C.1. Site Management and Control

Management of the Instillation The Environmental Management System

SR Technics Ireland Limited operates an environmental management system (EMS) to manage its environmental issues. This system was developed in-house. An Environmental Policy (attachment number C.la) has been created for the facility and it is this policy that acts as a foundation for the EMS. The Environmental Policy is communicated to the workforce via environmental notice boards. The organisational chart (attachment number C.lb) shows the overall organisational structure along with the full environment management team. Environmental responsibilities are defined in the individual job descriptions.

The Environmental Committee

The EMS is structured as a decentralised body within the organisation. As part of the EMS an Environmental Committee has been established which is comprised of key management, specialists and representatives from each section in the Organisation. The Committee is headed by the Facilities Maintenance Manager and is supported by the Environment Officer. The Committee meets on the last Tuesday of each month with minutes taken and distributed to the attendees and

copied to key managers in areas of potentially high environmental impact.

The Environment Management Committee communicates the principals of the Integrated Pollution Control (IPC) Licence to all employees, with particular emphasis on:

> Meeting Licence Conditions,

> Continual Environmental Improvements (including waste minimization).

The Committee undertakes to ensure that staff have Environmental awareness in general and aims to generate and promote em environmental improvements. This involves ident implementation of environmental improvement projects. Receive

'B 5 DEC 2805

The Environmental Management Programme

As part of the company's EMS SR Technics has identified processes that impact on the environment significantly. These are updated each year and an environmental management programme (EMP - Attachment C.lc) has been created to manage these implications. As part of the programme the various forms of media are used to encourage the workforce to participate and identify areas for improvement. Several environmental improvements have been suggested and implemented such as soft drink can and bottle recycling, printer

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cartridge recycling, packaging reuse, etc. The environmental committee reviews how the EMP is progressing on a quarterly basis and also plays an important role in highlighting areas for improvement. There is an annual Environment Management review where a presentation is given to senior management on the environmental performance of the facility.

Environmental Training

SR Technics utilises the in-house training school to develop and implement environmental training programmes. Training is implemented as per procedure ProcE04.Gen (Training). All persons involved in operations that may have potentially significant environmental impacts are trained as part of this system. The need for regular technical training updates relating to aircraft means that there are continual environmental updates delivered to the attendees. Induction training is given to new employees and includes an environmental module.

Preventive Maintenance

A system of preventive maintenance (PM) is operated at the facility and regular checks are carried out on areaditems of plant that have been identified as environmentally sensitive. Calibration is carried out at quarterly intervals (or as necessary within these intervals) on monitoring equipment by an external contractor and certificates of calibration are kept on site. Scheduled monitoring as per the IPC Licence is controlled as per procedure ProcE06.FM (IPC Scheduled Compliance Monitoring). The monitoring frequencies are logged on the companies computerised maintenance management system and a report is produced detailing the type of monitoring that is required when the monitoring period is reached.

The collection and disposal of waste from the various Hangars and Shops is is monitored and controlled by the Environment Officer and the Operations Support

Manager. Non-hazardous waste is controlled via the Operations Support Manager and hazardous waste via the Environment Officer.

Non-hazardous waste is controlled by the following procedures which reflect Licence requirements:

ProcE06.GM (Wheel & Tyre Control)

ProcE02.Mats (Recycling of Waste Cardboard Cartons).

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Hazardous waste is controlled by the following procedures which reflect Licence requirements:

ProcE03.Gen (Hazardous Waste Disposal),

ProcEO5.FM (Disposal of Fluorescent Tubes & Light Bulbs),

ProcE 1 1 .Gen (Obsolete Equip Disposal),

ProcEOl .FM (Sludge Disposal from Interceptor),

ProcEOl .GM (Disposal of Contaminated Materials),

ProcE02.GM (Disposal of Waste Oil),

ProcE04.GM (Disposal of Waste Batteries),

ProcEO5.GM (Disposal of Ground Support Equip),

ProcEOl .LM (Handling of Surplus Aviation Fuel) and

ProcEO5.COH (Safe Disposal of Oxygen Generators).

Incoming materials/chemicals (including delivery to the Hangars1 Shops) are controlled by the following procedures which reflect Licence requirements:

ProcEO1 .ST (Vehicle Fuel Delivery to Garage Fuel Tanks),

ProcE02.ST (Vehicle Oil Delivery to Stores),

ProcE03.ST (Vehicle Oil Delivery to Storage Tanks),

ProcE04.ST (Delivery, Storage & Issue of Paint),

ProcEO5.ST (Provision of Fuels to Vehicles),

ProcEOl .Mats (Materials Receiving),

ProcE04,Mats (Materials Receiving),

ProcEO5-Mats (Materials Dispatch),

ProcE06.Mats (Issuing Hazardous Mats from Logistics Centre)

ProcEO7.Mats (Mats Delivery from Logistics to Shops & Hangars).

