acceptable means of compliance (amc) and guidance material...

CONSULTATION DRAFT: November 2009

Acceptable Means of Compliance (AMC)

and

Guidance Material (GM)

for

CASR Part 145 Manual of Standards

Approved Maintenance Organisations Requirements

An Acceptable Means of Compliance (AMC) explains how the requirements contained in the Civil Aviation Safety Regulations 1998 (CASRs) for a certificate, licence, approval or other authorisation can be met by an applicant. Applicants are not required to comply with the AMC but if they do, CASA will issue the authorisation. Alternatively, applicants can, on their own initiative, propose other ways of complying with the requirements of the CASR, which CASA will assess on an individual basis.

Guidance Material (GM) provides explanations and amplification of a CASR’s policy intention, rather than a means of complying with it. GM should be read in conjunction with the applicable CASR(s) and AMCs. GM is identified by grey shaded text.

Acceptable Means of Compliance (AMC) Guidance Material (GM) CASR Part 145

AMC/GM for CASR Part 145 CONSULTATION DRAFT 2

Table of Contents 145.A.10 Scope ......................................................................................................................... 6

GM – Line Maintenance........................................................................................................ 6 AMC – Line Maintenance ..................................................................................................... 6 AMC – Base Maintenance..................................................................................................... 6 GM – Small Organisations of One Person ............................................................................ 6 5 AMC – Small Organisations of One Person.................................................................. 7 6 AMC – Small Organisations Up to Ten Individuals Involved in Maintenance............. 8

GM 145.A.25(a) Facility Requirements ................................................................................ 8 AMC 145.A.25(a) Facility Requirements.............................................................................. 9 GM 145.A.25(b) Facility Requirements ................................................................................ 9 AMC 145.A.25(b) Facility Requirements ........................................................................... 10 GM 145.A.25(d) Facility Requirements .............................................................................. 10 GM 145.A.25(e) Facility Requirements .............................................................................. 10 AMC 145.A.25(e) Facility Requirements............................................................................ 10 GM 145.A.30(a) Personnel Requirements............................................................................ 10 GM 145.A.30(b) Personnel Requirements ........................................................................... 10 AMC 145.A.30(b) Personnel Requirements......................................................................... 11 GM 145.A.30(c) Personnel Requirements............................................................................ 11 AMC 145.A.30(c) Personnel Requirements......................................................................... 11 GM 145.A.30(d) Personnel Requirements ........................................................................... 12 AMC 145.A.30(d) Personnel Requirements......................................................................... 12 GM 145.A.30(e) Personnel Requirements – Employee Qualifications................................ 13 AMC 145.A.30(e) Personnel Requirements – Employee Qualifications ............................. 13

Training syllabus for initial human factors training ............................................................ 15 GM 145.A.30(f) Personnel Requirements ............................................................................ 16

Specialist Services Maintenance Certification .................................................................... 16 Non-Destructive Testing ..................................................................................................... 17

AMC 145.A.30(f) Personnel Requirements ......................................................................... 17 Non Destructive Testing (NDT).......................................................................................... 17

Organisations............................................................................................................... 18 Personnel ..................................................................................................................... 18 Recording of NDT Test Results .................................................................................. 18 Visual Acuity............................................................................................................... 19

Welding ............................................................................................................................... 19 Engine Ground Running; Borescope Inspection; Flight Control Rigging........................... 19

AMC 145.A.30(h)1-2. Personnel Requirements .................................................................. 19 GM 145.A.30(j)1-3. Personnel Requirements ...................................................................... 19 GM 145.A.30(j)4. Personnel Requirements ......................................................................... 20 AMC 145.A.30(j)4.(i) Personnel Requirements................................................................... 20 AMC 145.A.30(j)4.(ii) Personnel Requirements.................................................................. 21



GM 145.A.35(a) Certifying and Support Staff..................................................................... 21 GM 145.A.35(b) Certifying and Support Staff..................................................................... 21 GM 145.A.35(b)3. Certifying and Support Staff.................................................................. 21 GM 145.A.35(c) Certifying and Support Staff..................................................................... 22 GM 145.A.35(d) Certifying and Support Staff ............................................................................ 22 GM 145.A.35(d) Certifying and Support Staff..................................................................... 22 AMC 145.A.35(e) Certifying and Support Staff .................................................................. 23 AMC 145.A.35(f) Certifying and Support Staff................................................................... 23 AMC 145.A.35(j) Certifying and Support Staff................................................................... 23 GM 145.A.37 Training ......................................................................................................... 24 GM 145.A.40(a) Equipment Tools and Material.................................................................. 24 AMC 145.A.40(b) Equipment Tools and Material............................................................... 24 GM 145.A.40(d) Equipment Tools and Material ................................................................. 24 AMC 145.A.40(d) Equipment Tools and Material............................................................... 24 GM 145.A.43 Fabrication in the Course of Maintenance (FITCOM).................................. 25 AMC 145.A.43 Fabrication in the Course of Maintenance (FITCOM) ............................... 25

Inspection and Identification ....................................................................................... 26 GM 145.A.43(b) Fabrication in the Course of Maintenance (FITCOM) ............................. 26 AMC 145.A.43(b) Fabrication in the Course of Maintenance (FITCOM) .......................... 26 GM 145.A.45(a) Maintenance Data .......................................................................................... 27 AMC 145.A.45(a) Maintenance Data........................................................................................ 27 GM 145.A.45(b) Maintenance Data ..................................................................................... 27 AMC 145.A.45(b) Maintenance Data .................................................................................. 27 GM 145.A.45(d) Maintenance Data ..................................................................................... 28 AMC 145.A.45(d) Maintenance Data .................................................................................. 28 GM 145.A.45(e) Maintenance Data ..................................................................................... 29 AMC 145.A.45(e) Maintenance Data................................................................................... 29 GM 145.A.47 Production Planning ...................................................................................... 29 AMC 145.A.47 Production Planning ................................................................................... 29 GM 145.A.50 Certification of Maintenance......................................................................... 30

System of Certification.................................................................................................... 30 Table 1 – Maintenance Verification and Certification Overview............................ 31

GM 145.A.50(a) Certification of Maintenance .................................................................... 32 AMC1; 145.A.50(a) Certification of Maintenance............................................................... 32 AMC2; 145.A.50(a) Certification of Maintenance............................................................... 32 AMC 145.A.50(d) Certification of Maintenance ................................................................. 34

Internal Release Documentation.......................................................................................... 34 GM 145.A.60 Occurrence and Major Defect Reporting ...................................................... 34



AMC 145.A.60 (a) Occurrence and Major Defect Reporting .............................................. 34 AMC 145.A.60 (b) Occurrence and Major Defect Reporting .............................................. 35 GM 145.A.65 Safety and Quality Policy, Maintenance Procedures and Management Systems.................................................................................................................................... 35

Organisational Management Systems ................................................................................. 35 AMC 145.A.65 Safety and Quality Policy, Maintenance Procedures and Management Systems.................................................................................................................................... 36

Quality Management Systems............................................................................................. 36 Organisational Management Structure – Summary......................................................... 38

Figure 145.A.65.1 Organisational Management System Structure ....................... 39 GM 145.A.65(a) Safety and Quality Policy, Maintenance Procedures and Management Systems.................................................................................................................................... 39 AMC 145.A.65(a) Safety and Quality Policy, Maintenance Procedures and Management Systems.................................................................................................................................... 39

Sample Safety Policy Statement...................................................................................... 40 Topics Acceptable for Inclusion in a CEO Statement of Corporate Safety Commitment40

GM 145.A.65(b) Safety and Quality Policy, Maintenance Procedures and Management Systems.................................................................................................................................... 42

Drug and Alcohol Management Plan (DAMP) ................................................................... 42 Fatigue Risk Management Systems for Maintenance Organisations .................................. 42

Background ..................................................................................................................... 42 Guidelines for ‘Good Practice’........................................................................................ 42

Underlying Principles .................................................................................................. 42 AMC 145.A.65(b) Safety and Quality Policy, Maintenance Procedures and Management Systems.................................................................................................................................... 44

Fatigue Risk Management Systems................................................................................. 44 GM 145.A.65(b)8. Safety and Quality Policy, Maintenance Procedures and Management Systems.................................................................................................................................... 44 GM 145.A.65(c)1. Safety and Quality Policy, Maintenance Procedures and Management Systems.................................................................................................................................... 44 AMC 145.A.65(c)1. Safety and Quality Policy, Maintenance Procedures and Management Systems.............................................................................................................. 45 GM 145.A.65(c)2. Safety and Quality Policy, Maintenance Procedures and Management Systems.............................................................................................................. 46 AMC 145.A.65(c)2. Safety and Quality Policy, Maintenance Procedures and Management Systems.............................................................................................................. 46 GM 145.A.65(d) Safety and Quality Policy, Maintenance Procedures and Management Systems.................................................................................................................................... 46 AMC 145.A.65(d) Safety and Quality Policy, Maintenance Procedures and Management Systems.................................................................................................................................... 46 GM 145.A.70(a)10. Maintenance Organisation Exposition ................................................. 47 AMC 145.A.70(a)10. Maintenance Organisation Exposition .............................................. 47 AMC 145.A.70 Maintenance Organisation Exposition........................................................ 47 GM 145.A.75 Privileges of the Approved Maintenance Organisation................................. 47

Sub-contracting Maintenance.......................................................................................... 47



Appendix I Safety Management Systems................................................................................ 49 1 Safety Management Process.................................................................................... 49

Collect the Data ........................................................................................................... 49 Figure SMS.1 Safety Management Process.......................................................... 50

Analyse the Data.......................................................................................................... 50 Prioritise Unsafe Conditions........................................................................................ 50 Develop Strategies....................................................................................................... 50 Approve Strategies ...................................................................................................... 50 Assign Responsibilities and Implement Strategies...................................................... 50 Re-evaluate Situation................................................................................................... 51 Collect Additional Data ............................................................................................... 51

2 Safety Management System Implementation Plan .................................................. 51 Small Organisations..................................................................................................... 51

3 The Components of a Safety Management System (SMS) ..................................... 51 GM – Safety Policy, Objectives and Planning ............................................................ 52 GM – Safety Risk Management .................................................................................. 59 Figure SMS.3 Tolerability of Risk (TOR) Triangle .................................................. 60 Figure SMS 4 Risk Management Processes.......................................................... 63 Risk .......................................................................................................................... 63 Risk Assessment ....................................................................................................... 63 Figure SMS.5 Example Risk Assessment Matrix ................................................... 64

AMC- Safety Risk Management ................................................................................. 66 Figure SMS.6 Risk Management Process – Overview Source: AS/NZ 4360 (2004) ..................................................................................... 66

GM – Safety Assurance Processes .............................................................................. 67 Systems to Achieve Safety Oversight: ...................................................................... 67 Safety Performance Monitoring and Measurement................................................. 68 Internal Safety Investigation.................................................................................... 68 Investigation Management ...................................................................................... 68 Scope of Safety Investigations ................................................................................. 69 Figure SMS.7 Internal Safety Investigation Process ............................................. 70 Change Management ............................................................................................... 70 Continuous Improvement of the Safety System ........................................................ 71 Management Review................................................................................................ 71

AMC –Safety Assurance Processes – Small Organisations ........................................ 72 GM – Safety Promotion............................................................................................... 72

Training and Education........................................................................................... 72 Safety Communication ............................................................................................ 73

AMC – Safety Promotion – Small Organisations........................................................ 73



145.A.10 Scope

GM – Line Maintenance 1 Where aircraft are to be maintained in accordance with progressive type programmes or for

temporary and occasional cases (AD’s, SB’s) under a Line Maintenance approval in accordance with a control procedure as mentioned above, the particular check or task should be individually assessed.

AMC – Line Maintenance 1 Line Maintenance should be understood as any maintenance that is carried out before flight to

ensure that the aircraft is fit for the intended flight.

2 Line Maintenance may include: Trouble shooting.

Defect rectification.

Aeronautical Product replacement with use of external test equipment if required. Aeronautical Product replacement may include products such as engines and propellers.

Scheduled maintenance and/or checks including visual inspections that will detect obvious unsatisfactory conditions/discrepancies but do not require extensive in depth inspection. It may also include internal structure, systems and powerplant items which are visible through quick opening access panels/doors.

Minor repairs and modifications which do not require extensive disassembly and can be accomplished by simple means.

3 For the carrying out of Aircraft Maintenance in accordance with Progressive type programmes or for temporary and occasional cases (AD’s, SB’s) by an AMO that holds Line Maintenance approval only, it is acceptable for the AMO to have a control procedure in its exposition for the assessment of the organisation’s capability to complete all tasks within the particular check safely to the required standards at the designated line maintenance station and where the Quality Manager approves the assessment.

AMC – Base Maintenance Maintenance tasks falling outside the criteria for Line Maintenance above are considered to be Base Maintenance.

Where the AMO uses facilities either inside or outside Australia such as satellite facilities, sub-contractors or line stations, such facilities may be included in the approval without being identified on the approval certificate, if the AMO’s exposition identifies the facilities and contains procedures to control such facilities and CASA is satisfied that they form an integral part of the AMO.

GM – Small Organisations of One Person 1 This Guidance Material (GM) provides guidance on how the smallest organisations satisfy the

intent of Part-145:

2 By inference, the smallest Part-145 AMOs would only be involved with a limited number of light aircraft, or aeronautical products used for large aircraft or aircraft operated in Passenger Service operations. It is therefore a matter of scale; small AMO’s maintaining a small number of light aircraft do not demand the same level of resources, facilities or complex maintenance procedures as a large organisation.



3 A Part-145 approval may be required by two quite different types of small organisations; the first being the light aircraft maintenance hangar, the second being the aeronautical product maintenance workshop maintaining such products as small piston engines, radio equipment etc.

4 Where only one person is employed (in fact having the certifying function and others), the AMOs approved under Part-145 may use the alternatives provided in this Guidance Material limited to the following:

(a) For Class ‘Aircraft’ maintenance; A2 Rating, Base and Line maintenance of aeroplanes of 5700 kg and below (piston

engines only. A3 Rating, Base and Line maintenance of single engined helicopters of less than 3175 kg. A4 Aircraft other than A1, A2 and A3.

(b) For Class ‘Engine’ maintenance; B2 Rating, Piston engines with a maximum output of less than 450 HP.

(c) For Class ‘Aeronautical Products’ maintenance, ‘C’ Ratings.

(d) For Class ‘Specialist Services’ maintenance; D1 Rating (Non-Destructive Testing); D2 Rating (Welding); D3 Rating (Other Specialist Service as specified).

5 AMC – Small Organisations of One Person (a) The minimum acceptable means of compliance to MOS paragraph 145.A.30 (b) is for one full-

time person who holds the position of ‘Accountable Manager’, maintenance engineer and is also the Certifying Employee, meeting the requisite Part-66 requirements. No other person may issue a Certificate of Release to Service and therefore if absent, no maintenance may be released during such absence.

(b) The quality and safety monitoring functions under MOS paragraphs 145.A.65 (c) and (d) may be contracted to an appropriate organisation approved under Part-145 or to a person with appropriate technical knowledge and extensive experience of quality audits employed on a part-time basis, with the agreement of CASA. Note: Full time for the purpose of Part-145 means not less than 35 hours per week except during vacation periods.

(c) For a small organisation where one individual uses a contracted quality and safety monitoring arrangement, the requirement of MOS paragraph 145.A.35(i) is satisfied by the submission to and acceptance by CASA of the nomination of that individual as the Accountable Manager, where the individual is also responsible for Quality and Safety issues and for Maintenance Certifications and Certificates of Release to Service. In this situation it is not necessary for the individual to issue authorisations for him or herself. The individual’s authorisations will be limited by his or her qualifications, which are required to be specified under paragraph 145.A.30(e) and may be referred to in a description of the AMO’s capability in the Exposition.

(d) For acceptable means of compliance to MOS paragraphs 145.A.65(c) and (d) the contracted quality or safety monitoring organisation or person should make a minimum of 2 visits per 12 months and it is the responsibility of this organisation or person to carry out such monitoring on the basis of 1 visit pre-announced and 1 visit unannounced to the organisation.

(e) With only one person as in 5(c) above, the requirement for a separate record of authorisation under paragraph 145.A.35(j), may be satisfied by a description of the individual’s authorisations or qualifications to be included in the AMO’s exposition.



(f) The AMO is responsible to comply with the findings of the contracted quality or safety monitoring organisation or person.

(g) Under the intent of CASR 145.010(3)(c), if the organisation or person contracted for quality monitoring loses or relinquishes its approval; or if the AMO wishes to change the contracted provider of this function, then the AMO must apply to CASA for a significant change approval with a proposal for new quality monitoring arrangements.

6 AMC – Small Organisations Up to Ten Individuals Involved in Maintenance (a) For acceptable means of compliance to MOS paragraph 145.A.30(b), the normal minimum

requirement is for the employment on a full-time basis of two persons who meet CASA’s requirements for certifying employees, whereby one holds the position of "maintenance engineer" and the other holds the position of "quality audit engineer". Either person could assume the responsibilities of the accountable manager providing that they can comply in full with the applicable elements of MOS paragraph 145.A.30(a), but the "maintenance engineer" should be the certifying person to retain the independence of the "quality audit engineer" to carry out audits. Nothing prevents either engineer from undertaking maintenance tasks providing that the "maintenance engineer" issues the Certificate of Release to Service.

(b) The "quality audit engineer" should have similar qualifications and status to the "maintenance engineer" for reasons of credibility, unless he/she has a proven track-record in aircraft quality assurance, in which case some reduction in the extent of maintenance qualifications may be acceptable.

(c) In cases where CASA agrees that it is not practical for the organisation to nominate a post holder for the quality monitoring function, this function may be contracted in accordance with paragraph 5(b), but if the AMO is approved on this basis, then paragraphs 5(f) and 5(g) are also applicable.

GM 145.A.25(a) Facility Requirements Where the hangar is not owned by the organisation, it may be necessary to establish proof of tenancy.

Protection from the weather elements relates to the normal prevailing local weather elements that are expected throughout any twelve month period. Aircraft hangar and component workshop structures should prevent the ingress of rain, hail, ice, snow, wind and dust etc. Aircraft hangar and component workshop floors should be sealed to minimise dust generation.

For line maintenance of aircraft, hangars are not essential but it is recommended that access to hangar accommodation be demonstrated for usage during inclement weather for minor scheduled work and lengthy defect rectification.

Employees involved in aircraft maintenance should be provided with an area where they may study maintenance instructions and complete maintenance records in a proper manner.



AMC 145.A.25(a) Facility Requirements Where the AMO uses facilities either inside or outside Australia such as satellite facilities, sub-contractors or line stations, such facilities may be included in the approval without being identified on the approval certificate, if the AMO’s exposition identifies the facilities and contains procedures to control such facilities and CASA is satisfied that they form an integral part of the AMO.

