities.
Article 2. Definition of SMS in maintenance organizations (MOSMS).
The MOSMS framework consists of the components and elements established
below:
1. Safety policy and objectives:
a. Management responsibility and commitment: The maintenance organization will define its safety
policy in accordance with the relevant national and international requirements. The safety policy:
i. It will reflect the commitment of maintenance organizations with respect to safety;
ii. It will include a clear statement about the provision of resources necessary for its implementation;
iii. It will be signed by responsible management personnel belonging to the organization;
iv. It will be documented and communicated, ostensibly supporting the entire organization.
13
The MOSMS framework consists of the components and elements established below
(Cont.):
1. Safety policy and objectives (Cont.):
b. Safety objectives: Taking into account its safety policy, the maintenance organization should
define its safety objectives. The safety objectives must:
i. Be consistent with the security objectives established in the Program;
ii. Serve as a basis for the establishment of safety performance indicators and targets as required in the following
section;
iii. Reflect the organization's commitment to continuously improve the overall performance of the MOSMS;
iv. Document and transmit to the entire organization; and
v. Be reviewed periodically to ensure they remain relevant and appropriate for the maintenance organization.
c. Establishment of safety performance indicators and targets: Maintenance organizations will
establish performance indicators and performance goals for their MOSMS. Safety performance
indicators and targets should:
i. Be consistent with its safety objectives and with performance indicators and performance targets in the area of
safety of the State;
ii. Be appropriate to its specific operational context and the volume and complexity of its activities.
14
(Cont.):
Note 1: Annex 1 of this resolution establishes a list of safety performance indicators that, at a minimum, should be
established by maintenance organizations.
Note 2: Annex 2 of this resolution establishes a non-exhaustive list of safety performance indicators by way of
example that maintenance organizations may use in addition to those set out in Annex 1.
Note 3: The goals will be established in a second phase when, in response to the type of indicator and the period of
capture of the value thereof, statistically significant information has been collected on the behaviour of the
indicators established by the organization. No later than 12 months after the establishment of the indicators.
1. Safety policy and objectives (Cont.):
d. Compliance with safety requirements: Maintenance organizations shall ensure the existence of
adequate procedures to ensure the use of good maintenance practices and the airworthiness of
aircraft and compliance with the safety requirements set out in national and Union regulations.
Applicable European and. Establishment of a plan of actions for the achievement of the
performance goals of the maintenance organization:
The maintenance organizations will establish a plan of actions to achieve the established performance goals.
15
(Cont.):
2. Assessment and control of safety risks (Cont.):
a. Identification and registration of hazards: Continuous surveillance of operations or activities will
be carried out through the establishment of an internal system of notification of events (1),
including safety deviations (2), which allows the collection and evaluation of the same.
(1) Event: any safety-related event that endangers or that, if not corrected or addressed, could endanger an
aircraft, its occupants or any other person, including, in particular, accidents and serious incidents;
(2) Deviations from operational safety: safety events with real consequences of little or no magnitude, which
suppose a separation with respect to established norms, procedures or practices.
b. Risk assessment: Maintenance organizations will develop a procedure to analyze the events
collected in accordance with the previous section, in order to determine the security risks
associated with the events or groups of events observed and recorded.
16
(Cont.):
2. Assessment and control of safety risks (Cont.):
c. Risk control:
i. Based on the analysis established in the previous section, each organization will determine the appropriate
corrective or preventive measures, where appropriate, for the improvement of aviation safety.
ii. When an organization determines the appropriate measures to solve the real or potential air safety
deficiencies:
a) Apply these measures in due time; and
b) Establish a process to monitor the application and the effectiveness of the measures.
d. Quality system: Maintenance organizations will establish a process for the internal management
of safety deviations and for monitoring the application and the effectiveness of the corrective or
preventive measures applied.
17
(Cont.):
This process will be established through a quality system that includes:

i. Independent audits to monitor compliance with the rules applicable to aircraft or elements, that corrective or
preventive measures are adopted within the established period and that there are adequate procedures to
ensure the use of good maintenance practices and the airworthiness of aircraft or elements.
ii. A system for communicating quality information to the person or group of persons specified in section
145.A.30b) of Commission Regulation (EC) No 1321/2014 and ultimately to the responsible manager, to ensure
that appropriate and timely corrective or preventive measures are taken in response to the reports derived from
the established independent audits.
18
(Cont.):
3. Promotion operational safety:
a. Instruction and education: Within the procedure established by the maintenance organization to
control the competence of the personnel participating in any activity related to maintenance,
management or quality audits, specific training on the MOSMS will be included, adding additional
elements to the current one:
i. Knowledge of the relevant parts of the memory and maintenance organization procedures.
ii. Knowledge of the system of notification of events and understanding of the importance of reporting events, incorrect
maintenance data and existing or potential defects.
iii. Knowledge of safety risks related to the work environment.
b. Safety communication: The maintenance organizations will define in their safety policy, duly
documented, the disclosure methods among their employees of:
i. The policy and objectives of operational safety of the MOSMS.
ii. Critical information for safety
19
(Cont.):
4. Continuous improvement:
The maintenance organizations will observe and evaluate the effectiveness of their MOSMS to allow the
continuous improvement of the general performance of the MOSMS through the quality system
described in section 2.d).
20
Appendix 1
List of safety performance indicators that, as a minimum, should be
established by maintenance organizations
Product safety performance indicators (SPI)
Quotient of the number of double inspections that identified a maintenance error per
number of double inspections carried out (3)
Quotient of the number of unsatisfactory functional tests per number of functional tests
performed (4).
Number of events related to maintenance per activity volume (5).
Number of investigations carried out as a result of maintenance events, in which it was
determined that the maintenance personnel involved had a substantial influence on
these events, per number of total events related to maintenance.
21
Appendix 1 (Cont.)
Process Safety Performance Indicators (SPI)
Percentage of implementation of corrective / preventive actions derived from operational
safety deviations.
Appendix 2
Non-exhaustive list of safety performance indicators by way of example that
maintenance organizations may use in addition to those set out in Annex 1
Other product / process indicators in the area of maintenance organizations:
Number of events with ambiguous maintenance data per activity volume (6).
Number of events related to maintenance personnel rotations not performed per activity volume
(4).
Number of events related to maintenance tools per activity volume (4).
Number of events related to the spare parts of the warehouse per activity volume (4).
Number of events related to maintenance records with defects / failures per activity volume (4).
Number of investigations carried out of components removed from service considerably before
reaching their life limit per volume of activity (4).
22
Appendix 2. (Cont.)
Other product / process indicators in the area of maintenance organizations
Analyzed events (performed with risk management) per activity volume (4).
Changes analyzed (performed with risk management) per activity volume (4).
Percentage of personnel that have had training about the equivalent mechanism and in the
report of events.
Security reports received from contractors or related to contractors per contractor.
Security communications published per quarter.
% of work orders for which detailed planning was done
Fatigue of maintenance engineers / maintenance error:
% of work orders with a difference> 10% between the proposed waiting time and the actual
processing time.
% of work orders with a difference> 10% between the estimated workload and actual needs.
Maintenance error:
% of work orders that require re-work.
23
Appendix 2. (Cont.)
Indicators of systemic issues: compliance / audits
Internal audits:
Total number / trend in the audit planning cycle.
% of findings analyzed due to their importance for safety.
Number of significant findings compared to the total number of non-compliances.
Number of repeated findings within the audit planning cycle.
Average waiting time to complete the corrective actions per supervisory - trend planning cycle.
External audits:
Total number / trend in the audit planning cycle.
% of the breaches analyzed due to their importance for safety.
Number of significant non-compliances compared to the total number of non-compliances.
Average waiting time to complete the corrective actions per supervisory - trend planning cycle.
Consistency of results between internal and external audits / compliance control
Number of significant findings discovered only through external audits.
24
Appendix 2. (Cont.)
Indicators of systemic issues: effectiveness of MOSMS
Strategic management:
Level to which operational safety is considered in the official plans of the organization and strategy
documents.
Frequency with which the official plans of the organization and the strategy documents are reviewed with
respect to safety.
Management commitment:
Number of "walk-arounds" of management per month / quarter / year.
Number of management meetings dedicated to safety by month / quarter / year.
Rate of rotation of key safety personnel:
Duration of the mandate.
Number of cases in which the reasons for the departure of key personnel have been analyzed.
Supervision:
Number of cases in which the supervisors expressed positive feedback on the conscious behavior
regarding safety of their personnel to the month / quarter / year.
25
Appendix 2 (Cont.)
Indicators of systemic issues: effectiveness of MOSMS (Cont.)
Notification:
Number of notifications received per month / quarter / year and trend.
% of notifications to which information was provided to the notifier within 10 business days.
% of notifications followed by an independent safety review.
Identification of the hazards:
Number of accident / serious incident scenarios analyzed to support Safety Risk Management (SRM) per
month / quarter / year.
Number of new hazards identified through the internal notification system per month / quarter / year
and trend.
Findings with external audits related to hazards that had not been previously perceived by personnel /
management.
Number of safety notifications received from personnel per month / quarter / year and trend.
26
Appendix 2 (Cont.)
Risk control:
Number of new risk control validated by month / quarter / year.
% of the total budget allocated to new risk controls.
Management and development of human resources competences:
% of the template for which a competency profile has been established.
% of personnel who have had training in security management.
Frequency of review of competency profiles.
Frequency of review of the scope, content and quality of training programs.
Number of changes made to training programs as a result of staff feedback to the month / quarter / year.
Number of changes made to training programs following the analysis of internal safety notifications by
month / quarter / year.
27
Appendix 2 (Cont.)
Change management:
Number of organizational changes for which a formal assessment of safety risks has been performed per
month / quarter / year and the trend.
Number of changes in the Standard Operating Procedures (SOPs) for which a formal assessment of safety
risks has been carried out per month / quarter / year and the trend.
Number of technical changes (for example, new equipment, new installations, new hardware) for which a
formal assessment of safety risks has been carried out per month / quarter / year and the trend.
Number of risk controls implemented by changes to month / quarter / year and trend.
% of changes (organizational / SOP / technical, etc.) that have been subject to risk assessment.
Management of contractors:
% of contractors whose performance in safety matters has been evaluated.
Frequency with which the performance in terms of safety of contractors is determined.
% of contractors integrated into the safety notification system of your company.
% of contractors for whom safety training has been provided.
% of contractors who have implemented training control procedures.
28
Appendix 2 (Cont.)
Management of contractors:
% of contractors that have established an information system (or feedback) on safety issues with their
customers.
Number of safety notifications received from contractors per month / quarter / year and trend.
Number of safety actions initiated due to safety performance evaluation or safety notifications received
per month / quarter / year and trend.
Emergency response planning (ERP):
Number of emergency simulacrums per year.
Frequency of the ERP review.
Number of ERP training courses per month / quarter / year.
% of personnel trained in the ERP within quarter / year.
Number of meetings with the main partners and contractors to coordinate the ERP to the month /
quarter / year.
29
Appendix 2 (Cont.)
Promotion of operational safety:
Number of published safety communications (per month / quarter / year).
Number of courses completed (per month / quarter / year).
Number of safety briefings (or briefings) conducted (per month / quarter / year).
Safety culture:
Level to which the staff considers safety as a value that guides their daily work (for example, on a scale of
1 = low to 5 = high).
Level to which the staff considers that safety is highly valued by their managers.
Level to which the principles of human action are applied.
Level to which staff take initiatives to improve organizational practices or report a problem to
management.
Level to which the conscious behaviour of safety is supported.
Level to which staff and management are aware of the risks of their operations and what they imply for
themselves and for others.
30
NOTES:
(3) Double inspection should be understood as a method of error capture of critical maintenance
tasks. This indicator will be applied to a representative sample of critical maintenance tasks
defined by the organization.
(4) This indicator will be applied to a representative sample of functional tests defined by the
organization.
(5) Each organization will define the exposure unit it deems appropriate to define the volume of
activity (number of inspections, number of tasks, number of maintenance operations, man-hours,
etc.)
(6) Each organization will define the exposure unit it deems appropriate to define the volume of
activity (number of inspections, number of tasks, number of maintenance operations, man-hours,
etc.)
31
Module 14
Example of AMO SMS

