Part-CAMO and the Management of Safety
Author: John Elkin, Consultant
Currently the hot topic in the Continuing Airworthiness community is the requirement to move to Part-CAMO and introduce a management system. Among other tasks this brings the need to have a Safety Policy and an individual or team to develop, administer and maintain an effective safety management process.
So, what does this mean? Do you need to appoint a Safety Manager? What does a compliant and, more importantly, effective Safety Policy look like? How long do you have to make the switch to Part-CAMO?
Let’s explore beyond what the regulation says and look at its intent.
The Continuing Airworthiness Regulation (EU)1321/2014 has been amended by the adoption of Opinion 06/2016 which introduces the concept of safety management into Part-M, specifically Part-CAMO which replaces sub Part-G. The changes to the regulation were published in Jul 2019 but at the time of writing (Jan 2020) the AMC and GM is eagerly awaited across industry.
Key points to consider in the meantime.
Although safety management is a familiar term, what does it mean to those organisations affected by this change?
The intention is to encourage organisations to embed safety management along with risk-based decision making across all activities, rather than having a multi-layer complexity of system upon system.
If you are familiar with other regulatory areas, you’ll see the wording in CAMO.A.200 ‘Management system’ closely mirrors the same .200 sections in ORO.Gen and Part-21. The anticipated change to Part-145 (see NPA 2019-05) is likely to be very similar, bringing in another .200 regulation.
By harmonising and standardising the management of safety in your CAMO with the other functional areas of aviation, the aim is to enhance safety through the establishment of a safety system with suitable policies and realistic, meaningful targets; together with the appropriate resource to support this. Safety performance, reporting, assurance and the right safety culture are key enablers in this. Under the new regulation the Accountable Manager is obliged to “establish and promote the safety policy”, similar to the current requirements under Part-145.
In turn, getting this right for your organisation will make it easier to manage the systematic identification of hazards as well as manage risk efficiently and effectively. This should form the bulk of how you choose to manage safety and, rather than being a ‘tick-box’ compliance activity, it can help you develop a performing CAMO.
What do you need to do?
Managing safety should not be considered a bolt-on extra. Through a more focused approach to how safety is managed you can continue with business as usual and achieve a safer outcome. Most CAMOs are possibly already close to complying with the new regulation. Many of the processes will be in place, perhaps with different labels, but the function and output are likely to be close to being compliant.
A key change under CAMO.A.305 (a) Personnel requirements is:
“(5) nominate a person or a group of persons with the responsibility for managing the development, administration and maintenance of effective safety management process as part of the management system.”
Depending on the size and scope of your organisation you may choose, or need to, create new positions. Conversely you may find you have the capacity and competence within your existing structure. Those you nominate in accordance with CAMO.A.305 (a)(5) above will need to appear in your exposition, along with other changes to your management structure. You will also need to include details of how you’ll meet the new regulation’s requirements and describe how you will manage safety.
To help with this we have developed a brand-new course, EASA Part-Camo Safety Management Overview, which is designed for anyone responsible for continuing airworthiness management and will also benefit those with an understanding of existing Part-M regulations.
The course content will tackle questions such as:
- What will the changes look like and how will they affect my CAMO?
- What terminology will be introduced to legislation?
- What do I need to do differently as a result?
What’s more, we explore the broader overall benefits a management system brings to your organisation, making any business case stronger.
Clearly there is no ‘one size fits all’ solution to this – each organisation will have to adapt to fit the size, scope and type of operation it is supporting; this course helps you refine your thinking and prepare appropriately for the transition. All of which will make it easier for you, and the regulator, to assess your compliance and performance.
You have until August 2021 to become compliant. If you haven’t yet started to assess how this change will affect your current operations and approvals then it’s time to start. Please click here to find out more about our Part-CAMO Safety Management course or contact firstname.lastname@example.org.