An acceptable means of compliance to the requirement for segregation of specialist workshops will be segregation to the extent that sensitive equipment is not contaminated in areas where they are to be maintained. For example workshops where composite repairs and sanding is performed should be segregated from electronic, hydro mechanical component or hydraulic component workshops. Segregation may be by physically isolating workshops with solid walls or by a combination of distance and less substantially partitioned bays with adequate environmental control. Additionally, similar segregation should be provided where sensitive tooling and equipment is used for maintenance.

Facilities including aircraft hangars, Aeronautical Product Maintenance workshops and office accommodation may be provided that are appropriate for the tasks carried out in them to the extent that:

1 Employees can carry out required tasks without undue discomfort because of temperature (for example, there may be adequate heating and cooling); and

2 Airborne contamination, including dust, is kept to a minimum and below a level in the work task area where visible aircraft or aeronautical product surface contamination cannot be seen.

3 Lighting allows each maintenance task to be carried out properly or effectively; and

4 Noise does not distract individuals from carrying out maintenance tasks.

Where facilities cannot ensure these criteria or for maintenance that must be performed outside any hangar, workshop or office as mentioned above such as for line maintenance, a Part 145 organisation may comply with this requirement by:

1 Providing Personal Protective Equipment and clothing;

2 Having procedures that identify when and under what conditions maintenance may be performed, for example;

If the facilities cannot provide adequate heating and cooling, procedures may define the conditions under which maintenance may be performed; and.

If it is impractical to control noise during maintenance tasks, individuals involved in the tasks may be provided with equipment that will prevent excessive noise from causing distraction; and

If airborne contamination results in visible surface contamination, all systems that could be affected by the contamination are sealed until the contamination and the source of the contamination are removed.

Aircraft hangar and component workshop floors should be sealed to minimise dust generation. The degree to which floors should be sealed depends upon the approved scope of maintenance for the facility. An acceptable standard for a workshop that overhauls intricate avionic components will be more stringent than for an aircraft hangar that is approved for line maintenance and defect rectification. As a minimum, for hangar floors to be sealed means that they should not be dirt or gravel floors where dust and dirt may contaminate aircraft or aeronautical products. The outcome required is that where systems or components are open they should not be subjected to dust and contamination due to environmental factors.

GM 145.A.25(b) Facility Requirements This provision is intended to provide for adequate office accommodation for:

1 maintenance planning functions; and 2 task research, maintenance data and instruction research and reading; and



3 certification and coordination requirements of maintenance employees for: (a) normal scheduled maintenance; and (b) the rectification of defects that could normally be expected in the AMO’s maintenance

facilities and locations.

AMC 145.A.25(b) Facility Requirements It is acceptable to combine any or all of the office accommodation requirements into one office subject to employees having sufficient room to carry out assigned tasks. Office accommodation may be provided for the processing and management of check sheets and task cards and their certification management, as well as for the research and reading of maintenance tasks, maintenance instructions and other maintenance data by maintenance employees.

GM 145.A.25(d) Facility Requirements Having storage facilities for serviceable aeronautical products, tools and equipment that are clean, well ventilated and maintained at a constant dry temperature to minimise the effects of condensation will be an acceptable means of compliance. Manufacturer’s storage recommendations will be followed for those aeronautical products, tools and equipment identified in such published recommendations.

Storage racks should be strong enough to hold aeronautical products and provide sufficient support for large aeronautical products such that the product is not distorted during storage.

All aeronautical products, wherever practicable, should remain packaged in protective material to minimise damage and corrosion during storage.

GM 145.A.25(e) Facility Requirements Sufficiency of hangar space to carry out planned base maintenance may be demonstrated by the preparation of a projected aircraft hangar visit plan relative to the maintenance programme. The aircraft hangar visit plan should be updated on a regular basis.

AMC 145.A.25(e) Facility Requirements An acceptable hangar visit plan will be one that is described in the exposition as a document that is regularly updated and used as a reference for projected planning of hangar utilisation. The hangar visit plan by virtue of its continual changeability needs only to be included in the exposition by reference, with the description and procedures for control to be included in the exposition.

GM 145.A.30(a) Personnel Requirements With regard to the Accountable Manager, it is normally intended to mean the Chief Executive Officer of the AMO, who by virtue of the position has overall (including in particular financial) responsibility for running the organisation. The Accountable Manager may be the Accountable Manager for more than one organisation and is not required to be necessarily knowledgeable on technical matters as the AMO’s exposition defines the maintenance standards to be adhered to. When the Accountable Manager is not the Chief Executive Officer (or equivalent), or where the finances of the organisation may be controlled by a board of directors, CASA will need to be satisfied that such an Accountable Manager has direct access to chief executive officer and has a sufficiency of ‘maintenance funding’ allocation to support the scope of maintenance proposed for approval.

GM 145.A.30(b) Personnel Requirements The Quality Manager’s responsibilities are outlined in MOS paragraph 145.A.30(c).

The Safety Manager’s responsibilities are outlined in AMC paragraph Safety Responsibilities.



AMC 145.A.30(b) Personnel Requirements Dependent upon the size of the organisation, the Part-145 AMO functions may be subdivided under individual managers or combined in any number of ways.

The AMO should have, dependent upon the extent of approval, a base maintenance manager, a line maintenance manager, a workshop manager, a quality manager and a safety manager; all of whom should report to the Accountable Manager, except in small Part-145 organisations where any one manager may also be the Accountable Manager, as determined by CASA.

The Base Maintenance Manager is responsible for ensuring that all maintenance required to be carried out in the hangar, plus any defect rectification carried out during base maintenance, is carried out to the design and quality standards specified under MOS paragraph 145.A.65(b). The Base Maintenance Manager is also responsible for any corrective action resulting from the quality compliance monitoring function under MOS paragraph 145.A.65(c).

The Line Maintenance Manager is responsible for ensuring that all maintenance required to be carried out on the line including line defect rectification is carried out to the standards specified under MOS paragraph 145.A.65(b) and is also responsible for any corrective action resulting from the quality compliance monitoring function under MOS paragraph 145.A.65(c).

The Workshop Manager is responsible for ensuring that all maintenance on aeronautical products is carried out to the standards specified under MOS paragraph 145.A.65(b) and is also responsible for any corrective action resulting from the quality compliance monitoring under MOS paragraph 145.A.65(c).

The sub-paragraphs 2 - 7 above provide titles for the positions described by way of example only. The organisation may adopt any title for the described managerial position, but should identify to CASA the titles and persons nominated in accordance with MOS paragraphs 145.A.30(b) and (c).

Where an organisation chooses to appoint managers for all or any combination of the identified Part-145 functions because of the size of the undertaking, it is necessary that these managers report ultimately through either the Base Maintenance Manager or Line Maintenance Manager or Workshop Manager or Quality Manager or Safety Manager, as appropriate, to the Accountable Manager.

Certifying employees may report to any of the managers specified depending upon the type of control the approved maintenance organisation uses (for example licensed engineers/independent inspection/dual function supervisors etc.). However the employees that conduct the quality compliance monitoring referred to in MOS paragraph 145.A.65(c)1 and employees that conduct any safety compliance audits under a safety management system under MOS paragraph 145.A.65(d) should retain reporting lines independent of the maintenance management structure referred to in MOS paragraph 145.A.30(b)1.

GM 145.A.30(c) Personnel Requirements An acceptable management structure for an AMO will be where the quality and safety managers are not a responsible manager for maintenance functions within the AMO.

Monitoring the AMO’s Quality System includes requesting remedial action as necessary by the Accountable Manager and the nominated persons referred to in MOS paragraph 145.A.30(b).

AMC 145.A.30(c) Personnel Requirements The qualifications that CASA accepts for nomination of Quality Manager are:

1 comprehensive knowledge of the AMO’s exposition; and

2 knowledge of the CASR Part 145 and this MOS; and

3 a formal qualification in quality management; and

4 two years experience in quality management system activities.



GM 145.A.30(d) Personnel Requirements Has sufficient employees, means that the AMO employs or contracts a sufficient number of individuals on a basis that provides for organisational stability and consistency of the workforce.

The AMO’s policies relating to the number of employees required under various maintenance scenarios and the levels of supervision required between individual maintainers and Certification Authorisation holders should be shown here. CASA does not prescribe supervisory ratios however the AMO should be able to show reasonable compliance to the standards set in their exposition through the management of personnel availability through their man-hour plan.

AMC 145.A.30(d) Personnel Requirements An acceptable means of compliance to this provision is for an AMO to either directly employ individuals or to contract individuals on a basis of continued employment; where

1 All contracted individuals are made aware that when working for the Organisation, they are required to comply with the Organisation’s procedures specified in its exposition, which are relevant to their duties.

2 For line maintenance, the contracted individuals will be limited to half of the number of employees on any shift that are required to perform the maintenance that would normally be expected under the Organisation’s approval; or

3 For base maintenance and aeronautical product maintenance, at least half of the contracted individuals will be engaged for at least the duration of the base maintenance or aeronautical product maintenance check.

An acceptable maintenance man-hour plan will take into account any maintenance carried out on aircraft / aeronautical products from outside Australia and should also take into account all work performed that is not within the scope of the AMO’s maintenance approval.

An acceptable maintenance man-hour plan will relate to the anticipated maintenance work load except that when the AMO cannot predict such workload due to the short term nature of its contracts, then the maintenance manpower plan should be based upon the minimum maintenance workload needed for commercial viability. Maintenance work load includes all necessary work such as, but not limited to, planning, maintenance record checks, production of worksheets/cards in paper or electronic form, accomplishment of maintenance, inspection and the completion of maintenance records.

In the case of aircraft base maintenance, an acceptable maintenance man-hour plan will relate to the aircraft hangar visit plan as specified in AMC 145.A.25(a).

In the case of aeronautical product maintenance, an acceptable maintenance man-hour plan will relate to the aeronautical product planned maintenance as specified in MOS paragraph 145.A.25(a)4.

For quality and Safety Management System monitoring functions, an acceptable man-hour plan will be one that is sufficient to meet the requirement of 145.A.65(c) and (d), which means taking into account AMC 145.A.65(c) and (d). Where quality and safety monitoring employees perform other functions, the time allocated to those functions needs to be taken into account in determining requisite quality and safety monitoring employee numbers.

An acceptable maintenance man-hour plan will be one that is reviewed at least every 3 months and updated when necessary.

Because of the changing nature of the man-hour plan, it is acceptably included in the exposition by reference and with the exposition describing the man-hour plan and the procedure for its management.

An acceptable procedure for significant deviations from the maintenance man-hour plan will be where the deviations are reported through the departmental manager to the Quality Manager and the Accountable Manager for review. Significant deviation means more than a 25% shortfall in available man-hours during a calendar month for any one of the functions specified in 145.A.30(d).



GM 145.A.30(e) Personnel Requirements – Employee Qualifications For an AMO to provide Maintenance Services, individuals must carry out maintenance on behalf of the AMO. The AMO authorises these individuals to carry out the maintenance on its behalf and must specify in its Exposition, the standards for competence that the AMO intends to accept for individuals that perform the maintenance.

An AMO’s training; assessment and authorisation procedures should also identify and provide for any operational tasks or inspections that a Part-66 Licence holder has not received training for, on a specific type rated aircraft, (such as engine ground running or Borescope Inspections) which employees may be required to carry out on behalf of the organisation.

The purpose of human factors continuation training is primarily to ensure that employees remain current in terms of human factors understanding and also to collect feedback on human factors issues. Consideration should be given to the possibility that such training has the involvement of the quality and safety department/s. There should be a procedure to ensure that feedback is formally passed from the trainers to the quality and safety department/s to initiate action where necessary.

Human factors continuation training should be of an appropriate duration in each two year period in relation to relevant quality and safety audit findings and other internal/external sources of information available to the organisation on human errors in maintenance.

AMC 145.A.30(e) Personnel Requirements – Employee Qualifications An acceptable means of compliance for an AMO to this requirement is for the AMO’s Exposition to include a procedure that identifies varying stages or levels of qualification, from accepted national qualification standards for more complex tasks, to simple on-the-job training and AMO acceptance of competency of individuals for less difficult or repetitive tasks. The procedures specify standards for employees including planners, Aircraft Maintenance Engineers, specialised services employees, supervisors and certifying employees to be assessed for competence by ‘on the job’ evaluation and/or by examination relevant to their particular job function within the organisation before unsupervised work is permitted. A record of the qualification and competence assessment would be kept.

To assist in the assessment of competence, job descriptions may be used to describe each job role in the organisation. Adequate initial and recurrent training is provided and recorded to ensure continued competence.

The acceptable procedure for assessment will establish that: 1 Planners are able to interpret maintenance requirements into maintenance tasks, and have an

appreciation that they have no authority to deviate from the maintenance data.

2 Individuals performing maintenance tasks are able to carry out maintenance tasks to any standard specified in the maintenance data and will notify supervisors of mistakes requiring rectification to re-establish required maintenance standards.

3 Specialised services employees are able to carry out specialised maintenance tasks to the standard specified in the maintenance data and will both inform and await instructions from their supervisor in any case where it is not possible to complete the specialised maintenance in accordance with the maintenance data.



4 Supervisors are able to ensure that all required maintenance tasks are carried out and where not completed or where it is evident that a particular maintenance task cannot be carried out to the maintenance data; such problems will be reported to the 145.A.30(c) person for appropriate action. In addition, for those supervisors who also carry out maintenance tasks; that they understand such tasks should not be undertaken when incompatible with their management responsibilities.

5 Certifying employees are able to determine when the aircraft or aeronautical product is serviceable and ready to release to service and when it should not be released to service.

6 Quality and safety audit employees are able to monitor compliance with the AMO’s procedures, its exposition and Part-145, identifying non compliance in an effective and timely manner in order that the organisation may remain in compliance.

In the case of planners, specialised services employees, supervisors and certifying employees, knowledge of the AMO’s procedures relevant to their particular role in the organisation is important. The aforementioned list is not exclusive and may include other categories of personnel.

With respect to the understanding of the application of human factors and human performance issues, maintenance, management, and quality audit personnel should be assessed for the need to receive initial human factors training, but in any case all employees involved in any maintenance, management, quality and safety audit functions should receive human factors continuation training. This should concern to a minimum:

1 Post-holders, managers, supervisors; 2 Certifying employees, Aircraft Maintenance Engineers Aeronautical Product workshop

maintenance employees, and Specialist Services technicians; 3 Technical support personnel such as, planners, engineers, technical record staff; 4 Quality control/assurance and Safety Management System employees; 5 Human factors staff/ human factors trainers; 6 Store department staff, purchasing department staff; 7 Ground equipment operators; 8 Contract staff in the above categories.

Initial human factors training should cover all the topics of the training syllabus specified in paragraph 0 either as a dedicated course or else integrated within other training. The syllabus may be adjusted to reflect the particular nature of the AMO. The syllabus may also be adjusted to meet the particular nature of work for each function within the organisation. For example:

1 Small organisations not working in shifts may cover in less depth subjects related to teamwork and communication,

2 Planners may cover in more depth the scheduling and planning objective of the syllabus and in less depth the objective of developing skills for shift working.

3 Depending on the result of the evaluation mentioned in paragraph 6, initial training should be provided to employees within 6 months of joining the AMO, but temporary employees should be trained shortly after joining the organisation to cope with the duration of employment.

4 Employees recruited from another AMO and temporary employees should be assessed for the need to receive any additional Human factors training to meet the new AMO’s human factors training standard.

Acceptable means of compliance for the provision of Human Factors training may be training conducted by the maintenance organisation itself, or independent trainers or any training organisations acceptable to CASA and specified in the Exposition.

The Human factors training procedures should be specified in the AMO’s Exposition.



Training syllabus for initial human factors training 1 The training syllabus below identifies the topics and subtopics that may be addressed as an

acceptable means of compliance for the provision of human factors training.

2 The AMO may combine, divide, or change the order of any subject of the syllabus to suit its own needs, provided that all subjects are covered to a level of detail appropriate to the organisation and its personnel.

3 Some of the topics may be covered in separate training (health and safety, management, supervisory skills, etc.) in which case duplication of training is not necessary.

4 Where possible, practical illustrations and examples should be used, especially accident and incident reports.

5 Topics should be related to existing legislation, where relevant. Topics should be related to existing guidance/advisory material, where relevant (eg. ICAO HF Digests and Training Manual).

6 Topics should be related to maintenance engineering where possible; too much unrelated theory should be avoided.

1 General / Introduction to human factors 1.1 Need to address human factors 1.2 Statistics 1.3 Incidents 2 Safety Culture / Organisational factors 3 Human Error 3.1 Error models and theories 3.2 Types of errors in maintenance tasks 3.3 Violations 3.4 Implications of errors 3.5 Avoiding and managing errors 3.6 Human reliability 4 Human performance & limitations 4.1 Vision 4.2 Hearing 4.3 Information-processing 4.4 Attention and perception 4.5 Situational awareness 4.6 Memory 4.7 Claustrophobia and physical access 4.8 Motivation 4.9 Fitness/Health 4.10 Stress 4.11 Workload management 4.12 Fatigue 4.13 Alcohol, medication, drugs 4.14 Physical work 4.15 Repetitive tasks / complacency 5 Environment 5.1 Peer pressure 5.2 Stressors 5.3 Time pressure and deadlines 5.4 Workload 5.5 Shift Work 5.6 Noise and fumes



5.7 Illumination 5.8 Climate and temperature 5.9 Motion and vibration 5.10 Complex systems 5.11 Hazards in the workplace 5.12 Lack of manpower 5.13 Distractions and interruptions 6 Procedures, information, tools and practices 6.1 Visual Inspection 6.2 Work logging and recording 6.3 Procedure – practice / mismatch / norms 6.5 Technical documentation – access and quality 7 Communication 7.1 Shift / Task handover 7.2 Dissemination of information 7.3 Cultural differences 8 Teamwork 8.1 Responsibility 8.2 Management, supervision and leadership 8.3 Decision making 9 Professionalism and integrity 9.1 Keeping up to date; currency 9.2 Error provoking behaviour 9.3 Assertiveness 10 Organisation’s HF program 10.1 Reporting errors 10.2 Disciplinary policy 10.3 Error investigation 10.4 Action to address problems 10.5 Feedback

GM 145.A.30(f) Personnel Requirements

Specialist Services Maintenance Certification Specialised Services Personnel are particularly trained and qualified in the specialist field and may not have a holistic understanding of the interrelationship of an aircraft’s systems, or airworthiness implications that the work may have, that an Aircraft Maintenance Engineer License holder should have. For this reason the Specialised Services Maintenance Certification will only be for the scope of the specialised service work and is not intended to cover work normally performed and certified for by a Part-66 Licensed Aircraft Maintenance Engineer, nor can the AMO authorise an employee to issue a Certificate of Release to Service predicated on the Specialist Service qualification.

Following the issue of a Maintenance Certification for a Specialist Service, a Certificate of Release to Service must be issued:

For maintenance carried out on an aircraft in Line Maintenance, by an appropriately authorised holder of a Category B1 or B2 Licence or equivalent.

For maintenance carried out on a small aircraft in Base Maintenance, by an appropriately authorised holder of a Category B1 or B2 Licence or equivalent.

For maintenance carried out on a large aircraft in Base Maintenance, by an appropriately authorised holder of Category C Licence or equivalent.

