Introducing SMS into Part M /CAMO –
Continuing Airworthiness Management of Aircraft
EASA Opinion published
EASA has published its long-awaited Opinion outlining how Safety Management is to be introduced into the Part M requirements.
EASA expects that the proposed changes will:
- Increase the level of safety in continuing airworthiness management and maintenance of aircraft operated by licensed air carriers and of CMPA (complex motor-powered aircraft)
- Facilitate the implementation of single management systems by multiple-approved organisations and streamline the related oversight.
What are the implications of this regulatory change for your organisation?
This regulatory change is ultimately designed to create a harmonised approach to the implementation of the new management system requirements for all Continuing Airworthiness Management Organisations (CAMOs), ensuring effective compliance monitoring, safety risk management and oversight for all continuing airworthiness management activities.
At a high level, and as illustrated in the diagram opposite, CAMOs will need to improve their understanding of the differences between good compliance management and aviation safety risk, as well as the role of the human and human performance, in improving aviation safety.
SMS into Part-M: The Opinion
As a result of the rulemaking process and Comment Response Documents 2013-01(A) & 2013-01(B), EASA has published a significant Opinion relating to introducing SMS into Part-M. This will be achieved through the introduction of Annex Vc to the continuing airworthiness regulation – ‘Part-CAMO’, dedicated to CAMOs which are managing aircraft operated by licensed air carriers and/or CMPA. Only Part-CAMO organisations will be required to implement SMS based on a set of proportional management system requirements.
The new Annex Vc ‘Part-CAMO’ will supersede the current Subpart G of Annex I (Part-M). The changes introduced are largely aligned with the general authority and organisation requirements adopted in the other domains (Aircrew, Air Operations, ADR, ATM/ANS).
This Opinion also proposes consequential amendments to other areas of ‘Part-M’, ‘Part-145’ and ‘Part-T’ resulting from the changes proposed with ‘Task force for the review of Part-M for General Aviation Phase II’ from the new Part-CAMO.
It is also preparing the ground to allow licensed air carriers to contract a CAMO, which is the objective of rulemaking task concerned with contracting out continuing airworthiness tasks.
We strongly encourage all organisations and relevant employees to familiarise themselves with these significant changes. Through our participation in industry working groups, Baines Simmons has played a key role in this change process and is currently evaluating the impact to the structure and requirements of various typical organisations. We will be releasing further information and updating our website in the near future.