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Safety first

Some of the defining features for MRO within the aviation industry are the thorough regulations, specifically from a safety point of view. Mario Pierobon reports on the importance of ensuring all maintenance meets an exacting standard

It is fair to say that the safety of all international aircraft operations is at stake once an airliner is released to service after maintenance. MRO regulatory thoroughness, however, is often accompanied by regulatory complexity. The interpretation of MRO regulatory requirements may not be much of a challenge for those who are hands-on in the aircraft maintenance business, however, the rulemaking process, including making sure that all organisations comply with the requirements, is normally far more cumbersome. This complexity is why maintenance organisations are required by law to employ suitably qualified professionals – quality managers – to ensure that processes are in place for MRO service providers to comply with current and upcoming requirements.


Aircraft maintenance is a world of constant change; this is not only caused by technological advances, but also by organisational changes. The latter being the guide to upcoming regulatory requirements that will affect the MRO industry. Attempting to illustrate these changes, as well as provide some guidance as to what they mean for affected organisations, can be difficult. First and foremost, new requirements concern safety management system (SMS) implementation within any organisation operating in the airworthiness sector: Part-M Subpart G approved continuing airworthiness management organisations (CAMOs) and Part-145 approved maintenance organisations (AMOs), for example.


SMS requirements

Werner Luehmann, Head of Regulatory Compliance and Authorities’ Liaison at Lufthansa Technik, notes that European regulations do not require Part-145 maintenance organisations to implement an SMS. There is, however, a significant advance in regard to SMS implementation at maintenance organisations in Europe. In addition, a new European regulation (EU 376/2014) has been issued that establishes ‘advanced occurrence reporting’ to enable safety management at a European Aviation Safety Agency (EASA) member states level, under the coordination and control of EASA itself.


Luehmann says that the first European introduction of SMS in the domain of continuing airworthiness will only be for CAMOs (Part-M Subpart-G), as they are the ones most closely connected to the operating procedures of air operators (AOC holders), which are already required to have an SMS. Luehmann also notes that several non-European authorities already require maintenance organisations to have an SMS in place. As a consequence, many European MROs – such as Lufthansa Technik – which hold these foreign approvals have implemented an internal SMS in compliance with the foreign authorities’ requirements (generally based on International Civil Aviation Organisation (ICAO) requirements).


What they imply

SMS is indeed a hot topic in aviation management. At its core, an SMS is a set of codified and documented practices designed to ensure that aeronautical service providers – including CAMOs and AMOs – become better aware of the safety hazards that are particular to their businesses and individual operations, as well as ensuring that they proactively manage them, including making continuous improvements. The theoretical framework of SMS is also rooted in the assumption that the aviation industry must move beyond mere compliance with regulatory requirements. Safety is an organisational property that is not simply ensured by a 'one size fits all' approach. Common industry-wide standards only provide for a high level safety objective, which may be met by organisations in alternative ways out of the recognition of the peculiar operational contexts. SMSs are, in a way, transferring even more of the responsibility for safety performance to the industry, which must subsequently be proactive in recognising and addressing safety hazards.


With regard to SMS implementation, there are a number of challenges maintenance service providers must meet that are important to be aware of. According to Luehmann, MROs need procedures to maintain quality related reports. “In the case of Lufthansa Technik, this has been accomplished by an in-house electronic, data-based work flow system called Q/star. However, this is only the tool,” says Luehmann. He notes, however, that no sophisticated system works without the input of the employees. “Therefore, the biggest challenge is to create an SMS culture within the MRO sector, meaning that people are aware about the SMS and not afraid to report occurrences or perceived hazards. This has been accomplished by training and by enabling anonymous reporting, as well as by prohibiting any ‘finger pointing’ in the course of the investigation,” he says.


The desired result from SMS implementation is that the workforce trusts the system and knows that all information will be protected and assessed, according to Luehmann.


Expected benefits

Luehmann believes that safety must always have the highest priority in the aviation industry and there are benefits to be derived from SMS implementation in the maintenance world. “SMS helps MROs to mitigate any safety related risk. Other than reacting to each occurrence discretely, SMS enables the MRO to be a learning company, to not only react to any incident, but also to take preventive actions” he says.


He notes that without an SMS, whenever a safety related incident occurs the MRO is only able to contain the damage, which is a very costly process. “By having an SMS in place, the MRO can monitor potential risks and implement mitigating barriers, even before any occurrence materialises. Therefore, by mitigating risks in advance, a working SMS environment not only increases aviation safety, but also potentially saves costs to the MRO” he says.


Management system

Upcoming requirements regarding SMS implementation will be compiled with some new wording. Interestingly, there will be no reference in the regulation text relating to ‘SMS’, instead there will be a more generic reference to a ‘management system’, which includes both a safety and a compliance monitoring function. This will be in line with the wording currently used in EASA regulations for air crew and air operations that cover a total system approach, for example mandating the same set of management system requirements across all aeronautical service providers.


The current term of ‘quality system’ used in the existing regulations on continuing airworthiness will be superseded, as it already has been in approved training organisations (ATOs) and AOC holders. The abandonment of this expression is not only due to there being a safety function in the management system, but also due to the fact the use of the word ‘quality’ has never really been seen in regulations regarding aviation management systems. The established contemporary meaning of the word ‘quality’ is the one derived from the ISO 9000 series of standards on quality management, where the word refers to customer satisfaction.


In aviation management, ‘quality’ has instead always been used to mean ‘legality’, that is to say compliance with safety regulatory requirements, which despite being customer expectations, are not the only ones. With the abandonment of the word ‘quality’ and its substitution with ‘compliance monitoring’, clarity will be achieved throughout the maintenance world as to what this very managerial function is expected to deal with, that is to say it will ensure that organisations perform in conformity with the law. >>

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