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Storage of materials/chemicals on site is controlled by the following procedures which reflect Licence requirements:

ProcE03.Mats (Storage of Hazardous Material)

ProcE07.Mats (Mats Delivery from Logistics to Shops & Hangars).

Quality Management System

SR Technics's quality system is registered under BS EN 9001:2000, EASA 145 and FAR 145. The Safety and Quality policy is given in the Maintenance

Organisation Exposition (MOE).

The Quality Manual is reviewed periodically in order to maintain familiarity with the current requirements and provisions contained therein. All revisions to this manual are numbered in sequence and the IAA must approve each revision in the revision changes part one of this Maintenance Organisation Exposition (MOE). The Quality Assurance Manager is responsible for preparing and issuing the approved revisions to this manual.

The Quality Assurance Manager is responsible for monitoring by sarnpling/auditing that there is full compliance with the requirements of this Manual in accordance with the duties assigned therein. The auditing system is described in section 3 of this MOE. This Manual is issued electronically in accordance with the Distribution List and in such a manner that prevents any changes being made to it other than by the Quality Assurance Manager.

Safety Management System

SR Technics also operates a Safety Management System (SMS). This is tasked with identifLrng any adverse trends in relation to safety related events or potential events and with addressing identified deficiencies in the interests of safety. As

part of this SMS SR Technics has become a Registered Premises (No. PF/TD/EX/35) for the keeping of mixed explosives under Dublin Fire Brigade, licensed under the Radiological Protection Institute of Ireland (No. 0089-0022- 05) to work with radioactive substances, a member of the European Aviation Safety Agency (EASA) (Ref: IE.145.003) and is certified under the US Department of Transportation Federal Aviation Administration (No. MEDY393G).

Environmental Performance Review

The overall performance of the facility is determined based on the monitoring of results, preventive maintenance checks, waste figures and the progression of the EMP. An Environment and Safety Audit Checksheet is completed weekly in

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each area to identify areas of improvement. The environmental performance is further analysed by unannounced audits, visits, sampling and analyses from the Environmental Protection Agency (EPA) and also from Fingal County Council. The EMS is also supported by the IS09001-2000 Internal audit schedule.

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ENVIRONMENTAL POLICY

SR Technics Ireland Limited is a major aircraft maintenance organisation located at Dublin

Airport and is committed to conducting its operations in an environmentally responsible

manner. Meeting our responsibility to protect the environment enhances our ability to

provide competitive and profitable services.

SR Technics Ireland Limited commits to:-

+ Conducting operations in a manner that protects the environment, our employees and our

neighbours.

a + Compliance with all laws ons and licences applicable to our operations.

+ Applying pollution pre principles to cost effectively reduce the environmental

impacts of our operations.

+ Managing resources responsibly.

+ Maintaining a comprehensive Environmental Management System to implement this

policy and to ensure continual improvement.

+ Support environmental responsibility to all levels of our organisation by environmental

awareness, communication and training.

+ Establishing and regularly reviewing environmental objectives and targets.

+ Reporting on the environmental performance of our operations.

Declan B'Shea Chief Executive SR Technics Ireland Limited

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Attachment Ne C.lb. - Environmental Organisational Structure a SR Technics Ireland Limited Environment Organisational

Structure

CEO SR Technics Ireland Limited

? Environment Committee Facilities Maintenance Manager - Chairman Environment Officer - Vice-Chairman Safety Manager Base Maintenance Representative Painting Manager Line Maintenance Representative Facilities Services Manager Materials Representative Purchasing Representative Training Representative Finance Representative Quality Assurance Representative Engineering Representative

\ Ground Eouioment Re~resentative

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Environmental Management Programme - Schedule of Environmental Targets and Obiectives, 2005 - 2009

Ref I Objective Target I Timeframe I Responsibility 1 2005 Project Ref Emissions to Air 1.1

1.2

1.3

1.4

1.5

EnT00405.AOH

EnT00705.AOH

EnT00 105. AOH

EnT00205.AOH

EnTo0605.AOH

Emissions to Sewer

Aircraft Overhaul Environmental Representative

Aircraft Overhaul Manager

Aircraft Overhaul Environmental Representative Aircraft Overhaul Environmental Representative Aircraft Overhaul Environmental Representative

Elimination of High Solvent coating products

Minimisation of fugitive emissions

Reduction of VOC's during aircraft painting Reduction of VOCYs during aircraft stripping Review of Aircraft Cleaning Products

2.1

2.2

General 3.1

Substitution of high solvent products with high solid or water based alternatives for all coating products Identify and quantify all sources of fugitive emissions and reduce by 10% Achieve minimum emissions by process control and abatement equipment Establish product range suitable for the removal of all paint types. Elimination of DCM Identify all cleaning processes and establish trial programme for alternatives

2001 - 2005

2003 - 2007

200 1 - 2005

2001 - 2005

2003 - 2007

Improve chemical handling, storage, use and disposal on the site.

To ensure all underground pipelines and drains are maintained in good condition. Waste

Improve waste management and reduce volume of waste generated.

