In leveraging the programs of the United Kingdom and Canada, the Australian government's Civil Aviation Safety Authority has published an advisory circular on the implementation of safety management systems for approved maintenance organizations, which is wrought with bureaucracy and added regulatory burden. (Draft AC 145-1(0))
This draft advisory circular provides guidance on the practical application of the regulations pertaining to safety management systems and provides examples of SMS processes suitable for organisations operating under Part 145 of the Civil Aviation Safety Regulations 1998. An aircraft maintenance provider seeking to become an approved maintenance organisation (AMO) under Part 145 of the CASR 1998 can utilise the guidance provided by this AC in developing its SMS.
While the advisory circular is a very well written document and likely appropriate for a very large, corporate-owned maintenance organization supporting a large air carrier, the 62-page document is excessive for medium and small AMOs. And, while the AC attempts in numerous places to state that an AMO's SMS program should be scalable, the "required elements" contained in the following sections make the likelihood of over regulating SMS a likely reality.
- SMS requirement.
- Safety policy and management systems.
- Safety and risk management plan.
- Safety assurance system.
- Safety training and promotion.
- Internal reporting and associated investigative processes.
- Appendix 1 - Benefits of a safety management system.
- Appendix 2 - Appointments for SMS responsibilities.
- Appendix 3 - SMS design and documentation - SMS Manual.
- Appendix 4 - SMS integration and implementation considerations.
- Appendix 5 - SMS checklist summary.
The AEA values the benefit of system safety and the methodology that SMS can bring into an aviation business. However, the modeling of the CASA SMS program after the Canadian model, which currently is ONLY applicable to the AMOs in support of scheduled air carriers, and the United Kingdom model--which has been delayed once again--while ICAO is still in development of standards and recommended practices for approved maintenance organizations, is unrealistic.
The arbitrary inclusion of items in the SMS program that (1) are not directly associated with aviation safety and (2) are not required by regulation is a blatant attempt to bypass the legal due process of rulemaking: something industry has feared of the SMS programs, which CASA has just confirmed.
The Association encourages the membership to read the advisory circular and submit comments to CASA no later than 7 June 2012.
The AEA does have an SMS solution that meets the criterion of ICAO without the excessive administrative burden contained in this draft AC. We will continue to work with CASA for acceptance of our program. The program will be briefed, and enrollment in the program will begin, at the AEA South Pacific Regional Meeting on 12-14 November, 2012.
FOR MORE INFORMATION:
Contact Ric Peri, vice president of government & industry affairs for AEA, by email at firstname.lastname@example.org or by phone at 202-589-1144.