For maintenance on aeronautical products, by an appropriately authorised person for the issue of the Certificate of Release to Service for the product.



Non-Destructive Testing CASA recognises the National Aerospace Non-Destructive Testing Board of Australia (NANDTB) as the industry representative body for the purpose of Australian Standard AS 3669 Non-destructive testing – Qualification and approval of personnel – Aerospace.

Non-Destructive Testing (NDT) means such testing specified by the type certificate holder /aircraft or engine or propeller manufacturer in accordance with the maintenance data as specified in 145.A.45 for in service aircraft/aeronautical products for the purpose of determining the continued fitness of the product to operate safely.

NDT method means a method of inspection covered by this AMC, including the following: 1 Radiographic, all inspection techniques utilizing penetrating radiation, e.g. X, gamma and neutron

radiography 2 Ultrasonic, all inspection techniques utilising stress waves, e.g. acoustic emission and techniques

using ultrasonic frequencies 3 Eddy current, all inspection techniques utilizing electromagnetic phenomena but excludes

magnetic particle methods 4 Magnetic particle, all inspection techniques utilizing the migration of particles to flux leakage

fields, e.g. magnetic rubber techniques 5 Liquid penetrant, all inspection techniques utilising penetrating liquids.

NDT technique means a particular way in which a method may be used, e.g. through transmission ultrasonic as distinct from pulse-echo ultrasonic.

NDT procedure means a detailed written description of the way in which a particular component is to be inspected. Although Level 3 qualified NDT employees may be qualified via AS 3669 to establish and authorise methods, techniques, etc., this does not permit such employees to deviate from methods and techniques published by the type certificate holder/manufacturer in the form of continued airworthiness data, such as in non-destructive test manuals or service bulletins, unless the manual or service bulletin expressly permits such deviation.

Borescoping and other techniques such as delamination coin tapping are non-destructive inspections rather than non-destructive testing. The AMO should have an exposition procedure to ensure that employees who carry out and interpret such inspections are properly trained and assessed for their competence with the process. Non-destructive inspections, not being considered as NDT by Part-145 are not listed in Appendix 2 under class rating D1.

AMC 145.A.30(f) Personnel Requirements This Acceptable Means of Compliance describes methods and standards that CASA finds acceptable for applicants for Part-145 approvals to issue of Maintenance Certifications for Specialist Services Maintenance Authorisations.

Non Destructive Testing (NDT) An acceptable means of compliance to this MOS paragraph is for an AMO to set qualification standards for NDT employee authorisations based upon AS 3669 or other standards recognised by the NANDTB.

Note: A non destructive visible dye or fluorescent penetrant test using portable equipment means those processes and equipments covered by AQTF Competency unit ‘MEM24.2B Perform penetrant testing’, being a pre-requisite competency unit for the grant of a Part 66 B1 Licence.



Organisations The AMO that carries out NDT during the course of maintenance will have procedures in place to ensure that the NDT activities are carried out to Australian national standards and meet all the other applicable regulatory and/or statutory requirements. The AMO will have internal procedures to ensure personnel that carry out and/ or issue Maintenance Certifications for NDT are qualified to standards mentioned in this AMC or as approved by CASA as an acceptable alternative standard and assessed as competent for the purposes of the authorisation. A Certificate of Release to Service will be issued following all NDT Maintenance Certifications.

Personnel AMO's that carry out NDT must have adequate numbers of authorised staff, employed or contracted, to physically carry out the work.

The AMO will appoint a person to control NDT (NDT Controller); that has the qualifications and experience to be accepted by the National Aerospace Non-destructive Testing Board (NANDTB) as NDT Level 3 person, within the meaning of Australian Standard 3669 and is responsible for the following:

Establishing NDT acceptance and rejection criteria; Maintaining NDT records; Approving the AMO’s NDT training, assessment, and examination of persons permitted to

carry out NDT; Maintaining records of training and experience for NDT individuals; Setting up and testing NDT test equipment; Interpreting test results; and Internal surveillance of NDT tasks.

The AMO will authorise individuals to perform specific NDT tasks who: Are recommend by the NDT controller for the task; Have completed a training program that has been checked by the NDT controller as meeting

the requirements for the task. This must be as a minimum to NDT Level 1 course as described in Australian Standard 3669;

Have been assessed as being competent to carry out the specific tasks by the NDT Controller; and

Have passed an annual visual acuity test.

The persons approved by the AMO to perform and certify the results of the NDT tasks are: Authorised in writing, under the AMO’s Exposition procedures and in compliance with MOS

paragraph 145.A.30(f) to carry out the maintenance and to issue a Maintenance Certification for NDT tasks.

Only responsible for performing specific tests on nominated parts, in accordance with defined processes and procedures that have unambiguous acceptance and rejection criteria.

Recording of NDT Test Results A person fitting an aeronautical product to a higher assembly or an aircraft must be aware of the extent and results of NDT testing carried out. In addition to normal AMO’s recording requirements, the following information should be provided:

The NDT method and procedures used; Approved data relating to the test, including any applicable Airworthiness Directives; Results of the test; and



Name and authorisation number of the person who issued the Maintenance Certification for the NDT work.

Visual Acuity Persons who physically carry out NDT inspections must ensure that they have appropriate visual acuity to carry out any particular NDT task.

An acceptable level of visual acuity for NDT is indicated by the person’s ability to read the Jaeger No. 1 letters of a standard Jaeger Test Chart at a distance of not less than 30 cm with at least one eye, either corrected or uncorrected, or an equivalent standard established by an optometrist. This test should be carried out at least annually.

The visual acuity test should normally be conducted by an optometrist or other trained person. However, a CASA Airworthiness Inspector may conduct this test.

If the person is required to wear spectacles or other optical aids it must be endorsed on the NDT authorisation and the person must be advised that they may only make inspections while wearing the spectacles or other optical aids.

Welding An acceptable means of compliance is for the Part 145 AMO to test and qualify it's employees to the standard contained in CAAP 33-1 (0) http://casa.gov.au/wcmswr/_assets/main/download/caaps/airworth/33_1.pdf

Engine Ground Running; Borescope Inspection; Flight Control Rigging An acceptable qualification for use as a prerequisite for training, assessment and authorisation of employees for these functions will be a Part 66 Licence that covers the aircraft or engine type.

AMC 145.A.30(h)1-2. Personnel Requirements An acceptable means of compliance to the requirement for a register of Certifying Employees will be to maintain a list of authorised individuals including their name, the dates of authorisation validity and the authorisation number to enable cross-reference to the authorisation record required by 145.A.35(j).

It is acceptable for a register of Certifying Employees to be maintained as a document or computer record separate to the exposition, provided that the management part of the exposition contains clear cross references to the register.

GM 145.A.30(j)1-3. Personnel Requirements



An AMO may be authorised for maintenance on Australian registered aircraft in facilities outside Australia. Individuals may be authorised to issue Maintenance Certifications and Certificates for Release to Service based on Maintenance Certification licenses held, provided that the licence was granted under Part-66 or a law of the foreign country where the AMO’s main location is located or in which the facility is located. Additionally if the foreign country is a state under EASA, the licence may be granted under a law of any other EASA member state.

Example: An organisation approved under part 145 that has its main location in Hong Kong, may authorise as Certifying Employees at its main location, holders of Maintenance Certification licenses issued under CASR Part 66 or HKAR 66. If the organisation has a facility in the Singapore, the AMO may authorise as Certifying Employees, holders of Australian Part 66, HKAR 66 or CAAS 66.

GM 145.A.30(j)4. Personnel Requirements An authorisation under this provision for a ‘single maintenance event’ should only be considered for issue by the quality department of the contracted AMO after it has made a reasoned assessment that such a requirement is appropriate under the circumstances and at the same time maintaining the required airworthiness standards. The AMO’s quality department will need to assess each situation individually prior to the issuance of a ‘single maintenance event’ authorisation

An authorisation under this provision should not be issued where the level of certification required could exceed the knowledge and experience level of the employee it is issued to. In all cases, due consideration should be given to the complexity of the work involved and the availability of required tooling and/or test equipment needed to complete the work.

AMC 145.A.30(j)4.(i) Personnel Requirements In situations where an authorisation is required for the issue of a Maintenance Certification and CRS for ‘single maintenance event’ for an aircraft type for which a certifying employee does not hold a type-rated authorisation, the following procedure is an acceptable means of compliance:

1 Flight crew will communicate details of the defect to the operator’s contracted supporting AMO, with full details of the defect. If necessary the supporting maintenance organisation will then request the use of an authorisation for a single maintenance event from the quality department.

2 Before issuing an authorisation for a single maintenance event, the quality department will verify that:

(a) Full technical details relating to the work required to be performed have been established and passed to the certifying employee; and

(b) The organisation has an approved procedure in place for co-ordinating and controlling the total maintenance activity undertaken at the location under the authority of the single maintenance event authorisation; and

(c) The individual to whom a ‘single maintenance event’ authorisation is issued has been provided all the necessary information and guidance relating to maintenance data and any special technical instructions associated with the specific task undertaken; and

(d) A detailed step by step worksheet has been defined by the AMO and communicated to the ‘single maintenance event’ authorisation holder; and

(e) The individual holds authorisations of equivalent level and scope on another aircraft type of similar technology, construction and systems.

3 The ‘single maintenance event’ authorisation holder will sign off the detailed step by step worksheet when completing the work steps. The completed tasks should be verified by visual examination and/or normal system operation upon return to an appropriately approved Part-145 AMO facility.



AMC 145.A.30(j)4.(ii) Personnel Requirements For individuals not employed by the AMO who meet the requirements of MOS paragraph 145.A.30(j) (5), in addition to the items listed in AMC 145.A.30(j) (5) (i), paragraphs 1, 2 and 3, the quality department of the AMO may issue a ‘single maintenance event’ authorisation subject to full qualification details relating to the proposed certifying employee being verified by the quality department and made available at the location.

GM 145.A.35(a) Certifying and Support Staff ‘An adequate understanding of the aircraft and/or aeronautical products referred to in their certification authorisation, together with the Organisation’s procedures’ means that the individual employee has received training and assessment and has relevant maintenance experience on the product type and associated organisation procedures such that the employee understands how the product functions, what the more common defects are and what the associated consequences of the defects are.

The organisation should hold copies of all documents that attest to employee qualification and recent experience.

GM 145.A.35(b) Certifying and Support Staff An AMO issues a certification authorisation when satisfied that compliance has been verified with the appropriate paragraphs of Part-145 and Part-66. If the AMO grants an authorisation to an employee predicated on the employee holding a Part-66 Aircraft Maintenance Engineer’s Licence or applicable qualification, the AMO must ensure the qualification is valid at the time of issue and that the authorisation clearly specifies that the authorisation’s validity is predicated upon continued validity of the qualification.

GM 145.A.35(b)3. Certifying and Support Staff This provision empowers an AMO to train; assess and authorise employees in a wide range of specialist services functions for the purposes of issuing Maintenance Certification for those functions. The exposition procedure should set standards for recognition of qualification for each specific specialist service it wishes to provide. This may include NDT and Welding qualifications shown in acceptable means of compliance for paragraph 145.A.30(f).

Additionally this provision may be used for training assessment and authorisation by an AMO of individuals for engine ground running, borescope inspection and flight control rigging, where the applicable type training course does not include requisite training for the function.



GM 145.A.35(c) Certifying and Support Staff The requirement for six months experience in every two years for authorisation holders should not be confused with the Part 66 requirement for Maintenance Certification Licence holders. The Part 66 requirement for experience in each two years for Licence holders is for six months’ exercise of licence privileges, which is in particular, certification. The Part 145.A.35(c) requirement is for experience in the carrying out of maintenance and/or certification duties for that maintenance for at least some of the aircraft type systems or aeronautical products specified in the employee’s certification authorisation which the holder of the Certification Authorisation may certify. For example it would be expected that an employee authorised for CRS of aeronautical products would be required to carry out maintenance on at least some of the products for which he is authorised; a Part 66 Category B Licence holder would carry out maintenance and certification duties for at least some of the aircraft for which he is authorised and a Part 66 Category C Licence holder who is authorised to CRS large aircraft in Base Maintenance would certify for at least some of the aircraft types for which he or she is authorised.

GM 145.A.35(d) Certifying and Support Staff Continuation training is a two-way process to ensure that certifying employees remain current in terms of procedures, human factors and technical knowledge and that the AMO receives feedback on the adequacy of its procedures and maintenance instructions.

Continuation training should be of sufficient duration in each 2 year period to meet the intent of MOS paragraph 145.A.35(d), but it is acceptable for the training to be split into a number of separate elements. MOS paragraph 145.A.35(d) requires this training to keep certifying employees updated in terms of relevant technology, procedures and human factors issues, which means it is one part of ensuring quality. Therefore sufficient duration should be related to relevant quality audit findings and other internal and external sources of information available to the organisation on human errors in maintenance. This means that in the case of an organisation that maintains aircraft with few relevant quality audit findings, continuation training could be limited to days rather than weeks, whereas a similar organisation with a number of relevant quality audit findings, such training may take several weeks. For an AMO that maintains aeronautical products, the duration of continuation training would follow the same philosophy, but should be scaled down to reflect the more limited nature of the activity. For example, certifying employees who release hydraulic pumps may only require a few hours of continuation training, whereas those who release turbine engines may only require a few days of such training. The content of continuation training should be related to relevant quality audit findings and it is recommended that such training is reviewed at least once in every 24 month period.

GM 145.A.35(d) Certifying and Support Staff An acceptable means of compliance to the intent of this training is for the training to be interactive in nature and include the involvement of the quality department, to ensure that feedback is actioned. Alternatively, there may be a procedure to ensure that feedback is formally passed from the training department to the quality department to initiate action.

Continuation training covers changes in relevant requirements such as CASR’s, changes in AMO procedures and the modification standard of the products being maintained plus human factors issues identified from any internal or external analysis of incidents. It also addresses instances where employees failed to follow procedures and the reasons why particular procedures are not always followed. The continuation training reinforces the need to follow procedures and provides that incomplete or incorrect procedures are identified to the company in order that they can be corrected. This does not preclude the possible need to carry out a quality audit of AMO procedures.



AMC 145.A.35(e) Certifying and Support Staff An acceptable programme for continuation training will list all certifying employees and when training will take place, the elements of the training and an indication that it was carried out as scheduled. This information should subsequently be transferred to the certifying employees record as required by MOS paragraph 145.A.35(j).

AMC 145.A.35(f) Certifying and Support Staff MOS paragraph 145.A.35(f) requires that all certifying employees except those authorised under MOS paragraph 145.A.30(j)5 are required to be assessed for competence, qualification and capability related to intended certifying duties. There are a number of acceptable means in which this assessment may be carried out, but the following points need to be considered to establish an assessment procedure that suits the particular AMO.

1 Competence and capability can be assessed by working the employee under the supervision of either another certifying person or a quality auditor for sufficient time to arrive at a conclusion as to the employee’s competence. Sufficient time could be as little as a few weeks if the person is fully exposed to relevant work. It is not required to assess the employee against the complete spectrum of intended duties.

2 When the individual has been recruited from another (second) AMO and was a certifying employee in that organisation then the first AMO may accept a written confirmation from the Quality Manager of the second AMO about the individual’s competence and capability.

3 Qualification and competency assessment may be achieved by collecting copies of documents that attest to qualification and competencies achieved, such as licences and authorisations held by an individual. This should be followed by a confirmation check with organisations that issued the documents and finally a comparison check for differences between any product type ratings on the qualification documents and the relevant product types maintained by the AMO. Product type differences may identify the need for additional training and assessment prior to certification authorisation by the AMO.

AMC 145.A.35(j) Certifying and Support Staff The following information forms an acceptable means of compliance to the record keeping requirements of this paragraph:

1 Name; 2 Date of Birth; 3 Basic training; 4 Type training; 5 Continuation training; 6 Experience; 7 Qualifications relevant to the approval; 8 Scope of the authorisation; 9 Date of first issue of the authorisation; 10 If appropriated – expiry date of the authorisation; 11 Identification number of the authorisation.

It is acceptable for the record system to be controlled by the AMO’s quality department to provide isolation from individuals concerned, and the records may be kept in any format. This does not mean that the quality department must run the record system.



Individuals authorised to access the record system will be kept to a minimum to ensure that records cannot be altered in an unauthorised manner or that such confidential records become accessible to unauthorised persons.

For the purposes of initial and continuation regulatory and compliance oversight, CASA is an authorised person with access to the record system.

GM 145.A.37 Training The relevant requirements of Part 66 and Part 147 are the requirements referred to in:

1 Part 66 Manual of Standards Paragraphs 66.A.45; 66.A.50; 66.A.55; 66 MOS Appendix III and the applicable AMC/GM; and

2 Part 147 Manual of Standards requirements listed under the titles ORGANISATIONAL REQUIREMENTS and AIRCRAFT TYPE TRAINING REQUIREMENTS.

GM 145.A.40(a) Equipment Tools and Material Once an applicant for approval has determined the intended scope of approval for consideration by CASA, it will be necessary to show that all tools and equipment as specified in the maintenance data are held or can be made available when needed.

All tools and equipment specified in maintenance data as being necessary to measure specified dimensions and torque figures etc, that require to be controlled in terms of servicing or calibration should be clearly identified and listed in a control register including any personal tools and equipment that the AMO agrees can be used.

AMC 145.A.40(b) Equipment Tools and Material An acceptable control procedure for these tools and equipment is one that ensures the calibration and testing of such items on a regular basis and that indicates to users that the item is within any inspection or service or calibration time-limit. A clear system of labelling all tooling, equipment and test equipment is therefore necessary giving information on when the next inspection or service or calibration is due and if the item is unserviceable for any other reason where it may not be obvious. A register will be maintained for all precision tooling and equipment together with a record of calibrations and standards used.

Inspection, service or calibration on a regular basis should be in accordance with the equipment manufacturers’ instructions except where the organisation can show by results of an assessment process specified in its exposition that a different time period is appropriate in a particular case. For example if a particular torque wrench is heavily utilised, the organisation may show through experience that the wrench requires more frequent calibration than as recommended by the manufacturer.

GM 145.A.40(d) Equipment Tools and Material The degree to which tools and equipment may be out of tolerance will vary from item to item. Therefore it will be necessary for the procedure to show how items will be assessed and who will be responsible for the assessment.

AMC 145.A.40(d) Equipment Tools and Material An acceptable means of compliance to this provision is for the required procedure to show how the AMO will track aircraft or components that have been released to service following maintenance where tools or equipment have been used, which subsequently have been found to have been significantly out of tolerance at the time of the performance of the maintenance.

The procedure should also show how once tracked by the system, the affected aircraft or aeronautical products are reviewed for serviceability or airworthiness.



GM 145.A.43 Fabrication in the Course of Maintenance (FITCOM) These paragraphs give guidance to an AMO when controlling the fabrication of aeronautical products (FITCOM parts) for installation on aircraft or aeronautical products during the course of maintenance in accordance with MOS paragraph 145.A.43. Aeronautical products fabricated as described in this Guidance Material do not require an Australian Parts Manufacturer Approval (APMA).