State Procedure

Example of AMO SMS State Procedure

PART 145 SMS PROCEDURE
SCOPE.
The purpose of this guide is to develop guidelines for SMS implementation for maintenance
organizations Part 145, which establishes the requirements for the establishment of a MOSMS to
the safety management system by maintenance organizations
INITIAL APPROVAL
Maintenance organizations approved by CAA to which they apply MOSMS must start up the
components and elements corresponding to MOSMS. In addition, the maintenance organization
must document in writing the methodology followed for the implementation and maintenance and
monitoring of the components and elements of the MOSMS.
CONTINUING SURVEILLANCE
The continued monitoring of the MOSMS will be carried out through at least one audit within the
period of biennial continuous monitoring established for the maintenance organization.
The audit will be documented through the corresponding CAA forms for the inspection of
maintenance organizations, including the elements of documentary and physical audit.
33

MOSMS PROCEDURE
The maintenance organization must document in writing the methodology followed for the
implementation and maintenance of the components and elements of the MOSMS. The
organization may choose to:
1.- Develop a particular document of the MOSMS.
2.- Use another manual developed by the organization, in case the organization has already
established a Security Management System (SMS) and has a manual on it. In this case, you must
establish a cross table between the SMS Manual and the elements / components of the MOSMS.
34

1. Policy and objectives Operational Safety - General
1.a Responsibility and commitment of management
The organization must document in writing the safety policy. The organization may choose to
include the safety policy in the safety and quality policy proper to the MOE required by 145.A.65
(a).
The safety policy will be signed by the responsible manager of the organization and will be adjusted
to at least the following:
a) Reflect the organization's commitment to safety
b) It will include a clear statement about the provision of resources necessary for its implementation.
c) Defines disclosure methods among its employees of:
I. MOSMS safety policy and objectives
II. Critical information for safety
In the "Safety Management Manual" (SMM), doc. 9859 of ICAO, an example of a safety policy can
be found.
35
36

