Printed headline: 2020
That is the year the European Aviation Safety Agency (EASA) plans to release a final regulation requiring repair stations to adopt a risk-based approach through a formal safety management system (SMS).
The notice of proposed amendment (NPA) sets forth specific revisions to the regulations governing aircraft parts and component manufacturers (Part 21) and repair stations (Part 145). Under the proposal, EASA Part 145 approval holders would be required to implement an SMS program without exception. The mandate will not apply to training organizations (Part 147) or general aviation approval holders (Part CAO).
The proposal follows the 2016 opinion that introduced SMS for continuing airworthiness management organizations (Part CAMO) managing aircraft operated by licensed air carriers and/or complex motor-powered aircraft. The latest NPA is part of the SMS integration plan’s “Phase II,” intended to encompass repair stations and manufacturers.
While the NPA is applicable to two groups of approval holders, implementation methodologies differ. Unlike the “product-focused” approach driving proposed changes in Part 21, the architects of Part 145 revisions followed an “integrated management system” approach. That is, where able, the repair station regulation proposal aligns with Part CAMO SMS requirements. Thus, aircraft operators that also hold an EASA Part 145 certificate would by and large be able to use the same processes and procedures for both programs.
Proposed changes to Part 145 align provisions and numbering with Part CAMO, add sections to address alternative means of compliance, require establishment of a “management system and safety philosophy,” modify the phrase “indirect approval” so that it is consistent with the concept of “change not requiring prior approval” and henceforth refer to “human factors training” simply as “safety training.”
If adopted, the new Part 145 will specifically require repair stations to address the risk of personnel fatigue in their management systems. Suggested guidance calls for the organization to maintain a policy for the management of fatigue-related risks—in compliance with applicable national and/or European Union laws and in consideration of International Civil Aviation Organization-recommended practices—and facilitate fatigue management training.
According to a survey conducted by EASA in preparation for the rulemaking, 63% of EASA Part 145 certificate holders already have an SMS program in place. The most common reason for implementation was regulatory requirements by another national aviation authority or because the company held another approval subject to SMS requirements. Survey results suggest that around 30% of repair stations with an SMS implemented the program voluntarily.
Three out of four Part 145 respondents supported an all-inclusive approach—that is, the application of SMS requirements across all repair stations without exception, regardless of size or the type of work performed. The feeling was mutual among competent authorities: The vast majority of representatives agreed there should be no exceptions provided.
The NPA timeline anticipates final publication in the third quarter of 2020, a year sooner than the timetable provided in the 2019-23 European Plan for Aviation Safety released late last year. The deadline to submit comments to the NPA is July 17.