Maintenance organisations approved under Part-145 often need to be able to fabricate aeronautical products (e.g. hoses, brackets, cables etc) during the course of maintenance of a particular aircraft or aeronautical product.

If an AMO has been approved to maintain aircraft or aeronautical products under Part-145, it may only fabricate a replacement part for an aircraft or aeronautical product covered by its certificate of approval, and only if it has the capability to fabricate the particular part with respect to appropriate facilities, tools and trained and competent employees.

Such fabrication activity by an AMO is limited to a specific need at a particular time rather than to the production of aircraft parts for commercial reasons. The provision for fabrication of aeronautical products is not intended to permit the fabrication of products or modification kits etc for onward supply and/or sale by an organisation approved under Part-145, but if an AMO maintains a fleet of aircraft or a particular type of aeronautical product, it is acceptable to fabricate and stock parts for a known need relating to future maintenance by the AMO of that fleet or type of aeronautical product.

Note: It is not acceptable to fabricate any item to pattern unless an engineering drawing of the item is produced, which includes any necessary fabrication processes and which is acceptable to CASA.

Where a TC-holder or an approved production organisation is prepared to make available complete data, which is not referred to in aircraft manuals or service bulletins, but provides manufacturing drawings for items specified in parts lists, the fabrication of these items is not considered to be within the scope of an approval unless agreed otherwise by CASA in accordance with a procedure specified in the exposition.

AMC 145.A.43 Fabrication in the Course of Maintenance (FITCOM) The agreement by CASA for the fabrication of aeronautical products by the AMO should be formalised through the approval of a detailed procedure mentioned in the AMO’s exposition. This AMC contains principles and conditions, which if taken into account for the preparation of a control procedure, will form an acceptable means of compliance to the intent of MOS 145.A.43.

Fabrication, inspection, assembly and test should be clearly within the technical and procedural capability of the organisation.

All necessary data to fabricate a part should be approved either by CASA or the type certificate (TC) holder or Part-21 design organisation approval holder, or supplemental type certificate (STC) holder. This data may include repair procedures involving the fabrication of parts. Where the data on such parts is sufficient to facilitate fabrication, the parts may be fabricated by an organisation approved under Part-145. Care should be taken to ensure that the data include details of part numbering, dimensions, materials, processes, and any special fabrication techniques, special raw material specification and/or incoming inspection requirement and that the approved organisation has the necessary capability. That capability should be defined by way of exposition content. Where special processes or inspection procedures are defined in the approved data that are not available at the organisation the organisation can not fabricate the part unless the competent authority or the type certificate (TC) holder or Part-21 design organisation approval holder gives an approved alternative.

Items fabricated by an organisation approved under Part-145 may only be used by that organisation in the course of overhaul, maintenance, modifications, or repair of aircraft or components undergoing work within its own facility. The permission to fabricate does not constitute approval for manufacture, or to supply externally and the parts do not qualify for certification on Authorised Release Certificate (CASA Form 1). This prohibition also



applies to the bulk transfer of surplus inventory, in that locally fabricated products are physically segregated and excluded from any delivery certification.

Examples of fabrication under the scope of a Part-145 approval may include; but are not limited to the following:

1 Fabrication of bushes, sleeves and shims;

2 Fabrication of secondary structural elements and skin panels;

3 Fabrication of control cables;

4 Fabrication of flexible and rigid pipes;

5 Fabrication of electrical cable looms and assemblies;

6 Formed or machined sheet metal panels for repairs.

All the above example aeronautical products, are to be fabricated in accordance with data provided in overhaul or repair manuals, modification schemes and/ or service bulletins, drawings or otherwise approved by CASA.

Inspection and Identification An acceptable procedure for the control of fabrication in the course of maintenance will ensure that any locally fabricated part is subjected to an inspection stage before, separately, and preferably independently from, any inspection of its installation. The inspection will establish full compliance with the relevant manufacturing data, and the part will be unambiguously identified as fit for use by stating conformity to the approved data. Adequate records will be maintained of all such fabrication processes including, heat treatment and the final inspections. All parts, except those having not enough space, will carry a part number that clearly relates it to the manufacturing/inspection data. Additional to the part number, the organisation's identity will be marked on the part for traceability purposes.

GM 145.A.43(b) Fabrication in the Course of Maintenance (FITCOM) This provision intends that records must be made of all parts fabricated in the course of maintenance. The AMO’s exposition procedure must specify how the AMO will record the information listed in paragraph 145.A.43(b)1-5 and how the AMO will meet the certification requirements for release of the product mentioned in 145.A.43(b)6.

AMC 145.A.43(b) Fabrication in the Course of Maintenance (FITCOM) As fabrication of aeronautical products (FITCOM parts) under this provision is in the course of maintenance, it is appropriate and acceptable that the release to service of the FITCOM part be incorporated in the Certificate of Release to Service for that maintenance. This is true for either maintenance of an aircraft for which the part is to be fitted, or maintenance of another aeronautical product to which the part is to be fitted.

If an AMO uses an approved system of internal release documentation described in 145.A.50(b) for the issue of Certificates of Release to Service for aeronautical products that it maintains for its own use, it is an acceptable means of compliance to 145.A.43(b) for the AMO to utilise that system for release and control of products fabricated in the course of maintenance. For an AMO’s Internal Release Documentation procedures to be acceptable for the record and control of products fabricated in the course of maintenance, the system must clearly differentiate between products maintained and products fabricated and must preclude the possibility of an Authorised Release Certificate being issued for the product at any time, or the supply of the product to another organisation in the future.



The use of an AMO’s system of internal release documentation for the release and control of FITCOM parts may provide for any airworthiness control requirements for the FITCOM part. It does not circumvent the requirements of 145.A.43(c) and (d). These requirements provide a link between the maintenance record and any airworthiness control for the aircraft or higher aeronautical product.

GM 145.A.45(a) Maintenance Data It is intended that an AMO should hold any maintenance data applicable to specific aircraft or aeronautical products that it is approved to maintain, which are listed on the AMO’s Approval Certificate.

AMC 145.A.45(a) Maintenance Data Where an AMO is approved to maintain a class of aircraft or aeronautical product and specific aircraft or aeronautical products are not individually listed on the approval certificate, it is an acceptable means of compliance for the AMO’s exposition to show how it accesses the maintenance data for a particular aircraft or aeronautical product when it is required to perform maintenance of the particular aircraft or aeronautical product. The exposition procedure will have to show how the AMO ensures that the maintenance data it accesses is current. Sources of data access may be from the Registered Operator, vendors, subscription services etc.

GM 145.A.45(b) Maintenance Data An AMO may generate new maintenance data for maintenance tasks only where no data currently exists (in any form) for the maintenance. For example if maintenance data exists in a Component Maintenance Manual or similar document, an AMO may not generate data under this provision for that maintenance to be carried out in an Aircraft maintenance environment. However if Aircraft Maintenance data such as an Aircraft Maintenance Manual contains data for the maintenance of an aeronautical product and there is no existing aeronautical product maintenance data for that product an AMO may generate data under this provision for workshop maintenance of the aeronautical product that is more extensive and detailed than the existing aircraft maintenance data, provided that the generation of the data does not involve creating or setting wear limits pertaining to the aeronautical product or any part of the product.

Under the intent of this provision, if an aeronautical product’s serviceability is managed under an aircraft maintenance program or an organisation’s internal release documentation procedure, the person responsible for the control of the aeronautical product management must be notified and must agree to the use of the generated maintenance data for the product.

AMC 145.A.45(b) Maintenance Data An acceptable exposition procedure would show how a person responsible for continuing airworthiness of an aircraft or management of an aeronautical product is consulted regarding the use of generated maintenance data and would provide a record of evidence that agreement was provided by that person.

An acceptable exposition procedure will specify whether the data will be retained in paper form or electronically in a computer database, describing the system of retention.

An acceptable procedure will describe a control system for communicating with manufacturers, TC holders or STC holders if applicable, to ensure that they are notified of the new data. The acceptable control procedure will also provide assurance that if any original data that pertains to the maintenance is produced by a manufacturer, TC holder or STC holder after the AMO’s generation of data, that original data is adopted for the maintenance.



GM 145.A.45(d) Maintenance Data The intent of this provision is to permit an AMO to alter existing maintenance data only where:

1 the maintenance can be carried out in a more practical or efficient manner than as described in the existing data; or

2 the existing maintenance data cannot be complied with by following the maintenance instructions; or

3 the alteration of the existing maintenance data is for the use of tools or equipment not specified in that data;

The exposition procedure should show how the approval process verifies how the altered maintenance data satisfies these criteria.

This provision is not intended to permit alteration of data to make it available in a different maintenance environment than for which it was originally intended. For example, Component Maintenance Manual data may not be altered or adapted for application and use in an Aircraft Maintenance environment.

AMC 145.A.45(d) Maintenance Data An acceptable exposition procedure will describe how the approval process for the alteration of Maintenance Data verifies that:

the maintenance can be carried out in a more practical or efficient manner than as described in the existing data; or

the existing maintenance data cannot be complied with by following the maintenance instructions; or

the alteration of the existing maintenance data is for the use of tools or equipment not specified in that data;

An acceptable exposition procedure would show how a person responsible for continuing airworthiness of an aircraft or management of an aeronautical product is consulted regarding the use of altered maintenance data and would provide a record of evidence that agreement was provided by that person for the use of the data.

An acceptable exposition procedure will specify whether the data will be retained in paper form or electronically in a computer database, describing the system of retention.

An acceptable procedure will describe a control system for communicating with manufacturers, TC holders or STC holders if applicable, to ensure that they are notified of the altered data. The acceptable control procedure will also provide assurance that if any original data that pertains to the maintenance is altered by a manufacturer, TC holder or STC holder to accommodate the AMO’s requirement to alter the original data after the AMO’s alteration; that altered original data is adopted for the maintenance.



GM 145.A.45(e) Maintenance Data For the purposes of sub-paragraph 3, a complex task is one where a task would be expected to span more than one shift or day, or where a team of employees is needed to accomplish the task, utilising a number of certification authorisation holders to verify completion of the task in accordance with maintenance data. Examples of such complex tasks may be:

1 A structural inspection task on a fuselage, where cabin furnishings require removal to facilitate the inspection, which itself may span a number of days, with replacement of cabin furnishings after the completion of the inspection.

2 An engine change that involves a number of clear stages, including certain ancillary tasks requiring additional independent inspections and after the installation, engine ground running to verify airworthiness of the aircraft.

AMC 145.A.45(e) Maintenance Data An AMO’s worksheet or work-card system will be acceptable under the requirements of sub-paragraph 3 if tasks of a complex nature are broken down into identifiable stages on the worksheet, with separate fields for signature by maintenance employees to verify completion of the stages, or for separate Maintenance Certification of the stages prior to the completion of the whole task.

GM 145.A.47 Production Planning Depending on the amount and complexity of work generally performed by the AMO, the production planning system may range from a very simple procedure to a complex organisational arrangement including a dedicated planning function in support of the production function.

It is intended that where an AMO is a provider of maintenance services to a Registered Operator, the AMO’s forecasting of maintenance work would necessitate lines of communication with that operator to ascertain what maintenance the operator anticipates will be required within the forecasting period.

Human performance limitations, in the context of planning safety related tasks, refers to the upper and lower limits and variations of certain aspects of human performance (Circadian rhythm / 24 hours body cycle) of which employees should be aware when planning work and shifts.

AMC 145.A.47 Production Planning For the purposes of Part 145, a system of production planning is acceptable if it gives consideration to:

1 Logistics, 2 Inventory control, 3 Square meters of accommodation, 4 Man-hours estimation, 5 Man-hours availability, 6 Preparation of work, 7 Hangar availability, 8 Environmental conditions (access, lighting standards and cleanliness), 9 Co-ordination with internal and external suppliers and contractors, 10 Scheduling of safety-critical tasks during periods when employees are likely to be most alert.

An acceptable procedure for shift changeover / handover of information is one that ensures effective communication when handing over the continuation or completion of maintenance actions, with consideration of three basic elements:

1 The outgoing individual’s ability to understand and communicate the important elements of the job or task being passed over to the incoming individual.



2 The incoming individual’s ability to understand and assimilate the information being provided by the outgoing individual.

3 A Formalised process for exchanging information between outgoing and incoming individuals, which includes a planned shift overlap and place for such exchanges to take place. Where an overlap is not possible, information is sufficiently documented and stages of maintenance sufficiently certified to ensure effective communication of all information relevant to the continuation of the maintenance.

GM 145.A.50 Certification of Maintenance System of Certification An Approved Maintenance Organisation may develop a System of Certification that includes provisions for compliance of various regulatory requirements such as:

Training, assessment, qualification and authorisation of employees Maintenance Certification and CRS requirements Work Card or Worksheet requirements Records Management requirements

Within its System of Certification, an AMO may train and authorise personnel to carry out maintenance on its behalf and sign for that maintenance after its completion or after completion to a stage of the maintenance. The AMO’s System of Certification may incorporate standards for various levels of authorisation as well as a description of the worksheet and records processes used.

Employees must be trained and assessed for the issue of Maintenance Certification Authorisations and Certificate of Release to Service Authorisations:

1 For Maintenance Certification after Aircraft Maintenance, employees have to be Part-66 License (or equivalent) holders or for Specialist Services Staff, qualified to a standard acceptable to CASA.

2 For the issue of Aircraft Certificates of Release to Service, employees must be Part-66 Licensed (or equivalent) holders holding; (a) For Line Maintenance, a Category B Licence for the aircraft; (b) For Base Maintenance of Large Aircraft, a Category C Licence for the aircraft; (c) For Base Maintenance of Small Aircraft, a Category B Licence for the aircraft.

The System of Certification should provide an effective trail of accountability to show which employee carried out maintenance, who issued Maintenance Certifications and Certificates of Release to Service, including the authorisation identification numbers of the employees involved; the date of the accomplishments and the maintenance data used.

The System of Certification should incorporate all regulatory requirements for Work Cards or Worksheets, and enable effective completion of operators’ own worksheet systems if they are required to be utilised. This may include the ability for the AMO’s Supplementary work card or defect reports to be appended to an operator’s task cards.

For Aeronautical Product maintenance, an AMO may train and authorise employees to issue task sign-off, Maintenance Certifications and Certificates of Release to Service (CRS), but only the CRS is mandatory.



Table 1 – Maintenance Verification and Certification Overview Note: This table is an overview only for guidance. For full details of provisions and requirements, refer to Manual of Standards and AMC material.

Function Part 145

Base Line

Sign for Task This Authorisation will be based on training and assessment leading to an organisational qualification. The process for this will be specified in the Exposition. A Signature for Task requires subsequent Maintenance Certification and a CRS.

N/A

Maintenance Certification

Maintenance Certifying Staff will be authorised to issue Maintenance Certifications for work carried out to give assurance that all subject maintenance was performed in accordance with Maintenance Data. Principally the qualification required for this authorisation will be a Part 66 license. However for specialised services, e g; NDT & Welding, nationally recognised qualifications may be acceptable; refer to AMC 145.A.30(f). Maintenance Certifications require subsequent CRS.

In Line Maintenance, the authorisation to issue Maintenance Certifications may be issued to staff based on Part 66 qualifications or for specialised services, a nationally or internationally recognised qualification acceptable to CASA; refer to AMC 145.A.30(f). This is not a CRS but is verification that the maintenance has been performed in accordance with maintenance data. Maintenance Certifications require subsequent CRS.

Certification of Release to Service (CRS)

A CRS is a Certification evidencing appropriate completion of Maintenance, made by Part 66 Licensed persons authorised by the AMO for the purpose of CRS. For Large aircraft this would be C Category License holders. For Small aircraft B1, B2 and B3 may be authorised for this purpose.

A CRS is a Certification evidencing appropriate completion of Maintenance, made by Part 66 Licensed persons authorised by the AMO for the purpose of CRS.

CRS (ARC)– Aeronautical Products

The AMO may authorise individuals to sign for tasks that they have carried out following confirmation of competence to perform the task. Additionally the AMO will have to ensure that employees that issue CRS for Aeronautical Products are appropriately qualified for the scope of work for which they are authorised. This may be on the basis of either external qualifications as mentioned within the Exposition or by a CASA approved procedure for training, assessment and qualification by the organisation as specified in the Exposition.



GM 145.A.50(a) Certification of Maintenance An aeronautical product that has been maintained whilst not fitted to the aircraft requires the issue of a Certificate of Release to Service (CRS) for that maintenance and the aircraft requires a CRS for the installation of the product on the aircraft when that occurs. The normal form required for use for the CRS for aeronautical products is the Authorised Release Certificate (ARC), known as CASA Form 1. The purpose of the CRS is to declare the serviceability of aeronautical products following maintenance by an AMO. The CASA Form 1 ARC is the primary form of CRS for an Aeronautical Product that has been maintained by an AMO and is the form that must be used unless there is an approved alternative system of Internal Release Documentation for the AMO included in its exposition.

The Authorised Release Certificate is not a delivery or shipping note.

Aircraft are not to be released using the Authorised Release Certificate.

The Authorised Release Certificate does not constitute approval to install the item on a particular aircraft, engine, or propeller, but helps the end user determine its airworthiness approval status.

AMC1; 145.A.50(a) Certification of Maintenance Where an AMO is part of the same business entity as an operator whose aircraft it maintains, if the AMO maintains an aeronautical product for its own fitment to that operator’s aircraft, it may use a system of in-house release documentation if the AMO has such a system of documentation included in its Exposition.

It is acceptable for an AMO to pre-print or computer generate Authorised Release Certificates in various sizes, providing that the form remains legible and it maintains the CASA published Authorised Release Certificate format and where:

1 orientation of the form remains in landscape format; and

2 the block numbers and the relative location of each block is retained; and

3 words on the Certificate must be in the English language; and

4 details to be entered on the Certificate can be either machine/computer printed or in handwriting using block letters and must permit easy reading; and

5 abbreviations are restricted to a minimum; and

6 Any space on the reverse side of the Certificate may be used by the originator for any additional information but must not include any certification statement.

AMC2; 145.A.50(a) Certification of Maintenance This acceptable means of compliance pertains to the issue of an Authorised Release Certificate by an AMO, where an aeronautical product has not undergone maintenance actions to repair a previous unserviceable condition. This AMC does not abrogate any responsibility of an AMO to comply with CASR Parts 42 and 145 for the performance of maintenance leading to the issue of a CRS for an aeronautical product.

1 It is acceptable for an AMO to issue a CASA form 1 ARC for the product if it is a product for which the AMO is approved to maintain, after verification of its serviceable condition in accordance with this AMC and procedures detailed in its exposition where the ARC is issued by:

(a) stating “Inspected” in block 12 of the ARC; and

(b) signing in block 20 by an individual appropriately qualified and authorised by the AMO; and

(c) where block 13 is used to specify:

(i) when the last maintenance was carried out and by whom; and



(ii) a list of all airworthiness directives, repairs and modifications known to have been incorporated, or if no airworthiness directives, repairs or modifications are known to be incorporated, then this is stated; and

(iii) detail of life used for service life limited parts being any combination of fatigue, overhaul or storage life; and

(iv) for any aeronautical product having its own maintenance history record, reference to the particular maintenance history record as long as the record contains the details that would otherwise be required in block 13. The maintenance history record and acceptance test report or statement may be attached to the CASA Form 1 ARC.

