1. Gdansk International Air & Space Law Conference November 2013 Authority and Organisation Requirements “effective management systems for authorities and organisations” John Vincent Deputy Director for Strategic Safety

2. 2 Introduction – ICAO Annex 19 Safety Oversight (Authority) Safety Oversight (Authority) SMS (Service Providers) SMS (Service Providers) State’s Safety Programme (SSP) (SSP) Safety data collection, analysis and exchange

3. Introduction Safety Management is done at various levels. ICF November 20133

4. Implementing Rule AR: Authority Requirements Subpart GEN: general requirements Subpart XXX: Specific, additional requirements OR: Organisation Requirements Subpart GEN: general requirements Subpart XXX: Specific, additional requirements Technical Requirements Subpart ABC Subpart DEF EASA Rule structure – general approach 4 AMCs & GM SSPSMS ICF November 2013

5. ARs & ORs: Regulatory references access: http://easa.europa.eu/regulations/regulations-structure.php Implementing Rulesrelated AMCs & GM amending Reg. (EU) No 290/2012 * to Reg. (EU) 1178/2011 FCL – MED – CC – ARs & ORs for Air Crew (FC & CC) ARA: Decision 2012/006/R* Subpart GEN ORA: Decision 2012/007/R* Subpart GEN Regulation (EU) No 965/2012, as last amended by Reg. 800/2013* Air Operations Commercial Air Transport, Non-commercial CMPA Non-commercial other than CMPA ARO: Decision 2012/016/R* Subpart GEN ORO: Decision 2012/017/R * Subpart GEN 5 * Subparts GEN of the Authority and Organisation Requirements respectively are fully aligned. ICF November 2013

6. Implementing Rule AR: Authority Requirements Subpart GEN: general requirements Subpart XXX: Specific, additional requirements OR: Organisation Requirements Subpart GEN: general requirements Subpart XXX: Specific, additional requirements Technical Requirements Subpart ABC Subpart DEF Authority Requirements 6 AMCs & GM SSPSMS ICF November 2013

7. Authority Requirements & SSP 7 ARs do not explicitly refer to SSP ARs support implementation of EASP/SSP, in particular by focussing on the critical elements of an oversight system: CE-3: State civil aviation system and safety oversight functions CE-4: Technical personnel qualification and training CE-5: Technical guidance, tools and the provision of safety-critical information CE-6: Licensing, certification, authorisation and/or approval obligations CE-7: Surveillance obligations CE-8: Resolution of safety concerns. ICF November 2013

8. 8 ARs supporting SSP implementation dedicated Section: MANAGEMENT SYSTEM ARX.GEN.200 Competent Authorities to establish management systems including: Internal audit & safety risk management ARX.GEN.205 Procedures for allocation of tasks to qualified entities: control of ‘contractors’ ARX.GEN.210 Management of changes in the management system and information to the Agency ARX.GEN.220 Record keeping requirements: Storage, accessibility and traceability Register of approved organisations March 16

9. 9 ARs supporting SSP implementation OVERSIGHT, CERTIFICATION, ENFORCEMENT ARX.GEN.300(c) The scope of oversight shall consider safety priorities (as per SSP – EASP) ARX.GEN.300(d) Oversight shall not be limited to the organisations the authority has certified – link with safety priorities ARX.GEN.300(e) Authorities may agree to share audits when the activity of an organisation involves more than one Member State ARX.GEN.300 (c) The 24-month oversight cycle to be extended (max: 48 months) or reduced depending on the safety performance of the organisation ARX.GEN.330 Changes to the organisation: The scope of changes not requiring prior authority approval will depend on the maturity of the organisation’s management system March 16

10. 10 OVERSIGHT: consider Risk & Performance March 16 Significant Risks identified Prioritisation of oversight Occurrences Audit & inspection results EASpEtc…

