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ARSA Takes Issue With Proposed EASA SMS Personnel Provisions

ARSA holds that safety is contingent on SMS and its processes, not individuals.

The percentage of European Aviation Safety Agency (EASA) Part-145 approval holders that have not yet adopted Safety Management Systems (SMS) is 37%.  The statistic came out of an EASA survey, conducted in preparation for a recent notice of proposed amendment (NPA) that would mandate SMS for approved maintenance organizations within the European Union (EU), and to those outside the EU directly regulated by EASA. One industry group in particular raised questions about proposed provisions that it says fly in the face of a systems-based approach.

In its comments, the Aeronautical Repair Station Association (ARSA) pointed specifically to language that would require a maintenance organization to obtain prior approval from the competent authority before implementing key personnel changes. ARSA maintains that the proposal runs contrary to SMS principles, which is rooted in the belief that safety depends on the organization and its processes, not individuals.

“The privilege of holding a certificate is not dependent on any one individual, but rather on the company’s SMS,” said ARSA Executive Vice President Christian Klein in the organization’s formal comments to the NPA. “Requiring the regulator to approve personnel changes made in accordance with the company’s SMS defeats the purpose of the system and the proposed regulatory changes.”

While the rule would not apply to facilities that hold certificates pursuant to a bilateral aviation safety agreement, ARSA says it expects that the requirement will find its way into the bilateral’s list of special conditions, effectively expanding the mandate’s reach to any approved maintenance organization holding a certificate pursuant to the bilateral.

The comment period for the EASA proposal closed on Sept. 6 (the original July 17 deadline was extended). Publication of the final decision is expected late next year.

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