2 If an aeronautical product is removed from a serviceable Australian registered aircraft, an AMO may issue an ARC for the product in accordance with he guidelines of AMC2; 145.A.50(a) paragraph 1 above if:

(a) the aeronautical product is removed from the aircraft by an individual that is qualified and approved by the AMO for the purpose; and

(b) the last flight operation with the product fitted revealed no faults on that product or related system; and

(c) the aeronautical product is inspected for satisfactory condition including in particular damage, corrosion or leakage and compliance with any additional applicable maintenance instructions; and

(d) the aircraft record is researched for any unusual events that could affect the serviceability of the product, such as involvement in an accident, incident, heavy landing or lightning strike; and

(e) for serialised aeronautical products, a maintenance history record is available; and

(f) compliance with known modifications and repairs is verified; and

(g) compliance with applicable airworthiness directives is verified; and

(h) the flight hours or cycles or landings as applicable for any service life limited products including the time since overhaul is ascertained and recorded.

3 If an aeronautical product is removed from an aircraft that has been withdrawn from service, or from an aircraft that has been involved in an abnormal occurrence such as an accident, incident, heavy landing or lightning strike, an AMO may issue an ARC for the product in accordance with the guidelines of AMC2; 145.A.50(a) paragraph 1 above if:

(a) the aeronautical product is removed by and following the procedures of a Part 145 AMO; and

(b) additional to the assessment processes outlined in this AMC above, the person responsible for continuing airworthiness of the aircraft onto which the product will be fitted, agrees to the use of the product and is able to align any requisite scheduled maintenance for the product with the maintenance programme of the aircraft; and

(c) all recorded defects are reviewed for the aircraft from which the aeronautical product is removed and an assessment is made that confirms both normal and standby functions of the removed product will not be affected by any aircraft defects.

4 If a used aeronautical product has been maintained by an organisation not approved under Part 145, a Part 145 AMO may issue an ARC for the product in accordance with he guidelines of AMC2; 145.A.50(a) paragraph 1 above if:

(a) the aeronautical product is dismantled by the AMO in accordance with applicable maintenance data, to an extent needed for inspection to ensure the product’s serviceability; and



(b) for service life limited aeronautical products evidence of life used is available; and

(c) reassembling and testing in accordance with maintenance data is carried out; and

(d) all certification requirements of Part 145 MOS paragraph 145.A.50 are complied to.

AMC 145.A.50(d) Certification of Maintenance

Internal Release Documentation Except under the provision of paragraph 145.A.50(f), an approved system of internal release documentation may be used only for aeronautical products for aircraft of a Registered Operator that is part of the same business organisation as the AMO and whose aircraft the AMO maintains.

The system of documentation includes all of the information required by an Authorised Release Certificate (ARC; CASA Form 1), but not all the information required for the ARC needs be included on the label that accompanies the aeronautical product. The label that accompanies the product must confirm the serviceability of the product and provide any information needed to enable determination of the product’s eligibility for fitment.

The system of documentation includes documentation additional to the label that accompanies the product. The additional documentation may be paper or computer records, traced to the particular aeronautical product, to provide for control of the aeronautical product’s maintenance and operational history including:

1 duplication of information included in the label that accompanied the product;

2 the identity and revision status of maintenance documentation used as the approved standard;

3 compliance or non-compliance with Airworthiness Directives or service bulletins;

4 details of maintenance work carried out or reference to a document where this is stated;

5 details of modifications carried out and approved data used (service bulletins, STCs etc.);

6 replacement parts installed and/or parts found installed, as appropriate;

7 concessions /exemption /exclusion, as applicable;

8 life-limited product’s history;

9 identity of Civil Aviation Regulation compliance;

NOTE: The control of the aeronautical product’s maintenance and operational history may be accomplished by the Registered Operator as part of its Continuing Airworthiness Maintenance function. In this case the Exposition procedure will have to show how the internal system of documentation is interfaced with the Registered Operator’s system of Continuing Airworthiness Maintenance Control.

GM 145.A.60 Occurrence and Major Defect Reporting The intent of Major Defect Reporting is to identify the factors contributing to incidents and to make the system resistant to repeated or similar errors. The requirements for an AMO to report Major Defects may be facilitated through an Occurrence Reporting facility that may be part of the AMO’s Safety Management System and/or Quality System.

AMC 145.A.60 (a) Occurrence and Major Defect Reporting An acceptable internal occurrence reporting system will enable and encourage free and open reporting of any actual or potentially unsafe occurrence. This will be facilitated by the establishment of a just culture. An organisation should ensure that employees are not inappropriately punished for reporting or co-operating with occurrence investigations.



The acceptable internal reporting process will be closed-loop, ensuring that actions are taken internally to address maintenance errors and safety hazards. Feedback to reporters, both on an individual and more general basis, ensures their continued support for the scheme.

AMC 145.A.60 (b) Occurrence and Major Defect Reporting An acceptable means of compliance for the requirements of Major Defect reporting is for the reports to the Registered Operator or CASA to:

1 describe the defect; and

2 set out the date on which the defect was discovered; and

3 set out the circumstances under which the defect was discovered; and

4 set out any action that has been taken or that is proposed to be taken:

(a) to rectify the defect; or

(b) to prevent the defect from recurring; and

5 set out what the person making the report thinks is the cause of the defect; and

6 if the defect is in an aircraft – set out:

(a) the type, model, serial number and registration mark of the aircraft; and

(b) the type, model and serial number of the aircraft’s engine, if relevant to the defect; and

(c) if the aircraft has a propeller – the type, model and serial number of the aircraft’s propeller, if relevant to the defect; and

(d) the time in service of, number of landings of, or number of cycles completed by, the aircraft since new; and

7 if the defect is in an aeronautical product – set out:

(a) the identity of the product, including (if applicable) the part number and serial number of the product; and

(b) the time in service of, or the number of cycles completed by, the product since new; and

(c) if the product has been overhauled – the time in service of, or the number of cycles completed by, the product since its most recent overhaul; and

(d) if the product is a turbine engine – the number of cycles completed by the engine since new.

GM 145.A.65 Safety and Quality Policy, Maintenance Procedures and Management Systems

Organisational Management Systems Because SMS and QMS share many commonalities, there may be a tendency to assume that an organisation that has established and operates a QMS does not need, or already has, an SMS. However, although SMS and QMS share commonalities, there are also important differences between both, as well as shortcomings in the effectiveness of QMS to achieve by itself the overarching objective of managing the safety risks or the consequences of hazards the organisation must confront during the activities related to the delivery of services.

The objective of a QMS is to provide systemic assurance that the processes and procedures used by the organisation will result in the provision of products or services that meet a predetermined standard and hence customers’ expectations. It does this by ensuring adequacy of and compliance to approved procedures. SMS differs from QMS in that SMS focuses on Human Factors and organisational factors,



and integrates into these, quality management techniques and processes, to contribute to the achievement of safety satisfaction. The objective of SMS is to identify the safety hazards the organisation must confront and in some cases generates during delivery of services, and to bring the safety risks or the consequences of these hazards under organisational control.

AMC 145.A.65 Safety and Quality Policy, Maintenance Procedures and Management Systems The management system of an organisation may comprise two separate but complementary systems; the Quality Management System (QMS) and the Safety Management System (SMS). The QMS and SMS should correspond to the size, nature and complexity of the organisation, being appropriate to its maintenance capability and all the hazards and risks associated with its activities.

It is an acceptable means of compliance to the requirements of Part-145 to integrate organisational management systems. Clear benefits of integration include;

Reduction of duplication and therefore of costs; Reduction in overall organisational risks and increase productivity; Balance of potentially conflicting objectives; Elimination of potentially conflicting responsibilities and relationships; and Diffusion of power systems.

Integration of QMS and SMS may result in synergistic realisation of organisational goals and in particular to the organisation’s safety goals. These management systems share many commonalities including that they:

Have to be planned and managed; Depend upon measurement and monitoring; Involve every function, process and person in the organisation; and Strive for continuous improvement.

Quality Management Systems The primary objectives of the quality system are to enable the organisation to ensure that it can deliver a safe product and that the organisation remains in compliance with the requirements.

An essential element of the quality system is the independent audit.

The independent audit is an objective process of routine sample checks of all aspects of the organisation’s ability to carry out all maintenance to the required standards and includes some product sampling as this is the end result of the maintenance process. It represents an objective overview of the complete maintenance related activities and is intended to complement the requirement of 145.050 (a) for certifying employees to be satisfied that all required maintenance has been properly carried out before issue of the Certificate of Release to Service. Independent audits should include a percentage of random audits carried out on a sample basis when maintenance is being carried out. This means some audits during the night for those organisations that work at night.

Except as specified in sub-paragraphs 7 and 9, the independent audit should ensure that all aspects of Part-145 compliance are checked every 12 months and may be carried out as a complete single exercise or subdivided over the 12 month period in accordance with a scheduled plan. The independent audit does not require each procedure to be checked against each product line when it can be shown that the particular procedure is common to more than one product line and the procedure has been checked every 12 months without resultant findings. Where findings have been identified, the particular procedure should be



rechecked against other product lines until the findings have been rectified after which the independent audit procedure may revert back to 12 monthly for the particular procedure.

Except as specified otherwise in sub-paragraphs 7, the independent audit should sample check on product on each product line every 12 months as a demonstration of the effectiveness of maintenance procedures compliance. It is recommended that procedures and product audits be combined by selecting a specific product example, such as an aircraft or engine or instrument and sample checking all the procedures and requirements associated with the specific product example to ensure that the end result should be an airworthy or serviceable product.

For the purpose of the independent audit a product line includes any product under an approval class rating as specified in the approval schedule issued to the particular organisation.

It therefore follows for example that a maintenance organisation approved under Part-145 with a capability to maintain aircraft, repair engines, brakes and autopilots would need to carry out 4 complete audit sample checks each year except as specified otherwise in subparagraphs 5, 7 or 9.

The sample check of a product means to witness any relevant testing and visually inspect the product and associated documentation. The sample check should not involve repeat disassembly or testing unless the sample check identifies findings requiring such action.

Except as specified otherwise in sub-paragraph 9, where a small organisation with a maximum of 10 personnel actively engaged in maintenance, chooses to contract the independent audit element of the quality system in accordance with 145.065 (c) (1) it is conditional on the audit being carried out twice in every 12 month period.

Except as specified otherwise in sub-paragraph 9, where the organisation has line stations listed as per 145.075 (d) the quality system should describe how these are integrated into the system and include a plan to audit each listed line station at a frequency consistent with the extent of flight activity at the particular line station. Except as specified otherwise in sub-paragraph 9 the maximum period between audits of a particular line station should not exceed 24 months.

Except as specified otherwise in sub-paragraph 5, CASA may agree to increase any of the audit time periods specified in the AMC 145.065 (c) (1) by up to 100% provided that there are no safety related findings and subject to being satisfied that the organisation has a good record of rectifying findings in a timely manner.

A report should be raised each time an audit is carried out describing what was checked and the resulting findings against applicable requirements, procedures and products.

The independence of the audit should be established by always ensuring that audits are carried out by personnel not responsible for the function, procedure or products being checked. It therefore follows that a large maintenance organisation approved under Part-145, being an organisation with more than about 500 maintenance employees should have a dedicated quality audit group whose sole function is to conduct audits, raise finding reports and follow up to check that findings are being rectified. For the medium sized maintenance organisation approved under Part-145, being an organisation with less that about 500 maintenance employees, it is acceptable to use competent personnel from on section/department not responsible for the production function, procedure or product to audit the section/department that is responsible subject to the overall planning and implementation being under the control of the quality manager. Organisations with a maximum of 10 maintenance employees actively engaged in carrying out maintenance may contract the independent audit element of the quality system to another organisation or a qualified and competent person approved by CASA.



Organisational Management Structure – Summary



Figure 145.A.65.1 Organisational Management System Structure

GM 145.A.65(a) Safety and Quality Policy, Maintenance Procedures and Management Systems Management’s commitment to safety should be formally expressed in a statement of the organization’s safety policy. This should reflect the organisation’s philosophy of safety management and become the foundation on which the organization’s Safety Management System is built. The safety policy outlines the methods and processes that the organisation will use to achieve desired safety outcomes, and it serves as a reminder as to “how we do business here”. The creation of a positive safety culture begins with the issuance of a clear, unequivocal direction.

A safety policy may take different forms but will typically include statements concerning:

The overall safety objective of the organisation;

The commitment of senior management to the goal of ensuring that all aspects of the operation meet safety performance targets;

A commitment by the organisation to provide the necessary resources for the effective management of safety;

A commitment by the organisation to make the maintenance of safety its highest priority; and

The organisation’s policy concerning responsibility and accountability for safety at all levels of the organisation.

The safety policy should be a written document that is issued under the authority of the highest level of management of the organisation, approved by the regulator and communicated to all staff. A sample corporate safety policy statement is included as an Acceptable Means of Compliance below. This statement presents a tangible indication of senior management’s commitment to safety. An alternative to this type of safety policy is a statement of commitment by the Chief Executive Officer (CEO) to the maintenance of the highest standards of safety. An example of topics that might be included in a CEO’s statement of commitment to safety is included below as an Acceptable Means of Compliance

In preparing a safety policy, senior management should consult widely with key staff members in charge of safety-critical areas. Consultation ensures that the document is relevant to staff and gives them a sense of ownership in it. Corporate safety policy must also be consistent with relevant State regulations.

AMC 145.A.65(a) Safety and Quality Policy, Maintenance Procedures and Management Systems An acceptable safety and quality policy wis one that as a minimum includes a statement committing the organisation to:

1 Recognise safety as a prime consideration at all times;

2 Apply human factors principles;

3 Encourage employees to report maintenance related errors/incidents;

4 Recognise that compliance with procedures, quality standards, safety standards and regulations is the duty of all employees;

5 Recognise the need for all employees to cooperate with the quality auditors.



Sample Safety Policy Statement Safety is the first priority in all our activities. We are committed to implementing, developing and improving strategies, management systems and processes to ensure that all our aviation activities uphold the highest level of safety performance and meet national and international standards.

Our commitment is to:

1 Develop and embed a safety culture in all our aviation activities that recognizes the importance and value of effective aviation safety management and acknowledges at all times that safety is paramount;

2 Clearly define for all staff their accountabilities and responsibilities for the development and delivery of aviation safety strategy and performance;

3 Minimize the risks associated with aircraft operations to a point that is as low as reasonably practicable/achievable;

4 Ensure that externally supplied systems and services that impact upon the safety of our operations meet appropriate safety standards;

5 Actively develop and improve our safety processes to conform to world-class standards; 6 Comply with and, wherever possible, exceed legislative and regulatory requirements and

standards; 7 Ensure that all staff are provided with adequate and appropriate aviation safety information and

training, are competent in safety matters and are only allocated tasks commensurate with their skills;

8 Ensure that sufficient skilled and trained resources are available to implement safety strategy and policy;

9 Establish and measure our safety performance against realistic objectives and/or targets; 10 Achieve the highest levels of safety standards and performance in all our aviation activities; 11 Continually improve our safety performance; 12 Conduct safety and management reviews and ensure that relevant action is taken; and 13 Ensure that the application of effective aviation safety management systems is integral to all our

aviation activities, with the objective of achieving the highest levels of safety standards and performance.

Topics Acceptable for Inclusion in a CEO Statement of Corporate Safety Commitment Listed below are topics that may be covered in statements of corporate safety commitment. Following each topic are subjects that are commonly addressed to amplify the corporate position on that topic.

1 Core values. Among our core values, we will include: (a) Safety, health and the environment; (b) Ethical behaviour; and (c) Valuing people.

2 Fundamental safety beliefs. Our fundamental safety beliefs are: (a) Safety is a core business and personal value. (b) Safety is a source of our competitive advantage. (c) Our business will be strengthened by making safety excellence an integral part of all aviation

activities. (d) All accidents and serious incidents are preventable. (e) All levels of line management are accountable for our safety performance, starting with the

Chief Executive Officer (CEO)/Managing Director.



(f) Core elements of our safety approach. The five core elements of our safety approach include: (i) Top management commitment:

Safety excellence will be a component of our mission. Senior management will hold line management and all employees accountable for

safety performance. (ii) Responsibility and accountability of all employees:

Safety performance will be an important part of our management/employee evaluation system.

We will recognize and reward safety performance. Before any work is done, we will make everyone aware of the safety rules and

processes, as well as each one’s personal responsibility to observe them. (iii) Clearly Communicated expectations of zero accidents:

We will have a formal written safety goal, and we will ensure that everyone understands and accepts that goal.

e will have a communications and motivation system in place to keep our employees focused on the safety goal.

(iv) Auditing and measuring performance for improvement: Management will ensure that regular safety audits are conducted. We will focus our audits on the behaviour of people, as well as on the conditions of

the workplace. We will establish performance indicators to help us evaluate our safety performance.

(v) Responsibility of all employees: Each of us will be expected to accept responsibility and accountability for our own

behaviour. Each of us will have an opportunity to participate in developing safety standards and

procedures. We will openly communicate information about safety incidents and will share the

lessons learned with others. Each of us will be concerned for the safety of others in our organisation.

(vi) Objectives of the safety process. Our objectives include: All levels of management will be clearly committed to safety. We will have clear employee safety metrics, with clear accountability. We will have open safety communications. We will involve all relevant staff in the decision-making process. We will provide the necessary training to build and maintain meaningful safety

leadership skills. The safety of our employees, customers and suppliers will be a strategic issue of the

organisation.



GM 145.A.65(b) Safety and Quality Policy, Maintenance Procedures and Management Systems Maintenance procedures should be kept current such that they are an accurate reflection on how the organisation performs maintenance.

All procedures and changes to those procedures should be verified and approved by the applicable Exposition procedure or by CASA before use where practicable.

All technical procedures should be designed and presented in accordance with good human factors principles.

Drug and Alcohol Management Plan (DAMP) Approved Maintenance Organisations by virtue of their approval scope will be involved in Safety Sensitive Aviation Activities (SSAA) as defined in CASR Part-99. Any organisation partaking of SSAA’s specified in Part-99.015 will be required by Part-99.030 to develop a Drug and Alcohol Management Plan (DAMP) in accordance with Part-99.045 and by Part-99.035 to implement it as described.

Fatigue Risk Management Systems for Maintenance Organisations

Background The following guidance material is developed from material presented by Simon Folkard D.Sc. from the Body Rhythms and Shiftwork Centre of the Department of Psychology, University of Wales Swansea, Singleton Park Swansea SA2 8PP, Wales, U.K. in a report to the United Kingdom Civil Aviation Authority. The report makes recommendations of guidelines for ‘good practice’ based on a large-scale survey that was undertaken of Licensed Aircraft Maintenance Engineers in the UK, and parallel surveys that were conducted of both employers and contract employers. These surveys yielded substantial evidence on the range of shift systems in operation in aircraft maintenance.

