Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B <strong>EASA</strong>.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 airsight GmbH - 38 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B <strong>EASA</strong>.2009.OP.21 contracts are signed. 6. Extends the activities of the Quality/Compliance System to assessing a service provider’s own safety management system. Operators could be required, through their de-icing / anti-icing programmes to actively encourage service providers to provide them with human factors and occurrence reports (or summary analyses); this will help operators comply with the SMS requirements and also to understand where the greatest risk exists. A subject-matter-expert could be nominated by an operator to provide advice to the safety manager concerning risk reduction measures and risk analysis. Across Europe there is almost a complete lack of the gathering and dissemination of de-icing / anti-icing safety; a centrally-driven and facilitated safety initiative, including survey, would provide a suitable kick-start. Operators can be encouraged to set safety objectives within their de-icing / anti-icing programmes. New contracts with new or existing service providers can be accompanied by a safety assessment. Ensuring that the SMS requirements are met and followed in the area of de-icing / anti-icing will have a positive effect on identifying currently unknown hazards and reducing risk. Providing motivation and guidance for operators to accomplish this and bring about a culture change within service providers will help to make this more successful. NB: The collection of safety data by service providers and the presentation of this data to operators may require a universal system. Either many operators collect all the data from a service provider and they each conduct analyses, which is a duplication of effort; or each operator is only presented with safety data specific to them, which will “hide” other precursors from their view. A third system would be for service providers to supply safety data to a central organisation for analysis and the results then distributed universally and used to improve safety. Such a system could operate voluntarily, therefore requiring a coordinating body for all service providers; or it could operate through the requirements of operators as a condition of contract. The benefits to the Industry of a centralised system is that it can be extended to other unregulated areas where safety data is scarce. AMC 2 to OR.GEN.200(a)(3) Management System airsight GmbH - 39 -
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Interim Report - Introduction - EASA

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