Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B
EASA.2009.OP.21
standard performance and their implications for the management system, and rectify
situations involving below standard performance identified through safety assurance
activities. The changes should be tracked to ensure that they are effective.
b. Continuous improvement should be achieved through proactive evaluation of:
i. facilities, equipment, documentation and procedures through safety audits
and surveys;
ii. Individual performance to verify the fulfilment of their safety responsibilities;
and
iii. reactive evaluations in order to verify the effectiveness of the system for
control and mitigation of risk.
Introduces ICAO SMS SARPS.
1.a Highlights the need to ensure operators are encouraging and providing the means for
service providers to collect and supply safety data concerning human factors, and
organisational factors within their own organisation. Linking this to the operator’s de-icing /
anti-icing policy/programme will highlight the need.
2.b A nominated post-holder may be the person responsible to make the decision to either
take mitigating measures or not, however, they will need to consult an expert on the subject
of de-icing / anti-icing. The safety manager may not be suitably qualified or experienced, and
therefore requiring the operator to nominate a subject-matter-expert will resolve this.
3.a Human slips, errors and deviations made by service provider personnel are not required
to be reported, let alone investigated. Mandatory occurrence reporting schemes tend to
control the focus of some operators; however, under the auspices of a performance-driven
regulation, such as SMS, the requirement to go beyond MORs is clear.
4.a Encouraging operators to include safety objectives within their de-icing / anti-icing policy
should drive the need to collect data in order to measure performance. Such performance
initially may revolve around increasing reports from service providers from zero in some
cases to what they would be expected to be. (Quote Kevan Baines of Baines-Simmons:
when speaking about maintenance organisations at an IFA conference 22 Sep at Gatwick,
he said “they should be receiving on average 2 human factors reports per person per year,
because that’s what airlines get from their pilots”. This need may be met through AMC to
OR.GEN.205 Contracting and Purchasing, shown below.
5.a Highlights the need to assess new providers for safety performance before, or when new
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