This guidance material is recommended for consideration in the development of Fatigue Risk Management Systems for AMO’s that employ individuals to maintain aircraft in a shift environment.

Guidelines for ‘Good Practice’

Underlying Principles Wherever possible, the guidelines proposed here are based on established trends in risk. These were derived from reviewing large-scale studies of accidents and/or injuries in many different types of industry and country. However, there are many features of work schedules that may give rise to concern with respect to their impact on sleep and/or fatigue, but for which there are, as yet, no good studies showing their impact on risk. In these cases, and in the absence of objective risk data, the guidelines have been based on the available evidence relating these features to sleep and/or fatigue. The aims in these cases have been threefold, namely to:

1 Minimise the build up of fatigue over periods of work;

2 Maximise the dissipation of fatigue over periods of rest;

3 Minimise sleep problems and circadian disruption;



Daily Limits There is good evidence that risk increases over the course of a shift in an approximately exponential manner such that shifts longer than about 8 hours are associated with a substantially increased risk. Thus, for example, it has been estimated that, all other factors being equal, the risk on a 12-hour shift system is some 27.6% higher than that on an 8-hour system. Shifts longer than 12-hours should thus clearly be considered as undesirable. For the same reason, it would seem wise to limit the extent to which a shift can be lengthened by overtime to 13 hours. Likewise, it would seem prudent to ensure that the break between two successive shifts is sufficient to allow the individual concerned to travel home, wind-down sufficiently to sleep, have a full 8-hour sleep, have at least one meal, and travel back to work. The EU’s Working Time Directive sets this limit at 11 hours, and this would be consistent with a maximum work duration, including overtime, of 13 hours. Three daily limits are thus recommended, namely:

1 No scheduled shift should exceed 12 hours.

2 No shift should be extended beyond a total of 13 hours by overtime.

3 A minimum rest period of 11 hours should be allowed between the end of shift and the beginning of the next, and this should not be compromised by overtime.

Breaks There is surprisingly little evidence on the beneficial effects of breaks on risk. However, there is evidence that fatigue builds up over a period of work, and that this can be, at least partially, ameliorated by the provision of breaks. There is also recent, and as yet unpublished, evidence that risk behaves in a similar manner, increasing in an approximately linear fashion between breaks. It would thus seem sensible to recommend limits on the duration of work without a break, and on the minimum length of breaks. It should be emphasised here that there is some evidence to suggest that frequent short breaks are more beneficial than less frequent longer ones. However, it is recognised that work demands may prevent the taking of frequent short breaks. In the light of this, and of the findings from the survey regarding the provision of breaks, two limits are thus recommended, namely:

1 A maximum of fours hours work before a break.

2 A minimum break period of ten minutes plus five minutes for each hour worked since the start of the work period or the last break.

Weekly Limits Fatigue accumulates over successive work periods and it is thus necessary to limit not only the daily work hours, but also the amount of work that can be undertaken over longer periods of time. The aim here is to ensure that any accumulation of residual fatigue is kept within acceptable limits, and can be dissipated over a period of rest days. However, if these limits are simply related to the calendar week this can result in unacceptably high numbers of shifts or work-hours between successive periods of rest days. It is thus necessary to express the limits with respect to any period of seven successive days. In the light of this, and the findings from the survey, the following recommendations are made:

1 Scheduled work hours should not exceed 48 hours in any period of seven successive days.

2 Total work; including overtime, should not exceed 60 hours or seven successive work days before a period of rest days.

3 A period of rest days should include a minimum of two successive rest days continuous with the 11 hours off between shifts (i.e. a minimum of 59 hours off). This limit should not be compromised by overtime.

Annual Limits Some residual fatigue may accumulate over weeks and months despite the provision of rest days, therefore annual leave is important. There is, however, little evidence to indicate what might be considered an ideal number of days annual leave.



AMC 145.A.65(b) Safety and Quality Policy, Maintenance Procedures and Management Systems It is acceptable for a Part 145 organisation to have procedures where all employees report any differences between their procedures and how the work is performed through their organisation’s occurrence reporting system or another dedicated feedback mechanism.

An acceptable means of compliance to the requirement for an AMO to ensure that any employee capacity to perform maintenance is not significantly impaired, is for the AMO’s approved Safety Management System to include

1 A Drug and Alcohol Management Plan (DAMP) as required by Part-99;

2 A Fatigue Risk Management System (FRMS);

Fatigue Risk Management Systems Large AMO’s that perform maintenance utilising night shifts and seven-day rosters, may develop Fatigue Risk Management Systems as an acceptable means of compliance to the intent of MOS paragraph 145.A.65(b)7. For smaller AMO’s that do not use shift rosters, a more simple policy to limit duty hours and overtime may be acceptable.

GM 145.A.65(b)8. Safety and Quality Policy, Maintenance Procedures and Management Systems The purpose of this procedure is to minimise the rare possibility of an error being repeated whereby identical aircraft components may be incorrectly reassembled thereby compromising more than one system. An example is the remote possibility of failure to reinstall engine gearbox access covers or oil filler caps on all engines of a multi-engined aircraft resulting in oil loss from all engines.

Procedures should be established to detect and rectify maintenance errors that could, as a minimum, result in a failure, malfunction or defect endangering the safe operation of the aircraft if not performed correctly. The procedure should identify the method for capturing errors, and the maintenance tasks or processes concerned.

In order to determine the work items to be considered, the following should primarily be reviewed to assess their impact on safety:

1 Installation, rigging and adjustments of flight controls; 2 Installation of aircraft engines, propellers and rotors; 3 Overhaul, calibration or rigging of components such as engines, propellers, transmissions and

gearboxes; and 4 Additional information should also be considered arising out of such systems as the occurrence

reporting system and maintenance error investigations. In order to prevent omissions, a maintenance certification should be performed for each maintenance task or group of tasks. To ensure the task or group of tasks is completed, it should only be certified for after completion. Where a maintenance certification is performed following the completion of a group of tasks, the AMO’s procedures should provide a means by which the certifying employee may verify completion of each of the steps. The grouping of tasks for the purpose of maintenance certification should allow critical steps to be clearly identified and a maintenance certification should be issued for each critical step.

GM 145.A.65(c)1. Safety and Quality Policy, Maintenance Procedures and Management Systems The primary objectives of the quality system are to enable the organisation to ensure that it can deliver a safe product and that the organisation remains in compliance to the requirements.



An essential element of the quality system is the independent audit. This is an objective process of routine sample checks of all aspects of the organisation’s ability to carry out all maintenance to the required standards and includes some product sampling as this is the end result of the maintenance process. It represents an objective over view of the complete maintenance related activities and is intended to complement the requirement of MOS paragraph 145.A.50(a) for certifying staff to be satisfied that all required maintenance has been properly carried out before issue of the certificate of release to service. Independent audits should include a percentage of random audits carried out on a sample basis when maintenance is being carried out. This means some audits should be conducted during the night if the organisation provides maintenance services at night.

It is intended that the requirements for independent quality surveillance and 12 monthly audits be provided by a department or group separate from the maintenance department, in order to achieve compliance determinations independent from the standpoint of the maintenance department, or commercial imperatives that may affect the judgement of maintenance management of the Organisation. CASA would expect that an organisation that has 10 or more employees involved in aircraft or aeronautical product maintenance should have a quality management system that is capable of achieving satisfactory independence of quality monitoring functions by virtue of its structure.

AMC 145.A.65(c)1. Safety and Quality Policy, Maintenance Procedures and Management Systems

1 An acceptable procedure for an independent surveillance auditing program is one that ensures that all aspects of Part 145 compliance are checked every 12 months by quality audit individuals that are independent of and not responsible for the maintenance functions, procedures or products that are being checked and who report to the quality manager. The independent surveillance programme may be carried out as a complete single exercise or subdivided over the 12 month period in accordance with a scheduled plan. The independent surveillance programme need not require each procedure to be checked against each product line when it can be shown that the particular procedure is common to more than one product line and the procedure has been checked every 12 months without resultant findings. Where non-conformances have been identified, the particular procedure will be rechecked against other product lines until the non-conformances have been rectified after which the independent audit procedure may revert back to 12 monthly for the particular procedure. For the purpose of the independent surveillance auditing programme, a product line includes any product under an Appendix 2 approval class rating as specified in the approval schedule issued to the particular organisation.

2 An acceptable independent surveillance audit programme will generate a report each time an audit is carried out describing what was checked and the resulting findings against applicable requirements, procedures and products.

3 An acceptable means of compliance for a large maintenance AMO that employs more than about 500 individuals for the performance of maintenance is to have a dedicated quality audit group whose sole function is to conduct audits, raise non-compliance reports and follow up to check that the findings are being rectified.

4 For a medium sized AMO with less than about 500 employees involved in maintenance, it is acceptable to use competent employees from one section or department not responsible for the production function, procedure or product to audit the section or department that is responsible subject to the overall planning and implementation being under the control of the quality manager.

5 Providing that the Quality Manager retains the responsibilities and oversight of the system as outlined in paragraph 145.A.30 (c)1 of the MOS, including overall planning and implementation, the functions of the quality system may be achieved in a number of ways, including: (a) For a medium sized AMO with less than about 500 employees involved in maintenance, it is

acceptable to use competent employees from one section or department not responsible for the



production function, procedure or product to audit the section or department that is responsible;

(b) For a small AMO where independence of the quality monitoring functions cannot be achieved, the Organisation may have procedures that allow another AMO or a person with appropriate technical knowledge and audit experience to perform the audits mentioned in paragraph 145.A.65(c)1;

(c) Where one or more Part 145 organisations exist within a business group or operator, a department of the group may provide the quality functions (including the monitoring and surveillance functions) for any or all of the group’s Part 145 organisations, providing that the manager responsible for the department that provides the quality functions must be the Quality Manager nominated for each of the Part 145 organisations.

GM 145.A.65(c)2. Safety and Quality Policy, Maintenance Procedures and Management Systems An essential element of the quality system is the quality feedback system. By virtue of the nature of this system requirement, it cannot be contracted to outside persons. The principal function of the quality feedback system is to ensure that all non-compliance findings resulting from the independent surveillance audit programme are properly investigated, corrected in a timely manner and to enable the accountable manager to be kept informed of any safety issues and the extent of compliance with Part 145.

AMC 145.A.65(c)2. Safety and Quality Policy, Maintenance Procedures and Management Systems An acceptable quality feedback system will ensure that audit reports referenced in paragraph 145.A.65(c)0 sub-paragraph 2 are sent to relevant departments for rectification action. Target rectification dates will have been discussed with such relevant departments prior to inclusion in the audit reports.

GM 145.A.65(d) Safety and Quality Policy, Maintenance Procedures and Management Systems It is intended that a Safety Management System’s Safety Assurance provisions as described in appendix I, include procedures for independent safety audits and safety investigation, to be provided by a department or group separate from the maintenance department, in order to achieve safety assurance determinations independent from the standpoint of the maintenance department, or commercial imperatives that may affect the judgement of maintenance management of the Organisation. CASA would expect that an organisation that has 10 or more employees involved in aircraft or aeronautical product maintenance should have a Safety Management System that is capable of achieving satisfactory independence of Safety Assurance functions by virtue of its structure.

AMC 145.A.65(d) Safety and Quality Policy, Maintenance Procedures and Management Systems Providing that the Safety Manager retains the responsibilities and oversight of the system as outlined in paragraph 145.A.30 (c)2 of the MOS, the functions of the safety management system may be achieved in a number of ways:

1 For a Part 145 organisation, the Organisation may establish its Safety Management System in accordance with guidelines provided in Appendix I of this AMC/GM; or

2 Where one or more Part 145 organisations exist within a business group or operator, a department of the group may provide the safety management functions (including any monitoring and



surveillance functions) for any or all of Part 145 organisations, if the manager responsible for the department that provides the safety management functions is the Safety Manager nominated for each of the Part 145 organisations; or

3 For a small AMO where the independence of any safety assurance functions within the Safety Management System cannot be achieved, the Organisation may have procedures that allow for the provision of those safety audit and investigation functions by:

(a) Another AMO or a person with appropriate technical knowledge and audit experience; or

(b) An operator that holds an SMS as a requirement of its AOC to provide the safety management functions referred to in paragraph 145.A.65(d).

GM 145.A.70(a)10. Maintenance Organisation Exposition The AMO’s Approval Certificate issued by CASA lists main locations nominated by the organisation. Additionally the AMO must list in its exposition, other locations that it will normally use, in accordance with paragraph 145.A.70(a)15.

The Approval Certificate outlines limitations applied to the scope of maintenance for which the AMO will be approved. This scope of maintenance applies to the organisation as a whole and the 145.A.70(a)10 requirement is for the organisation to outline what scope of maintenance it intends performing at each of its normal locations.

The scope of maintenance at any location may not exceed the statements of limitation on the certificate. If an AMO wishes to perform maintenance beyond the limitations stated on its approval certificate, an application for significant change to its approval is required.

AMC 145.A.70(a)10. Maintenance Organisation Exposition The AMO may choose to have all its locations listed on the certificate, and the limitations on the certificate closely defining the capability of the AMO at those locations. If this is the case, the AMO’s statement of capability may be a simple correlation of which activity listed on the certificate is intended to be performed at which location.

The statement of capability may also be a substantial process for the management of capability within broader limitations specified on the certificate, and the management of those capabilities at each of the locations listed on the certificate and in the exposition. Under this provision an acceptable procedure for the management of capability will show that assessment of available personnel, facilities, equipment and data meets the regulatory requirements and the requirements of this MOS, for each location.

AMC 145.A.70 Maintenance Organisation Exposition The information specified in MOS paragraphs 145.A.70 (5), (6), and (13) to (16) inclusive, whilst a part of the maintenance organisation exposition, may be kept as separate documents or on separate electronic data files subject to the management part of said Exposition containing a clear cross reference to such documents or electronic data files.

GM 145.A.75 Privileges of the Approved Maintenance Organisation Sub-contracting Maintenance A Registered Operator of large aircraft or aircraft operated for passenger operations will have to contract a Part 145 Approved Maintenance Organisation (AMO-1) to carry out the maintenance required on the aircraft and their aeronautical products, provided that AMO-1 has the approval rating for the aircraft and/ or products concerned as part of its approval. However if the AMO-1 does not have an approval rating for



part of the required work or components, it may subcontract out that portion of work to another AMO (AMO-2) that does have the approval to do so.

In this case, AMO-2 must also be a Part 145 Approved Maintenance Organisation with the contracted scope of work covered within its approval rating.

Additionally AMO-1 may subcontract to another organisation a portion of the work that it was contracted by an operator to carry out, if it has the approval scope to carry out that work. In this case the subcontracted organisation does not have to be an approved organisation for the scope of work undertaken; however AMO-1 must have an approval rating for the aircraft or aeronautical product to be maintained and AMO-1 must have a procedure in its exposition showing how it will control and monitor the subcontractor. When work is carried out under this provision the Quality System of AMO-1 is considered to be extended to include the subcontractor for that maintenance and AMO-1 must ensure that the subcontractor meets the requirements of Part 145 for that time.

Where a subcontracted organisation is not Part-145 approved, part of the control and oversight by the AMO includes monitoring and surveillance by the AMO’s Quality System, as any maintenance provided by the subcontractor would be performed under the approval of the AMO. To facilitate subcontracting such non-approved organisations and to ensure compliance to MOS paragraph 145.A.65(c)5 the AMO’s Exposition will need to include a control procedure that details the process for control of sub-contractors, including;

A pre audit procedure whereby the AMO will determine whether the sub-contractor will be able to meet the intent of Part-145 in providing the services that the AMO wishes to utilise and; Details of Quality Audits planned and performed are recorded, including

findings, corrective and preventative actions and; Records are kept of when the sub-contractors are utilised and; A clear revocation process for sub-contractors that fail to maintain the AMO’s requirements.



Appendix I Safety Management Systems A Safety Management System (SMS) is an organised approach to managing safety, including adoption of the necessary organisational structures, accountabilities, policies and procedures. It is Systemic in that safety management activities are carried out in accordance with a pre-determined plan, and applied in a consistent manner throughout the organisation. It is proactive in that it takes an approach that emphasizes prevention, through hazard identification and risk control and mitigation measures, before events that affect safety occur. It is also Explicit, it that all safety management activities are documented, visible and performed as an essential component of management activities. The complexity of the SMS should match the organisation’s requirements for managing safety. Complex Safety Management Systems may be inappropriate for small organisations. These organisations should tailor their SMS to suit the size, nature and complexity of the operation and allocate resources accordingly. Guidance for small organisations is specifically covered in this document.

For Part-145 Approved Maintenance Organisations, safety management should be a core business function, as is financial management. Addressing safety in a systemic, proactive and explicit manner ensures that on a long-term basis, safety becomes an integral part of the day-to-day business of the organisation and that the safety related activities of the organisation are directed to the areas where the benefits will be greatest. Effective safety management results a realistic balance between safety and production goals. Thus a coordinated approach in which the organisation’s goals and resources are analysed helps to ensure that decisions concerning safety are realistic and complementary to the operational needs of the organisation.

At the core of the SMS is a formal Risk Management process that identifies hazards and assesses and mitigates risk. Safety management is evidence-based, in that it requires the analysis of data to identify hazards. Using risk assessment techniques, priorities are set for reducing the potential consequences of the hazards.

1 Safety Management Process Strategies to reduce or eliminate hazards are developed and implemented with clearly established accountabilities. The situation is reassessed on a continuing basis and additional measures are implemented as required. Stages of the safety management process are outlined below.

Collect the Data The first step in the safety management process is the acquisition of the relevant safety data – the evidence necessary to determine safety performance or to identify latent unsafe conditions (safety hazards). The data may be derived from any part of the system: the equipment used, the people involved in the operation, work procedures, the human/ equipment/ procedures interactions, etc.



Safety ManagementProcess

Collect Data

Prioritise Unsafe Conditions

Analyse Data

Develop Strategies

Approve Strategies

Assign Responsibilities

Implement Strategies

Re-evaluate Situation

Collect Additional Data

Figure SMS.1 Safety Management Process

Analyse the Data By analysing all the pertinent information, safety hazards can be identified. The conditions under which the hazards pose real risks, their potential consequences and the likelihood of occurrence can be both qualitative and quantitative.

Prioritise Unsafe Conditions A risk assessment process determines the seriousness of hazards. Those posing the greatest risks are considered for safety action. This may require a cost-benefit analysis.

Develop Strategies Beginning with the highest priority risks, several options for managing the risks may be considered. For example the risk may be spread across as large a base of risk-takers as practicable; the risk may be eliminated entirely; the risk may be accepted and the operation continued unchanged or the risk may be mitigated by implementing measures to reduce the risk or at least facilitate coping with the risk.

Approve Strategies Management approval of agreed strategies is required to proceed. Strategies may need to be shown to have merit by preparation of cost benefit analysis reports or business cases.

Assign Responsibilities and Implement Strategies The details of an implementation plan must be formulated, including the determination of resource allocation, assignment of responsibilities, scheduling, revisions to operating procedures, etc.



