The ICAO Annex 19 Safety Management System approach has been released against Part 21 legalisation. The aim of such, is to recognise the limitations of human and organisational performance. EU Decision updated Part 21 in March 2022 proposing the newly adopted Design/Production Management System (21.A.139 / 21.A.239). Kevin Hopwood outlines the proposed guidance in his blog “Implementing Safety Training in Part 21 Organisations”. Now the regulation has been published (industry still awaits the associate AMC and GM), Baines Simmons wanted to proactively seek out and asses what questions industry are having.
Initial Airworthiness consultant Jack Coleman visited a TS01 (Management Systems – Safety Responsibilities) course being delivered in the first quarter of 2022 to a large Design Organisation’s (DO) senior management team (this DO has multiple civil and military organisation approvals), in an effort to gauge industry demands, questions, and challenges pertinent to these new regulations.
This client, a long-standing customer of Baines Simmons, endorse and practise the ‘blue line’ behaviour which allows the organisation to perform, rather than just be compliant. By attending a TS01 course, they are pro-actively acting on the recent Part 21 update, to assist their Part 21J employees to understand the concept of Safety Management Systems (SMS).
Upon initial introduction of both delegates and consultants, the conversation quickly outlined three key areas of discussion for the Management System approach into a Part 21 specific classroom:
- “What does it mean for me?” - a question posed from one Head of Design Organisation (HoD)
- “What do we need to be looking at from a Part 21J perspective?” - a question posed from another HoD (this organisation has one for each aircraft type, and for civil and military DOA)
- “How big is this organisational change?” – a question from a senior engineer
With the introduction of the Safety Management element into the Design Management System (21.A.239(b)), the impression from the HoD was that they were cautious of the additional responsibility required on top of product specific risk and current design assurance obligations. Who is “accountable” for the safety management system pertinent to the Part 21J organisation? Whilst the regulation states “…direct accountability of a single manager…”, this easily points towards the HoD. Within a larger organisation, this could facilitated by the current Safety Manager – currently orchestrating safety amongst other approvals (Air Ops, and Part CAMO for example) – with the HoD indirectly reporting into them. But for smaller organisations, where resource and staff are fewer, this may still fall to the HoD. Thus, increasing the workload of the role, and introducing a potential human factors risk, a prime example of the organisational risks that Part 21 organisations now need to consider.
With the Acceptable Means of Compliance (AMC) and Guidance Material (GM) still in progress, these industry questions could propagate the conversion of changes to the roles and responsibilities within Part 21 organisations. In large organisations, a Safety Manager, integrated as part of the Design / Production Management System, could be separate to the HoD and Head of Independent System Monitor (HISM), but still incorporated so that the HoD maintains visibility. Could the Chief of Office of Airworthiness take more responsibility of the product risk, whereas the HoD focus more of the organisational risk? These questions generated fantastic discussions within the multiple approval organisation who are interpreting this new way of thinking. This is where a fully integrated management system could propel large organisation’s safety control. But the accountability question is still very pertinent to smaller organisations. No matter how, these new responsibilities could expand job roles significantly and resources must be carefully allocated to ensure workload is suitably controlled and supervised.
Mandated by 376/2014, internal reporting is applicable to Part 21J and 21G organisations. From the perspective of Part 21 organisations, one could argue that the Voluntary Occurrence Reporting (VOR), accompanying the well-practised Mandatory Occurrence Reporting (MOR) is long overdue. The VOR construct is new to the Part 21 environment. MOR of design and production has been well practised – via the legacy 21.A.3A regulation (malfunctions and defects). However, with the introduction of a management system, Part 21 organisations can now opt to voluntarily disclose their occurrence to the agency if the organisations determines that wider industry lessons could be learnt
But what should Part 21 organisations look for? The difference here is that Part 21 personnel need to consider the risks away from the customary product risk, i.e. the risk associated with designing a specific change or repair, or producing a component under Subpart G approval, to now assessing organisational risk. An example in class with the client was fatigue of a Compliance Verification Engineer (CVE) due to workload, or the night shift overrunning due to production demand of a machine operator. This approach is now looking wider than the specific product risk. This workshop style really helped contextualise the safety message to the Part 21 cohort.
Want to know how organisations can enable their CVEs? Refer to our civil and military CVE course, and more on the roles and responsibilities of CVEs.
EASA eloquently put this in their 2018 DOA workshop, “we are very good at the 10% (product risk), this change focuses on the 90% (organisational risk)”. The recent pandemic has made us realise that external factors can drastically introduce risk into an organisation and to all personnel (most notably key safety personnel) that can potentially affect design and production outputs. This relationship between safety management and organisational performance is further explored in a white paper produced by Duane Kritzinger; “The Integration of Safety Management and Organisational Performance”.
What was comforting to the “blue line” organisation, with open-minded employees, was that the client already facilitates the management system approach, and fulfils some of the elements described within the revised 21.A.139/239. The task now is for the organisation to link these together in the structure required to be shown by the regulator and prove that this system is established, implemented, and maintained. Occurrence reporting, safety promotion (training and communication), and safety assurance are well rehearsed. It was observed that the Safety Risk Management (SRM) was a novel concept and one that was a ‘lightbulb moment’ when described within TS01. The “Effective Operation” model seen within the TS01 course really highlighted to delegates where and how SRM can integrate into the DMS processes.
Despite being a UK Health and Safety based term, ALARP (As Low AS Reasonably Practicable), referenced in Air Operations, presented a new insight to the organisation. ‘Filling the ALARP flask’ focuses on all factors affecting risk, from regulatory compliance, to industry best practise, to then quantitative and qualitative assessment, the in-class relation to design activities provoked a strong conversation peer-to-peer, and allowed departments to appreciate the risk levels they often work with. It can be argued that product risk is always being managed, controlled, and measured as part of the compliance verification activity, in testing as an example. But too much control can often stifle innovation, which allows Design Organisation Approvals (DOAs) to produce their market leading outputs. Managing this optimisation is a topic we discuss within our TR24 M01 course.
In summary, the delegates felt that the TS01 course really challenged their own way of thinking and their perspectives of safety. The Part 21 community will take time to adapt to this new system, but with the help of our consultants and using the spine of the SMARRT MAP this client felt happy they had additional tools and thoughts to take steps further up the “blue line” and challenge their own processes and methods. We appreciate that, for Part 21 organisations, taking a step away from product risk, and recognising how great an impact organisational risk can have, is novel. But with our tools and expertise, we maintain our emphasis on the safety of our client’s products so we can continue to make our skies safer.
For more information on how you can enable your organisation to perform, get in touch with the Baines Simmons team.