Update on RMT.0251 (MDM.055)‘Embodiment of SMS into Regulation 1321/2014’

PHASE I

Opinion 06/2016 ‘Part-CAMO’

E&M Sub-SSCC meeting 11 May 2016

This Opinion introduces safety management in continuingairworthiness management through the creation of a newAnnex Vc ‘Part-CAMO’ to Regulation 1321/2014.

This Opinion also proposes amendments to other Partsresulting from changes proposed with Opinion 05/2016 ‘Taskforce for the review of Part-M for General Aviation Phase II’and from the new Part-CAMO:

Part-M, Part-145, Part-T,

Part-21.

The Opinion prepares the ground for allowing licensed aircarriers to contract a CAMO (objective of RMT.0209 (M.014)).

Opinion 06/2016

E&M Sub-SSCC11 May 2016 2

E&M Sub-SSCC11 May 2016 3

Opinion 06/2016 ‘Part-CAMO’

for continuing airworthiness management of aircraft

•operated by licenced air carriers and/or

•CMPA (twin-turboprops < 5700 kg MTOM ‘exempted’)

CAMOs in this segment represent an estimated 65 % of all currently approved EASA CAMOs.

In Phase I only Part-CAMO will have SMS requirements (not Part-CAO, nor Part-145).

Part-CAMO can also be used for CAM of aircraft other than those operated by licenced air carriers and/or CMPA.

Some statistics

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~ 1240 CAMOs hold EASA approvals in addition to their Part-M/G approval with about 1010 of those being licenced air carriers

~ 736 CAMOs are only approved for aircraft up to 5.7 t MTOM

~ 750 CAMOs are not approved to any other EASA Part (‘stand-alone’ CAMOs)

Part-CAMO Section AOrganisation Requirements

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CAMO.A.1 GeneralGeneral requirements CAMO.A.005 ScopeCAMO.A.105 Competent authorityCAMO.A.115 Application for an organisation certificateCAMO.A.120 Means of complianceCAMO.A.125 Terms of approval and privileges CAMO.A.130 Changes to the organisationCAMO.A.135 Continued validityCAMO.A.140 AccessCAMO.A.150 FindingsCAMO.A.155 Immediate reaction to a safety problemCAMO.A.160 Occurrence reporting

ManagementCAMO.A.200 Management systemCAMO.A.205 Contracting and subcontractingCAMO.A.210 Internal safety reporting schemeCAMO.A.215 FacilitiesCAMO.A.220 Record keeping

CAMO specific requirementsCAMO.A.300 Continuing aw management expositionCAMO.A.305 Personnel requirementsCAMO.A.310 Qualification of airworthiness review staffCAMO.A.315 Continuing airworthiness managementCAMO.A.320 Airworthiness reviewCAMO.A.325 Continuing airworthiness management data

ORX.GEN

Section 1

ORX.GEN

Section 2

CAMO

specific

Part-CAMO Section BAuthority Requirements

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General requirementsCAMO.B.005 ScopeCAMO.B.115 Oversight documentationCAMO.B.120 Means of complianceCAMO.B.125 Information to the AgencyCAMO.B.135 Immediate reaction to a safety problem

ManagementCAMO.B.200 Management systemCAMO.B.205 Allocation of tasks to qualified entities CAMO.B.210 Changes in the management system CAMO.B.220 Record keeping

Oversight CAMO.B.300 Oversight principlesCAMO.B.305 Oversight programmeCAMO.B.310 Initial certification procedureCAMO.B.330 ChangesCAMO.B.350 Findings and corrective actionsCAMO.B.355 Suspension, limitation and revocation

ARX.GEN

Section 1

ARX.GEN

Section 2

ARX.GEN

Section 3

Part-CAMO Section AOrganisation Requirements

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General requirements CAMO.A.005 ScopeCAMO.A.105 Competent authorityCAMO.A.115 Application for an organisation certificateCAMO.A.120 Means of complianceCAMO.A.125 Terms of approval and privileges CAMO.A.130 Changes to the organisationCAMO.A.135 Continued validityCAMO.A.140 AccessCAMO.A.150 FindingsCAMO.A.155 Immediate reaction to a safety problemCAMO.A.160 Occurrence reporting