Re-evaluate Situation Re-evaluation of the original situation should determine the effectiveness of the strategies implemented; whether new problems may gave been introduced, how well the strategy for risk reduction meets performance expectations and whether modifications to the system or process may be required.

Collect Additional Data Depending on the re-evaluation stage, new or additional information may be required and the full process repeated to improve the safety action strategy.

2 Safety Management System Implementation Plan The first step, when introducing SMS into an organisation, is to develop an implementation plan. This will be a realistic strategy for the implementation of SMS that meets the needs of the organisation and defines the approach taken for managing safety. The contents of the plan should include:

1. Safety policy; 2. Safety planning objectives and goals; 3. System description; 4. Gap analysis; 5. SMS components; 6. Safety roles and responsibilities; 7. Safety reporting policy; 8. Means of employee involvement; 9. Safety communication; 10. Safety performance measurement; 11. Management review of safety performance; and 12. Safety training.

Small Organisations For a small organisation a simplified SMS implementation plan should be developed that includes:

The organisation’s approach to managing safety in a manner that meets its safety needs;

Coordination with the SMS of other organisations with which it interfaces during the provision of services; and

Endorsement by senior management and communication throughout the organisation.

3 The Components of a Safety Management System (SMS) A Safety Management System should comprise the following four components:

1. GM – Safety Policy, Objectives and Planning; 2. GM – Safety Risk Management; 3. GM – Safety Assurance; and 4. GM – Safety Promotion.



Figure SMS.2 SMS Framework

GM – Safety Policy, Objectives and Planning Management Commitment and Responsibility The Chief Executive Officer (CEO) and Accountable Manager demonstrate their commitment to safety by:

Recruiting a management team appropriate to the size and complexity of the organisation; Developing and disseminating a safety policy/ safety objectives; Creating and adequately resourcing a SMS program; and Specifying roles, responsibilities and accountabilities of the management team in relation to

aviation safety.

Senior management should develop an organisational structure that has the responsibility, authority and accountability assigned to it to assure the Safety Management System will function as planned. This would include an organisation chart that depicts the organisation structure inclusive of the SMS that establishes a clear line of communication from the Safety Manager (SM) directly to the Accountable Manager.

Safety Policy Management commitment to safety needs to be clearly expressed in a statement of the organisation’s safety policy, which outlines what the organisation will do to achieve the desired safety outcomes and that serves as a reminder as to ‘how we do business around here’.

A safety policy may take different forms, but will typically include statements concerning; The overall safety objective of the organisation; The commitment of senior management to the goal of ensuring that all aspects of the operation

meet safety performance targets; A commitment by the organisation to provide the necessary resources for the effective

management of safety;



The organisation’s policy concerning responsibility and accountability for safety at all levels of the organisation; and

Management’s explicit support of a ‘just culture’ as part of the overall safety culture of the organisation.

A typical SMS safety policy may include references to other programs, for example Occupational Health and Safety, Quality Management Systems, environmental management systems, security management systems.

Just Culture A ‘just culture’ provides clear boundaries about confidentiality, reporting requirements, and individual responsibilities in relation to the SMS as far as management and staff are concerned. However, in a ‘just culture’ policy, a clear distinction is required between what is acceptable behaviour and what is unacceptable, and that people are treated accordingly. ‘Just culture’ is a necessary evolution from the ‘blame free’ culture of the past.

Safety Objectives Safety objectives should state an intended safety outcome. They may be expressed in terms of short, medium and long term safety objectives.

To be able to measure the effectiveness of operational safety objectives, they should be Specific, Measurable, Achievable and Realistic; and have a specified Timeframe (SMART) within which they are to be achieved.

The operator should have documented plans of action to achieve each specified safety objective, and these should ideally be included within the implementation plan.

Safety Accountabilities of Managers The Accountable Manager of the organisation is ultimately accountable for the SMS and must provide resources essential to implement and maintain the program.

As the Responsible manager for the SMS, the Safety Manager will need to work with the management team to meet the objectives of the SMS. The structure of the organisation needs to be documented so that everyone understands their role and responsibilities. The Safety Manager is responsible to the Accountable Manager, who is ultimately accountable for the operation of the SMS. When formalising the organisation structure, it is important to remember that the Safety Manager needs direct access to the Accountable Manager.

The roles, responsibilities and accountabilities of the positions outlined on the organisational chart should be explicit with respect to the SMS.

All management and supervisory positions in addition to the Safety Manager would be expected to show leadership and have included in their responsibilities/ accountabilities a requirement to:

Actively support and promote the Safety Management System; Ensure due processes and procedures needed for safe operations are in place; Ensure that they and their staff comply with the SMS processes and procedures; Ensure resources are made available to achieve the outcomes of the SMS; and Continually monitor their area of responsibility, as outlined in the SMS Manual.

Appointment of Key Safety Personnel Large Organisations – A large organisation may have a dedicated Safety Department, led by the Safety Manager however named. There would be scope within the department to appoint a deputy Safety Manager and additional personnel as required.



Medium Organisations – A medium sized organisation may have a separate Safety Manager, possibly with a small number of staff. There would be scope for one of the ‘Safety Representatives’ to be appointed as deputy when required. The safety representative could be a front line staff member.

Safety Manager – roles, Responsibilities and Qualifications: Depending on the size of the organisation, the Safety Manager should possess operational management experience and an adequate technical background to understand the systems that support operations. Operational skills alone will not be sufficient. The Safety Manager should have a sound understanding of safety management principles, typically acquired through formal training and experience.

Depending on the size of the organisation, senior management should appoint a SM who, irrespective of other duties, will have responsibilities and authority that includes:

Ensuring that processes needed for the SMS are established, implemented and maintained; Reporting to the CEO on the performance of the SMS and the areas where improvement is

required; and Ensuring the promotion of awareness of safety requirements throughout the organisation.

The Safety Manager will be the catalyst to develop and mature the SMS over time, through engagement with the organisation’s executive, management at all levels and operational staff.

The Safety Manager is responsible for accomplishing tasks and functions of the SMS. The role and responsibilities of the Safety Manager are specified in the SMS Manual.

The Safety Manager needs to be ‘independent’ from operational areas, and have a direct reporting line to the Accountable Manager. A formal reporting line direct to the Accountable Manager gives the Safety Manager the ‘authority’ to look across the organisation from the safety perspective. The Safety Manager may have staff to assist in the role, and where possible, should also be assisted by safety representatives from each department or functional area.

Safety Responsibilities The SM is not the sole person responsible for safety. Specific safety activities and functional or operational safety performance outcomes are the responsibility of the relevant operational or functional managers, and senior management must not hold the Safety Manager accountable for line managers’ responsibilities. The Safety Manager should monitor all cross functional or departmental SMS activities to ensure their relevant integration. While the Safety Manager may be held accountable for the satisfactory administration and facilitation of the SMS itself, they should not be held accountable for the safety performance of the organisation — the Accountable Manager alone is accountable, except that if the Accountable Manager is not the CEO of the organisation, the CEO is also accountable for Safety.

The Safety Manager is responsible for, but not limited to: Drafting the SMS Manual; Implementing, maintaining reviewing and revision of the Safety Management System; Regular evaluation, reviews and fin-tuning of the Safety programme; Providing safety advice to management and staff; Providing timely advice and assistance on safety matters to managers, staff and contractors at all

levels; Communicating with heads of departments on safety related issues; Promoting safety awareness and a positive safety culture; Liaison with CASA and the Australian Transport Safety Bureau (ATSB) on safety-related issues; exchange of valuable lessons learned with other operators; Researching and sharing safety related information with other key safety personnel in the

organisation;



If delegated by the CEO, chairing the safety committee/ Safety Review Board; Incident and accident investigations; Managing immunity-based reporting systems (confidential reports); Monitoring the progress of safety reports and ensuring that hazards are addressed in a timely

manner; Maintaining an appropriate reporting system to identify hazards, which includes the ongoing

identification and management of hazards; Overseeing the reduction of hazards to ensure that they are as low as reasonably practicable ; Maintaining safety documentation; Ensuring SMS induction and recurrent training are conducted in accordance with the SMS

Manual; Identifying ongoing safety training requirements to support the SMS programme objectives; Overseeing the internal and external SMS audit programmes; Emergency response planning; and Maintaining the Emergency Response Plan.

Qualifications The Safety Manager’s qualifications and attributes may include the following:

broad operational knowledge and experience in the functions of an aviation organisation; Sound knowledge of safety management principles and practices; Sound knowledge and understanding of HF; Good written and verbal communication skills; Well-developed interpersonal skills; Computer literacy; The ability to relate to all levels, both inside and outside the organisation; Organisational ability; Capable of working unsupervised; Good analytical skills; Leadership skills and an authoritative approach; Worthy of respect among peers and management; Instructional qualifications and experience; for example, Certificate IV in Workplace Training and

Assessment; Knowledge of document procedure design; Sound understanding of hardware and software issues as it relates to SMS; and Good understanding of aviation operations.

Personal Traits Ideally the Safety Manager should possess qualities such as:

fairness; Assertiveness; Impartiality; Trustfulness; Integrity; Excellent communication skills; and Unbiased thinking.



The SM should be a person who is approachable, convincing, and who remains composed in adverse situations and above all is tenacious. Successful safety culture change related to SMS implementation takes time and ongoing commitment by the program manager.

If the Safety Manager lacks credibility, so will the SMS and the behaviour and attitude of staff will tend to be negative.

Training the person selected as the Safety Manager will need to be familiar with most aspects of the organisation, its activities and personnel. These requirements may be met in-house or from external courses, however, much of the Safety Manager’s knowledge will be acquired by self-education.

Areas where Safety Managers may require formal training include: HF principles; Integration of HF into an SMS; Understanding the role of human performance in accident prevention and causation; Familiarisation with different fleets, types of operations, routes, etc.; Understanding the role of human performance in accident causation and prevention; Development, implementation, operation and maintenance of an SMS; Accident and incident investigation; Crisis management and emergency response planning; Safety promotion; Communication skills; Computer skills such as word-processing, spreadsheets and database management; and Specialised training or familiarisation in, for example, Crew Resource Management (CRM),

Threat and Error Management (TEM), Fatigue Risk Management Systems (FRMS) and Safety/ Compliance Auditing.

Deputy Safety Manager Importantly, organisations need to give due consideration to deputising the Safety Manager’s role during periods of absence or depending on the size and complexity of the organisation.

Safety Committee and Action Groups If the organisation is large and complex then it is expected that there would be more than one group established to support the SMS program objectives. Typically, there would be a high level safety Committee (Safety Review Board (SRB)) to oversee the SMS program, and on or more Safety Action Groups (SAGs) who take strategic direction from the Safety Committee. Smaller and less complex organisations may only need to establish a Safety Committee.

Safety Committee (Safety Review Board (SRB)) A high level Safety Committee or SRB would normally be necessary for functional or senior management involvement on safety policy, overall system implementation and safety performance review purposes. Membership and level of participation in the safety committee would depend on the size and structure of the organisation. The Accountable Manager should chair this committee with representation from all relevant functional areas of the organisation. However if the Accountable Manager should choose to assign this task to an appropriate person, it should be clearly stated and substantiated in the SMS manual that the substituted chairperson is performing the task on behalf of the Accountable Manager whose accountability for safety is not compromised and that the Accountable Manager remains accountable for all decisions of the Safety Committee/ SRB.



A Safety Committee would typically consist of the Accountable Manager, the Safety Manager and other members of the senior management team. The objective of the Safety Committee is to provide a forum to discuss safety issues and the overall health and direction of the SMS. The role of the Safety Committee may include:

Making recommendations or decisions concerning safety policy and objectives; Defining safety performance indicators and setting safety performance targets for the

organisation; Reviewing safety performance and outcomes; Providing strategic directions to departmental SAGs – if established; Directing and monitoring the initial SMS implementation process; and/or Terms of reference for the safety committee should be documented in the SMS manual.

The membership of the Safety Committee/ SRB may, for example comprise: The Accountable Manager (Chair) Head of Safety Department/ Safety Manager (Secretary) Responsible and other senior Managers as required.

Safety Action Groups Safety Action Groups are accountable to, and take strategic directions from, the Safety Committee. Managers and supervisors from a given functional area would be members of the SAG for that area. The functional head of that area should chair the SAG. The role of the SAGs would include:

Overseeing operational safety within the functional area; Managing the area’s hazard identification activities; Implementing mitigation or corrective actions relevant to the area; Assessing the impact of safety on operational changes and activating hazard analysis process as

appropriate; Maintenance and review of relevant performance indicators; and Managing safety training and promotion activities within the area.

Departmental SAGs may appoint ‘SMS Coordinators’ to facilitate the department’s SMS activities.

Safety Management System Implementation Plan The SMS Implementation plan should detail all aspects of the development and implementation of the SMS. It is expected that the SMS program will mature over time through a process of continuous improvement. The implementation plan should address all area covered in the SMS Manual.

The planning (or establishment) group should identify existing resources; knowledge, experience and internal procedures in the organisation for the investigation of incidents, hazard identification, safety monitoring etc, for the integration into the SMS.

Third Party Interfaces – Contracted Activities Where an AMO sub-contracts activities to another organisation the AMO’s SMS is considered to extend to the sub-contracted organisation in the same way as the AMO’s Quality Management System (Ref AMC.145.225). Whether the AMO is a large or small organisation, it holds overall responsibility for the safety of services provided by the sub-contracted organisation and for ensuring that the sub-contractor complies with the safety standards prescribed in the contract. The AMO should ensure that the sub-contractor understands the AMO’s SMS and its responsibilities relating to it. These factors should be given equal weight with other considerations such as price, quality and timely delivery.



As a general guideline, a third party contract or service level agreement should include the following as a minimum standard:

any agreement for the provision of services should be supported by a written contract prior to services commencing;

all third party providers should hold the appropriate qualifications / credentials or approvals for the work being outsourced;

all written service level agreements should contain a schedule of oversight to monitor the third party’s performance on a regular basis;

where a service being provided is conducted under a licence or certificate approved by CASA, the written agreement should contain a statement requiring the third party to advise the contracting organisation of any regulatory action undertaken by CASA that may impact on the third party’s ability to provide the required services.

Coordination of the Emergency Response Plan (ERP) An Emergency Response Plan may be documented in a separate manual or incorporated into the organisation’s SMS manual. It is an integral part of the SMS, and is activated in the event of a major adverse occurrence to ensure the following:

Orderly and efficient transition from normal to emergency operations; Delegation of emergency authority; Assignment of emergency responsibilities; Authorisation by key personnel for actions contained in the plan; Coordination of efforts to cope with the emergency; Safe continuation of operations or return to normal operations as soon as possible; Planned and coordinated action to ensure the risks attributable to a major safety event can be

managed and minimised.

Constituent elements of an Emergency Response Plan include: Purpose of the ERP; Activation of the organisational ERP; External agency interface (for example; aerodrome ERP, ATSB, CASA, coroner); Passenger and crew welfare; Casualty and next-of-kin coordination; Accident investigation; Organisation ERP response – accident site Preservation of evidence; Media relations; Claims and insurance procedures; Aircraft wreckage removal; and Emergency response training.

Documentation The AMO’s SMS manual should effectively and concisely communicate the organisation’s approach to safety to the whole organisation. It should be regularly amended, controlled and distributed to reflect ongoing development and changes to the system. The following components and elements should to be documented:

Safety policy, objectives and planning: • management commitment and responsibility;



• safety accountabilities of managers; • appointment of key safety personnel; • SMS implementation plan; • coordination of the emergency response plan; • third-party interfaces – contracted activities; and documentation.

Safety risk management: • hazard identification processes; • risk assessment and mitigation processes; and • internal safety investigations.

Safety assurance: • safety performance monitoring and measurement; • the management of change; and • continuous improvement of the safety system.

Safety training and promotion: • training and education; and • safety promotion.

GM – Safety Risk Management Australian/New Zealand Standard (AS/NZS) 4360 Risk Management defines Risk Management as: ‘The culture, processes and structures that are directed toward realising potential opportunities whilst managing adverse effects’.

The process of risk management involves establishing an appropriate infrastructure and culture and applying a logical and systematic method of establishing the context, identifying, analysing, evaluating, treating monitoring and communication risks associated with any activity, function or process in a way that will enable organisations to minimise losses and maximise gains.

Risk management can be applied at many levels in an organisation, from strategic to operational. The objectives of risk management are to eliminate risk where practical, or reduce the risk (probability / consequence) to acceptable levels and to manage the remaining risk so as to avoid or mitigate any possible undesirable outcome of the particular activity. It is therefore an integral part of any Safety Management System.

Risk Criteria and the concept of ALARP

The risk of accidents or incidents occurring can be minimised by the use of proactive safety risk management strategies that identify and manage vulnerabilities to take necessary actions to reduce the risk of adverse consequences arising from them.

Where risk is concerned, there is no such thing as absolute safety. In committing to aviation, it has to be accepted that not all risk can or should be eliminated. There are practicable limits to which the aviation industry is able to go and the extent to which the industry and the community will pay to reduce adverse risks. Risk management systems are premised on the concept that management of risks should mitigate vulnerabilities so that risks are As Low as Reasonably Practicable (ALARP).

To manage risk to ALARP levels, the following principles apply: There is an upper level of risk that is deemed to be intolerable. If a risk is found to be intolerable,

risk reduction measures are essential, regardless of cost;



There is a lower level of risk that is deemed to be broadly acceptable. At this risk level (and below), maintain current systems and monitor and review the risk. Further risk reduction may be made, but only if the cost is insignificant; and

The ALARP region lies between the upper and lower levels of risk. If risk falls into this region, it should be reduced as much as is reasonably practicable.

In the ALARP region, risk reduction measures must be identified and evaluated in terms of cost and possible risk benefit. Any risk falling within the ALARP range must be assessed and reduced unless the cost of reducing the risk is grossly disproportionate to the benefit gained. This comparison may be a quantitative one, or based on qualitative arguments.

Figure SMS.3 Tolerability of Risk (TOR) Triangle

A risk can only be said to be ALARP when it can be demonstrated that all justifiable risk reduction measures have been considered and any remaining mitigation strategies cannot be justified.

The ALARP principle operates in an environment of continuous improvement. Both the risks and the methods of control change and evolve over time and consequently require a continual reassessment as to which risks, and their respective treatments are reasonable to sustain and which are not.

Hazard Identification Processes Hazards can combine in unforeseeable ways, so that even apparently trivial hazards can result in undesirable outcomes which may have catastrophic results.

Consequently the starting point for the whole safety risk management process must be establishment of the context and hazard identification. A systematic and comprehensive process is critical, because hazards not identified at this stage may be excluded from further risk analysis and treatment.

Hazard identification and reporting processes should be open to any employee. It may be achieved through formal or informal processes, at any time as well as under specific conditions such as:

When there is an unexplained increase in safety-related events or infractions; When there are abnormal audit or safety indicator trends;



When major operational changes are planned; Before a new project, major equipment or facility is set up; During a period of significant organisational change.

Hazards can be identified from the organisation’s reactive, proactive and predictive processes. This should include the organisation’s voluntary reporting system, audits and surveys, accident/incident reports as well as industry incident/accident reports.