11. 11 OVERSIGHT: consider Risk & Performance March 16 Significant Risks identified Prioritisation of oversight Safety performance/maturity of the organisation Audit programme (frequency) Audit programme (depth) Mgt. of changes Inputs (occurrences etc…) It is all about monitoring and managing safety performance

12. 12 Authority Requirements - Key points Common, generally applicable requirements adopted for Aircrew and Air Operations set the standard for other areas Authority Requirements mirror relevant organisation requirements require a management system for competent authorities support the implementation of EASP without explicitly regulating SSP aim towards enhanced efficiency: optimal use of authority resources cooperation / exchange of information between authorities & with the Agency risk & performance based oversight Existing rules will be aligned with these Part-ARX requirements ICF November 2013

13. Implementing Rule AR: Authority Requirements Subpart GEN: general requirements Subpart XXX: Specific, additional requirements OR: Organisation Requirements Subpart GEN: general requirements Subpart XXX: Specific, additional requirements Technical Requirements Subpart ABC Subpart DEF Organisation Requirements 13 AMCs & GM SSPSMS ICF November 2013

14. SMS./. Management system 14 There is no requirement to implement an SMS, but a requirement to implement a management system with specific features. This is aligned with the essential requirements of the Basic Regulation (see Annex I Art. 3.a.2). ‘The organisation must implement and maintain a management system to ensure compliance … and aim for continuous improvement of the system.’ Existing management systems within the scope of Reg. (EC) 2042/2003 mainly focus on compliance (quality system) ICF November 2013

15. Organisation Requirements - SMS EASA approach – main features Same general management system features for all approved organisations, with the same core requirements Total system approach A holistic approach to management will result in more effective operations and safety management. Integrated approach The management system shall correspond to the size, nature and complexity of the organisation. Proportionality Allow the use of alternative means of compliance by placing implementation aspects at AMC level. Flexibility Authority and Organisation Requirements 15ICF November 2013

16. Existing management system & SMS 16 Management System Compliance monitoring Documentatio n & records Human Resources FacilitiesContracting Finance & Budget SMS Safety Policy and Objectives Safety Risk Management Safety Assurance Safety Promotion ICF November 2013

17. Integrated approach to management 17 Management System Finance & Budget Safety policy and objectives Safety risk management Compliance monitoring Safety Assurance Doc. & records Human Resources Safety Promotion & Training Facilities Contracting ICF November 2013

18. Part-ORX Subpart GEN Section II “Management System” Paragraph Title ORX.GEN.200 Management system ORX.GEN.205 Contracted activities ORX.GEN.210 Personnel requirements ORX.GEN.215 Facility requirements ORX.GEN.220 Record-keeping 18ICF November 2013

19. “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 associated risks inherent in these activities.” 19 Management System requirements core elements ICF November 2013 clearly defined lines of responsibility and accountability safety policy identification of aviation safety hazards evaluation and the management of associated risks, mitigate the risk and verify effectiveness; maintaining personnel trained and competent management system documentation

20. From ‘Quality system’ to ‘Management system’: Some new obligations for the organisation: (1) Review the safety policy to ensure it addresses all new elements related to safety management. (2) Identify a person who will fulfil the role of safety manager (3) Establish a Safety Review Board (complex organisations) (4) Implement the new safety management processes: hazard identification, risk assessment and mitigation, performance monitoring, etc…. (5) Document the new safety management processes. (6) Extend the scope of internal auditing to the new processes. (7) Keep records of the output of those new processes. (8) Plan for emergencies « Emergency Response Planning ». 20ICF November 2013

21. 21 Organisation Requirements - Key points SMS is addressed as part of the Section A Organisation Requirements in a dedicated rule § ‘Management System’ and related AMCs/GM. These organisation requirements: build upon the existing quality system provisions address all elements of the ICAO SMS framework are compatible with existing management systems They ‘set the standard” for implementing SMS in the other areas within the Agency’s remit. total system approach encourage integrated management provide flexibility & proportionality ICF November 2013

22. Thank you for your attention! Questions?