ManagementCAMO.A.200 Management systemCAMO.A.210 Internal safety reporting schemeCAMO.A.215 FacilitiesCAMO.A.220 Record keeping

CAMO specific requirementsCAMO.A.300 Continuing aw management expositionCAMO.A.305 Personnel requirementsCAMO.A.310 Qualification of airworthiness review staffCAMO.A.315 Continuing airworthiness managementCAMO.A.320 Airworthiness reviewCAMO.A.325 Continuing airworthiness management data

from Quality system to Management system

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M.A.712 Quality system or organisational review

Main focus:

monitoring compliance

In case of licensed air carriers the quality system shall be an integralpart of the operator’s qualitysystem

CAMO.A.200 Management system

(CAMO.A.205/210/215/220)

Main focus:

managing safety risks

monitoring compliance

In case of licensed air carriers the management system shall be an integralpart of the operator’s management system

No organisational review – CM functionrequired in all cases !

Part-M Subpart G organisation approvals issued before (date of entry into force of Part-CAMO) shall be deemed to have been issued in accordance with Part-CAMO, with two years to correct any findings (cf. Opinion – Cover Regulation Article 4).

Organisational review for smallCAMOs, a/c < 2730 kg, balloons

Typical risk areas for CAMOs

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PERFORMANCE-INFLUENCING FACTORS: causing failure in the CAMO airworthiness management functions

CAMO HUMAN–SYSTEM INTERFACE: addressing the specific use of IT systems for the management of airworthiness as related to planning, scheduling, AD compliance, recording of changes and repairs, etc….

ORGANISATION INTERFACES: addressing the need to manage the risks associated with intra- and inter-organisation communication and integration of reporting and error management systems

AIRWORTHINESS MANAGEMENT ENVIRONMENT: ensuring that the CAMO creates a working environment that allows proper airworthiness management

ORGANISATIONAL FACTORS: CAMO placing inappropriate demands or undue pressure on its own or contracted maintenance provider(s) thus increasing the likelihood of errors

Changes required to comply with the new Part-CAMO (1/2)

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Nomination of a person or group of persons fulfilling the role of safety manager

• No overly prescriptive qualification and experience requirements are included for this position

Documented processes for hazard identification

Processes for safety risk assessment, analysis, including incident investigation, risk mitigation and follow-up of actions

Implementation of an internal safety reporting scheme

Safety action planning, including the establishment of a safety review board (SRB), composed of line managers, the accountable manager and the safety

manager

Changes required to comply with the new Part-CAMO (2/2)

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Safety performance monitoring to ensure that safety objectives are met

Emergency Response Planning

a system to plan the availability of staff

a process for the management of change, in particular to manage related risks, making use of the established safety risk management processes

Safety training, including Human Factors training and safety promotion

• No overly prescriptive training requirements are included - most of such training could be provided making use of resources already available

within the organisation.

Management system record keeping

Key Points

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SMS is addressed as part of the new Part-CAMO Organisation Requirements and related AMCs/GM (CAMO.A.200 series)

Part-CAMO will be required for continuing airworthiness management of

•Aircraft used by licensed air carriers

•CMPA (except for twin-turboprops < 5700 kg MTOM)

Part-CAMO organisation requirements

•build upon the existing quality system provisions

•cover all elements of the ICAO Annex 19 SMS framework (and more)

•are compatible with existing management systems (e.g. ISO 9001/EN9100)

•encourage integrated management (aligned with Parts ORA/ORO)

•provide flexibility & proportionality (details in AMCs)

RMT MDM.055PHASE I

Questions?

There are no ICAO SARPs considering a dedicated organisation approval for continuing airworthiness management.

For certified operators of aeroplanes or helicopters authorised to conduct international CAT i.a.w. Annex 6 Part I or Part III this activity is considered part the operator responsibilities.

Part-CAMO & Annex 19

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The Opinion will ensure partial compliance with ICAO Annex 19 in relation toStandard 4.1.2: ‘The SMS of a certified operator of aeroplanes or helicoptersauthorised to conduct international CAT iaw Annex 6 Part I or Part III shall bemade acceptable to the State of the Operator.‘

Safety Management

Certified operators in international CAT (other than by licensed air carriers) witha/c other than CMPA would not be fully ICAO Annex 19 compliant (not manycases considering EASA OPS rules).