Hazards can be identified from a range of sources including but not limited to: Brain-storming using experienced operational personnel; Development of risk scenarios; Trend analysis; Feedback from training; Flight data analysis programs; Safety surveys and operational oversight safety audits; Monitoring of normal operations; State investigation of accidents and serious incidents; and information exchange systems (similar

organisations, operators regulators etc.).

Over time, the ‘database’ of reported hazards enables the organisation to: Identify ‘hot’ issues that need particular attention; and Conduct trend analysis that can provide the basis for improvement of hazard identification.

Hazard and Occurrence Reporting Every event requires investigation of the occurrence, factors contributing to it, including organisational and human factors issues that played a role in it, in order to understand why it occurred. Organisational procedures for the internal and external reporting and recording of incidents, hazards and other safety-related issues will facilitate the organisation’s analysis of these events utilising timely collection of accurate and appropriate data. In this way organisations will react to information received and apply the necessary corrective actions to prevent recurrence of the event.

Statutory Reporting Requirements Organisations are required to meet statutory reporting requirements under the Transport Safety Investigation Act 2003. Reportable matters are categorised as Immediately Reportable Matters (IRM) and Routine Reportable Matters (RRM). IRM and RRM are required to be reported to the ATSB. Similarly Approved Maintenance Organisations are required by Part-42 and Part-145 to report certain major defects to CASA and to applicable design authorities. These reports, IRM and RRM pertain to events relating to an organisation’s operations, and therefore should to be included in the organisation’s internal reporting system (IRS), the requirements of which are described in Part-145.

Key Elements – IRS An organisation’s IRS should be accessible to all safety critical personnel and be intuitive in nature to facilitate effective use. It should be supported by a non-punitive reporting policy, have management support and encompass the following fundamental elements:

Procedures for reporting occurrences (including IRM and RRM), hazards, or safety concerns; Methods for the collection, storage and distribution of data (hazard register or log); Procedures for analysing data, safety reports and any other safety related information; Documentation of corrective action and risk reduction strategies; Determination of the effectiveness of corrective action; and Ongoing monitoring and review.



Safety Surveys Safety Surveys may be used as a flexible, cost-effective means to provide for identification and analysis of hazards and safety concerns, where employees are asked to offer opinions on various safety-related issues.

The Safety Survey may be conducted using various formats including electronic or paper-based checklists, questionnaires or interviews. The Survey may be used to establish an organisational benchmark and then re-used as a way of measuring improvement over a period of time.

Affected managers and staff should be given prior notification of intended Safety Surveys and assurance of the confidentiality of responses. They should be used to identify risks while maintaining a non-punitive policy, avoiding criticism of individuals. Safety Surveys should be used rarely enough to maintain participant interest and should not utilise unsubstantiated response data.

Hazard Management Hazard identification and risk projection is achieved by:

Stating the generic hazard (hazard statement), e.g. – an operating aircraft engine; Identifying specific components of the hazard, e.g. – engine intake suction; Project specific risks associated with each hazard, e.g. – foreign object ingestion.

Risk Assessment and Mitigation Processes Following the identification of a hazard, a form of analysis is required to assess its potential for harm or damage. This involves two considerations:

Probability: the probability of the hazard causing adverse consequences. Severity: the severity of the potential adverse consequences.

Risk assessment and mitigation processes analyse and eliminate, or mitigate to an acceptable level, risks that could threaten the capabilities of an organisation.

A system should be developed for assessing and analysing the data collected or derived from the actions outlined above. Information provided by analysis should be distributed to those with a responsibility for operational safety in the organisation.



Risk AssessmentSeverity of occurrence

Identify the hazards to equipment, property, personnel or the organisation.

Hazard Identification Identify the hazards to equipment, property, personnel or the organisation.

Risk AssessmentProbability of occurrence

What is the possibility of it happening?

Risk AssessmentAcceptability

Is the consequent risk acceptable and within the organisation’s safety performance criteria?

Accept the riskTake action to reduce the risk to an acceptable level.

YES NO

Figure SMS 4 Risk Management Processes

Confidential reporting systems should be based on established human factors principles including an effective feedback process.

Risk Risk is the assessed potential for adverse consequences resulting from any hazard, if its potential to cause harm is realised. A hazard has the potential to cause harm, while risk is the likelihood of that harm being realised within a specific time-scale.

Risk Assessment Risk management is the identification, analysis and mitigation of risks associated with the hazards of an organisation’s operations. Risk assessment uses conventional breakdown of risk into its two components – probability of occurrence and severity of the consequences of the occurrence should it take place.

A Risk Matrix is useful for assessing hazards. While the severity of the consequences can be defined, the probability of occurrence may be more subjective, dependent on the organisation’s operational experience. The assessment process should be documented at each stage to form a substantive and transparent record.



Figure SMS.5 Example Risk Assessment Matrix

Severity of Consequences: Aviation Definition Meaning Value Catastrophic Equipment destroyed. Multiple deaths 5 Hazardous A large reduction in safety margins, physical distress or a

workload such that organisations cannot be relied upon to perform their tasks accurately or completely. Serious injury or death to a number of people. Major equipment damage.

4

Major A significant reduction in safety margins, a reduction in the ability of organisations to cope with adverse operating conditions as a result of an increase in workload, or as a result of conditions impairing their efficiency. Serious incident. Injury to persons.

3

Minor Nuisance. Operating limitations. Use of emergency procedures. Minor incident.

2

Negligible Little consequence. 1

Probability of Occurrence: Qualitative Definition Meaning Value Frequent (1 to 10-3 per hour)

Likely to occur many times. 5

Occasional (10-3 to 10-5 per hour)

Likely to occur sometimes. 4

Remote (10-5 to 10-7 per hour

Unlikely, but may possibly occur. 3

Improbable 10-7 to 10-9 per hour

Very unlikely to occur. 2

Extremely improbable Almost inconceivable that the event will occur. 1

Risk Classification: Acceptable The consequence is so unlikely or not severe enough to be of concern; the

risk is tolerable. However, consideration should be given to reducing the risk further to as low as reasonably practicable in order to further minimise the risk of an accident or incident.

Review The consequence and/or probability is of concern; measures to mitigate the risk to as low as reasonably practicable should be sought. Where the risk is still in the review category after this action then the risk may be accepted, provided that the risk is understood and has the endorsement of the individual ultimately accountable for safety in the organisation.



Unacceptable The probability and/or severity of the consequence are intolerable. Major mitigation will be necessary to reduce the probability and severity of the consequences associated with the hazard.

Risk Mitigation: Risks should be managed to be as low as reasonably practicable. Risk must be balanced against the time, cost and difficulty of taking measures to reduce or eliminate the risk. The level of risk can be lowered by reducing the severity of the potential consequences, reducing the probability of occurrence or by reducing exposure to that risk. Corrective action will take into account any existing defences and their inability to achieve an acceptable level of risk. Corrective action should be subject to further risk assessment as outlined above, in order to determine that the risk is now acceptable and that no further risk has been introduced into operational activities.

Safety Risk Management is a formal process that is used to:

Identify hazards associated with an organisation’s operations;

Analyse and assess the risks associated with those hazards; and

Implement controls, when necessary, to prevent future accidents, incidents or occurrences. AS/NZS 4360 outlines the following as the main elements of the risk management process. Other guidance materials and standards may differ with regard to terminology; however the elements described are generally accepted ass essential to a comprehensive and defensible risk management system.



AMC- Safety Risk Management An acceptable risk management process constitutes elements as illustrated in Figure SMS.6:

(a) Communicate and consult Communicate and consult with internal and external stakeholders as appropriate at each stage of the risk management process and concerning the process as a whole.

(b) Establish the Context Establish the external, internal and risk management context in which the rest of the process will take place. Criteria against which risk will be evaluated should be established and the structure of the analysis defined.

(c) Identify risks Identify where, when, why and how events could prevent, degrade, and/or delay the achievement of safety objectives. Sometimes referred to as a Hazard Identification process, this encompasses a number of methodologies in identifying potential threats and past failures in order to determine the extent of the risks associated. Part of this process may include the establishment of a hazard log/register to ensure that hazards are tracked and treated as part of a formal process of prioritisation, documentation and assessment.

Figure SMS.6 Risk Management Process – Overview Source: AS/NZ 4360 (2004)

(d) Analyse risks Determine consequences and likelihood of the event and therefore the level of risk. Identify and evaluate existing controls (measures in place that control the hazard or reduce the likelihood of occurrence or consequence). This analysis should consider the range of potential consequences (both commercial and operational) and how these could occur. The determination may be the result of employing either qualitative, quantitative analysis techniques, or a combination of the two (semi-quantitative).

(e) Evaluate risks



Compare estimated levels of risk against the pre-established criteria of acceptability and consider the balance between potential benefits and adverse outcomes. This enables decisions to be made about the extent and nature of treatments required and about priorities.

(f) Treat risks Develop and implement specific cost-effective strategies and action plans for increasing potential benefits and reducing potential costs and losses.

(g) Monitor and review It is necessary to monitor the effectiveness of all steps of the risk management process. This is important for continuous improvement. Risks and the effectiveness of treatment measures need to be monitored to ensure changing circumstances do not alter priorities.

Safety Recommendations A formal record of each stage of the risk management process should be initiated and kept. Assumptions, methods, data sources, analyses, results and reasons for decisions should all be documented. An organisation should have procedures to communicate the results and recommendations of any safety investigations to appropriate stakeholders.

Small Organisations – Safety Risk Management Safety Risk Management for small organisations should include a process for hazard identification, risk analysis and mitigation, but may do so in a simplified manner.

The Hazard Identification and Risk Analysis Process may involve a risk profiling process that has been developed for activities of the type being conducted and that leads to commonly accepted mitigation strategies that in turn are tracked by the organisation to ensure that they are appropriate to the circumstances and that they are effective.

Safety Risk Management may also use hazard checklists or similar risk management processes that are integrated into the activities of the organisation.

GM – Safety Assurance Processes Quality Assurance uses systemic monitoring and review processes to provide assurance that the quality of the intended product or service to be provided will be of the standard expected by the customer and other stakeholders. Similarly Safety Assurance utilises systemic monitoring and review processes to provide assurance that the Safety Management System is functioning as documented and intended, mitigating risks to a level of predetermined acceptability.

Systems to Achieve Safety Oversight: The following elements are desirable:

An organisation-wide system for the capture of written safety event/issue reports; A planned and comprehensive safety audit review system that has the flexibility to focus on

specific safety concerns as they arise; A published system for the conduct of internal safety investigations, the implementation of

remedial actions, and the communication of such information; Systems for effective use of safety data for performance analysis and for monitoring

organisational change as part of the risk management process; Arrangements for ongoing safety promotion based on the measured internal safety performance

and assimilation of experience of other operations; Periodic review of the continued effectiveness of the safety management system by an internal,

independent body; and



Line managers monitoring work in progress in all safety critical activities to confirm compliance with all regulatory requirements, organisational standards and local procedures.

Safety Performance Monitoring and Measurement Safety management requires feedback on safety performance to complete the safety management cycle. Through feedback, system performance can be evaluated and any necessary changes effected.

Various stakeholders in the organisation require feedback to form an understanding of the level of safety within the organisation for different reasons including:

Staff may need feedback to develop confidence in their organisation’s ability to provide a safe working environment;

Line management requires feedback on safety performance to assist in the allocation of resources between the often-conflicting goals of production and safety;

Passengers are concerned with their own safety; Senior management seeks to protect the corporate image (and market share); and Shareholders wish to protect their investment.

The size and complexity of the organisation will determine the best methods for establishing and maintaining an effective safety performance monitoring program. Organisations providing adequate safety oversight employ some or all of the following methods:

Establishing an effective hazard and occurrence reporting system; Front-line supervisors maintain vigilance (from a safety perspective) by monitoring day-to-day

activities; Regular inspections (formal or informal) are conducted of day-to-day activities in all safety-

critical areas; Employee’s views on safety (from both a general and a specific point of view) are sampled

through safety surveys; All reports of identified safety issues are systematically reviewed and followed up; Safety related data is captured from programs such as Flight Data Analysis, MEDA reports and

Safety Investigations and Safety Audits. Safety data is analysed as part of an independent organised approach to studying safety

performance (safety studies). Internal and externally conducted safety audits are conducted regularly. Safety results are communicated to all affected personnel.

Internal Safety Investigation For every accident or serious incident, there may be hundreds of minor events or near-misses, many of which have the potential to become an accident. It is important that all reported events/hazards be reviewed and a decision taken o which ones should be investigated, and how thoroughly.

The organisational Safety Policy or SMS Protocols would need to state that the purpose of internal investigations is to find systemic causes and implement corrective actions, NOT to apportion blame to individuals. Where a ‘Just Culture’ policy is in place, the Policy and Protocols for internal investigations should clearly reference such policy.

Investigation Management Where the ATSB conducts an investigation into an organisation event, the Safety Manager or delegate would act as the organisation’s point of contact/coordinator for the investigation. This way the Safety Manager will be kept informed as the investigation progresses.



The level of resources allocated to an investigation should be balanced between their availability and the perceived benefit to the organisation in terms of potential for identifying systemic hazards and risks.

Investigations should be documented in order to definitively assure accountability of their management, showing;

The scope of the investigation; The composition of the investigation team, including specialist assistance if required; That the investigation outcomes are recorded for follow-up trend analysis; and That there is a time-frame for completion.

The person in charge of the investigation should have the authority to interview any manager or employee and access any company information source.

Scope of Safety Investigations The extent of the investigation will depend on the actual and potential consequences of the event or hazard. This can be determined through an initial risk assessment. Reports that demonstrate a high potential should be investigated in greater depth than those with low potential.

The investigative process should be comprehensive and should attempt to address the factors that contributed to the event, rather than simply focusing on the event itself – the active failure. Active failures are the actions that took place immediately prior to the event and have a direct impact on the safety of the system because of the immediacy of their adverse effects. They are not, however the root causes of the event; applying corrective actions to these issues may not address the real cause of the problem. A more detailed analysis is required to establish the organisational factors that contributed t the event.



Figure SMS.7 Internal Safety Investigation Process

Change Management Changes within an organisation can result in the creation of hazards that can impact on safety. Changes are often made to the organisation to meet business demands, but while changes need to be made effectively and efficiently, the main focus should always be on implementing the changes safely.

The organisation should identify changes in the business that could have an impact on: Resources – material and human; Management direction – processes, procedures, training; and



Management control.

Typical areas that would require the application of change management procedures include: Changes in an operators’ (customers’) schedules; New or additional locations, temporary or permanent; New or additional approval class, rating or capability; Additional aircraft numbers of a class already maintained; Introduction of new equipment and/or operating procedures; Changes in management or management structure; Restructure of operational departments.

The Approved Maintenance Organisation’s SMS documentation should identify those changes that necessitate formal risk management processes, including Human Factors issues. Also refer to the Integration of Human Factors into SMS in CAAP SMS-2(0).

Continuous Improvement of the Safety System Continuous improvement of the safety system requires management of tow major components:

Maintenance – the objective of which is to maintain current technological, managerial, and operating standards, and

Improvement – which is aimed at improving current standards.

Under the maintenance function, the Safety Manager should first establish a Safety Management System that includes policies, rules, directives and operating procedures (SOP’s) and then work towards ensuring that all employees follow SOP’s as approved in the organisation’s exposition. To achieve this, a combination of discipline and human resource development measures need to be employed.

Under the improvement function, management will be required to work continuously towards revising the current processes in response to changing needs, operational environments or standards.

Management Review Formal management reviews of the SMS should occur on a regular basis. Ideally there would be a quarterly high level review process via the Safety Committee/Safety Review Board to ensure:

That the SMS continues to meet its core safety objectives; Safety performance is monitored against objectives; and Identified hazards are addressed in a timely and appropriate manner.

Following the formal management review, there should be a periodic Safety Action Group (SAG) review process at line management level to include, for example:

Monitoring and reporting on safety management activities by SAG/Safety Committee; Measuring and reporting on safety management performance; Reporting on change management issues; Reporting on resource issues; and Reporting on safety training performance.

A safety review validates the SMS, confirming not only that people were doing what they were supposed to be doing, but also that their collective efforts have achieved the organisation’s safety objectives. Through regular review and evaluation, management can pursue continuous improvements in safety management and ensure that the SMS remains effective and relevant to the organisation’s operation.



Based on the SMS review, recommendations could include: Changed SMS objectives; Changed safety goals/targets; Improved SMS processes/procedures; and/or An implementation plan for improvement changes.

Continuous improvement: Should determine the immediate causes of below-standard performance and their implication in

the operation of the SMS; and Should rectify situations involving below-standard performance identified through safety

assurance activities.

Continuous improvement should be achieved through: Evaluation of facilities, equipment, documentation and procedures through safety audits and

surveys; Evaluation of an individual’s performance to verify the fulfilment of their safety responsibilities; Reactive evaluation in order to verify the effectiveness of the system for control and mitigation of

risk, e.g. incidents, accidents and investigations; and Tracking organisational changes to ensure that they are effective.

AMC –Safety Assurance Processes – Small Organisations For a small organisation of up to ten employees involved in the performance of maintenance, an acceptable Safety Assurance Process consists of periodic external safety audits that assist the organisation in verifying safety performance and rectifying any identified instances of sub-standard SMS performance.

GM – Safety Promotion

Training and Education All employees in the organisation should receive safety training as appropriate for their safety responsibilities. In particular all Operational Staff, Managers, Supervisors, Senior Managers and the Accountable Manager should be trained and assessed as competent to perform their SMS duties.

Operational Staff – should have an understanding of the organisation’s safety policy and an overview of the fundamentals of SMS.

Managers and Supervisors – should understand the safety process, hazard identification, risk management and the management of change.

Senior Managers – should understand organisational safety standards, safety assurance and the regulatory requirements for their organisation.

Accountable Manager – should have an awareness of SMS roles and responsibilities, safety policy, SMS standards and safety assurance.



Safety Communication Safety communication is an essential foundation for the development and maintenance of an adequate safety culture. The modes of communication may include:

Safety policies and procedures; Newsletters; Presentations; Safety notices; and Informal workplace meetings between staff and the Accountable Manager or Senior Managers.

Safety communication should: Ensure that all employees are fully aware of the SMS and the organisation’s safety culture; Convey safety-critical information; Explain why certain actions are taken; Explain why safety procedures are introduced or changed; Complement and enhance the organisation’s safety culture; and Contain a process for assessing the suitability of safety communication and its effect on the

organisation.

AMC – Safety Promotion – Small Organisations

Training All employees should receive safety training as appropriate for their safety responsibilities.

The safety training programme may consist of e-learning or similar training provided by training service providers.

Communication The organisation should establish communication about safety matters that:

Ensures that all employees are fully aware of the SMS; Conveys safety-critical information, and especially that related to assessed risks and analysed

hazards; Explains why particular actions are taken; and Explains why safety procedures are introduced or changed.

Regular staff meetings where information, actions and procedures are discussed may be used for the purpose of communications on safety matters.

acceptable means of compliance (amc) and guidance material...

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