Implementing Safety Training in Part 21 organisations
Author: Kevin Hopwood, Principal Consultant
In today’s aviation environment we are surrounded by not just complex regulations but impacted by tragic events that have caused and will continue to cause heartbreak to many people around the globe. And yet whilst our industry is suffering on a scale not seen since the impact of the ghastly terror attack on 9/11, we are rightly still subjected to external authority oversight and internal assurance activities.
Whilst EASA have been providing valuable guidance around operating within the Covid 19 environment they continue to work with the EU Commission to amend existing regulations along with the associated AMC/GM. In addition, they are also required to control the regulatory amendment process.
These changes are aimed at improving the safety of aircraft operations and impact not just the operators but those organisations who contribute to the safety of the operator and currently the public.
We are all aware (or should be) that it’s EASA’s intent to update the Certification Regulation 748/2012 (as amended) and Continuing Airworthiness Regulation 2018/1139 (as amended – for 145 organisations/Part M has been addressed). The aim of the NPA is to introduce safety management principles that implement ICAO Annex 19 and to foster an organisational culture for effective safety management and effective occurrence reporting in accordance with Commission Regulation (EU) No 376/2014. This blog focuses on the initial airworthiness aspect and therefore EASA NPA 2019/05(B).
The NPA is aiming to introduce several significant changes to the regulation, many of which will lead to meaningful changes within both Design and Production organisations. One key area of change is defined in the NPA noticeably 21.A.139 (c)5 & 21.A.239 (c)5 which are aimed at Promoting Safety in the organisation through training, education, and communication. Whilst the associated AMC/GM further defines the intent of the regulation the whole concept of safety simply cannot be defined in one simple regulatory sentence, paragraph or clause as the whole suite of regulations exist to capture the safety concept. Therefore, organisations will need to take time to think about the intent of the regulation and its impact on them. Organisations will need to piece the jigsaw together so that they can appreciate the intent of the new directions that EASA are aiming to implement in order to meet the intent of ICAO Annex 19 and 376/2014.
These new requirements mandate that approved organisations implement Safety Training programmes to:
- Support safety management policies and processes, including human factors training; and
- Ensure that personnel at all levels of the organisation develop and maintain their competency to fulfil their safety roles.
The requirements define that each organisation should adapt the syllabus to its own needs and that at least the following items should be included:
- The organisational roles and responsibilities related to safety, including the hazard identification and risk management processes, and to fostering a positive safety culture
- Safety objectives and the associated safety performance indicators
- Human factors principles, including human performance and limitations
- Legislation, where applicable
Therefore, to meet the intent of this each organisation should complete a Training Needs Analysis (TNA) to ensure that their training is customised for their people and be able to demonstrate how the TNA was completed.
The purpose of the recurrent safety training is:
- Primarily to ensure that staff remain current, notably on changes to SMS principles, processes and procedures; and
- Also, to share feedback on safety issues that are relevant to the organisation or lessons learned.
Training is paramount in providing personnel with knowledge, which in turn can increase output and give personnel a feeling of ‘being wanted’. No doubt there will be many organisations who will believe that completing TNA’s will provide minimal benefit, however in times like these it’s important that organisations understand that there can be immense value of the TNA led approach. Let’s embrace the intent of the regulation, it demands organisations be proactive, to improve the competence of personnel. The organisation’s management system not only contains processes and procedures, it contains people, and it is the human and management system performance that is being targeted through this NPA; together they should be complementing each other. We all know that the human form is made largely of water and water always finds the easiest route to its destination, so be proactive and make sure your people understand they are a vital cog in your organisation as their behaviours have an extraordinary impact on organisational compliance and ultimately safety performance.
Whilst the above concepts may be new learning for some personnel within our industry, I am quite confident in stating that nothing is new. For many years accidents and incidents have been occurring and, not surprisingly, they are simply re-incarnations of previous events so you may ask ‘Have we learned lessons?’
Many of you will say we have, others may disagree, but one thing is for certain and for that we need to go back to previous points in time to truly appreciate missed opportunities.
In May 2008, the JAA Human Factors Working Group released their report.
The report focussed on the impact of human factors in the maintenance environment and produced several well thought out findings and concepts that would provide a bedrock for changes to JAR 145. For many years I have examined the report and when I sit and spent those quiet moments analysing the content, I find that many of them are applicable to those organisations that exist in the ‘initial airworthiness’ domain and I, like others, am surprised it has taken such a period of time for this to be implemented.
Whilst many of us working from home think about how good our organisations are, the question I pose to you all is ‘Did the organisations really grasp the intent of the report, did the regulators understand its intent and complete oversight of the approved organisations with that in mind?’
So, let us not waste this opportunity again, lets embrace compliance, and visualise the intent of NPA2019/05 around the Safety Training requirements (plus every other requirement) and as a result improve business and safety performance.
Remember, know your people, trust your people, empower your people, train your people – they are vital to the success of your management system. So, engage your organisational corporate memory and, as the Roman Poet Horace stated, ‘Carpe Diem’.