1. Policy and objectives Operational Safety – General (Cont.)
1.b Operational safety objectives
The organization must document in writing its safety objectives taking into account that:
a) They must be coherent with the safety objectives;
b) They should serve as a basis for the establishment of safety performance indicators and targets as required in
the following section;
c) They must reflect the commitment of the organization to continuously improve the overall performance of the
MOSMS.
The safety objectives are statements of high level and often of a conceptual nature that identify, in
global and generic terms, what the organization is aimed to achieve in terms of safety
management.
Safety performance goals are parameters that allow measuring, through their values, the
effectiveness and efficiency of the mechanism equivalent to the management system of the
operational safety of maintenance organizations exclusively.
37
1.b Operational safety objectives
Below is a series of objectives that the maintenance organization can use as a reference to establish
its own objectives:
1.- Minimize the contribution of our maintenance activities in the accidents and serious incidents in which the
aircraft under maintenance of the maintenance organization are involved.
2.- Provide appropriate and relevant instructions related to safety management to all personnel of the
organization;
3.- Promote the notification of safety deficiencies, hazards and events among our employees through the
establishment of a Just Culture.
4.- Create channels of dissemination of safety information for all personnel of the organization;
5.- Decrease the number of claims for technical components under warranty
6.- Decrease the rate of major defects (derived from internal quality problems) versus the number of aircraft
maintained.
7.- Reduce the fatigue of maintenance technicians by introducing methods to estimate time and workload
realistically.
8.- Improve work procedures in order to reduce the percentage of work orders that require re-working.
38
1.c Safety performance indicators and targets
The organization shall document in writing the safety performance indicators and targets taking
into account that:
a) They must be coherent with their safety objectives and with safety performance indicators and targets;
b) They must be appropriate to their specific operational context and the volume and complexity of their
activities.
The responsibilities, criteria and procedures for the development and review of performance
indicators and targets for safety should be detailed.
1.d Plan of actions for the achievement of performance goals
The organization shall document in writing the procedure followed for the establishment of an
action plan for the achievement of performance goals.
39
2. Assessment and control of safety risks
2.a Identification and registration of hazards
The maintenance organization will document in writing the hazards identified for the maintenance
organization.
2.b Risk assessment
The organization shall document in writing the responsibilities, criteria and procedure followed for
the analysis of the events collected in order to determine the associated risks.
The procedure may include an analysis in terms of probability and severity of the event, and an
evaluation in terms of tolerability. In these cases, the analysis of the severity of the event must
consider the possible degraded situations in which the aircraft would remain after the release to
service or the failures that may occur in the aircraft as a result of the event.
40
2. Assessment and control of safety risks (Cont.)
2.c Risk control
The organization must document in writing the responsibilities, criteria and procedure followed for
the control of risks, including:
The appropriate corrective or preventive measures
The application of these measures and their follow-up
2.d Quality System
The organization must refer to the section of the corresponding MOE to follow up on this MOSMS
procedure.
41
3. Promotion of Operational Safety
3.a Training
The organization must document in writing the procedure followed to ensure that the
establishment and control of the personnel competence required by 145.A.30 (e) includes specific
training about the MOSMS.
3.b Safety promotion
The organization shall document in writing the procedure to convey the operational safety to the
organisation staff.
4. Continuous improvement
The organization must document in writing the procedure followed to observe the
effectiveness of the MOSMS. Reference may be made to the corresponding section of
the MOE, indicating that the planning of internal audits includes the verification of the
MOSMS elements.
42
Doubts ?
43
End of Module 14
AMO SAFETY MANAGEMENT
Thank you very much for your attention
www.eu-sea-app.org
easa.europa.eu/connect
Your safety is our mission.

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AIRWORTHINESS INSPECTOR TRAINING

MODULE 14. AMO Safety Management

SALVADOR ALEPUZ ROMAGUERA

Bangkok (Thailand), October 7th – 18th, 2019)

EU-South East Asia Aviation Partnership Project (EU-SEA APP)

ICAO & EASA

An Agency of the European Union 2

Annex 6, Part I, Chapter 8, requires States, as part of their State safety

Example of AMO SMS

An Agency of the European Union 12

1. Safety policy and objectives (Cont.):

This process will be established through a quality system that includes:

Example of AMO SMS

An Agency of the European Union 32

Example of AMO SMS State Procedure

Example of AMO SMS State Procedure

Example of AMO SMS State Procedure

Example of AMO SMS State Procedure

Thank you very much for your attention

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