EnTO 1005 .FM

EnTOO 105.Trng

Environment Officer

Facilities Maintenance Manager

Environment Officer

Hazardous Waste

EnTO 1205 .FM

EnT00505.FM

EnT00905.FM

Create a chemical register. Improve chemical control and delivery procedures Canyout drain inspection. Identify and repair defective drains.

Reduce volume of general waste by 10%.

4.1

Training 5.1

2005

2005

2001 - 2005

Improve waste management and reduce volume of waste generated.

Incorporate environmental awareness training into company training programmes

Reduce volume of hazardous waste by 10%. 200 1 -2005 Environment Officer

Technical Training Manager Ensure all personnel are regularly updated on environmental policy.

200 1 -2005

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Schedule of Environmental Targets and Obiectives, 2005 - 2009 Continued

Ref I Objective Target I Timeframe I Responsibility 1 2005 Project Ref Water Management

Facilities Maintenance Manager 2001 - 2005 EnT00305.FM Reduction of water usage by 10%. 6.1 Minimisation of water usage through monitoring, control and awareness

Energy Management 7.1 EnTOO 105 .FM Reduction of energy consumption by 12.5% Minimisation of energy use through

monitoring, control and awareness

EnTO 1005.COH

EnTOO 105.Gen

EnTOl105.FM

200 1 - 2005

Process Improvement

Facilities Maintenance Manager

2005 Landing Gear Service Centre Manager

To install a closed loop system into the rinsing process.

8.1

Safety Manager

Facilities Maintenance Manager

Eliminate emissions to sewer from Electroplating operation.

Noise 9.1

Management Minimisation of noise produced through a Noise Reduction Programme

Minimise noise emissions 2003 - 2007

Groundwater 2003 - 2005 Repair, test and verify integrity of all bund

structures 10.1 Reduce impact on groundwater from

defective bunds

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MAJNTENANCE SR Tecrhnfrs 6, Section: 11

ORGANOSAT1ON E KPOSITIBN

Page: 1 of 6

Ireland Effective Date Jan 2005

This document describes the e:jsential ft?atures of the Safety Management System of SR Technics Ireland Limited and is issued under the a~~thority of the Accountable Manager & CEO.

The Safety Management Systel-n (SMS) is tasked with identibing any adverse trends in relation to safety related events or potential events ;and with addressing identified deficiencies in the interests of safety. The system will also promulgate relevant information in relation to events and related corrective actions. The priority of the SUS is to address matters affecting, or with the potential to affect, airworthiness safety. However, overlaps with others aspects of safety that impact the wider aircraft maintenance activity and assoziated personnel safety are inevitable and will also be encompassed as appropriate by the systom.

The VP Engineering & Quality has been tasked with management of the Safety Management System. Regular reviews of the systern and recommended actions are conducted with the Accountable Manager.

This SMS has been develop~?d in order to meet the requirements of Irish Aviation Authority Aeronautical Notice NR A.67 and Part 14 5 and will be developed and added to based on experience and best industry practice.

I 1.2 SAFETY AND QUALITY P OLICY

The Cornpany Safety and Quality Policy Statement and Corporate Commitment of the Accountable Manager are contained in Sections 1-1 ar~d 1-2 of this Exposition.

Use or disclosure on this page is sut~ject to the restrictions on the title page of this document.

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SR 7er:hnlcs @J MAINTENANCE Section: 11 ORGANISATION

E:I(POSITION Page: 2 of 6

Ireland Effective Date Jan 2005

11.3 A,GHIEVING A POSITIVE SAFETY CULTURE

An orgarisation with a positive safeti culture is one which has managed to successfully institutionalise safety as a funda.nental value of the organisation, with personnel are every level of the organisation sharing a common ~:ommitmc?nt to safety. The conduct of an organisation's management and staff towards safety, safe..y practices and safety oversight will determine how business is conducted from a safety standpoint.

The ideal culture is one that supportive of staff and systems of work, recognises that errors will be made and that is not apportionrnent of blame that will resolve problems. Therefore, the supportive culture will encourage open reporting, seek to learn from its failures and be just in dealing with those involved. Punitive action must not follovl automatically from the open acknowledgement of human error. Hc~wever, it must be made clear that indemnity will not be guaranteed where there has been gross negligence. The front line defence is that staff must not accept unsafe behaviour from their colleagues.

It is only I,y the efforts of management and staff working together that a positive safety culture can be achieved and retained.

Use or disclosure on this page is sutlject to the restrictions on the title page of this document.

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SR Te1chnics f&j MAINTENANCE Section: 11 ORGANISATION

EXPOSITION Page: 3 of 6

Ireland Effective Date Jan 2005 -

11.4 MANAGEMENT OF: THE SAFETY MANAGEMENT SYSTEM

The VP Eingineering & Quality has day to day responsibility for the Safety Management System and reports to the Accountable Manager & CEO (IRL) in this regard. His responsibilities with respect to this system are:

To collect data on internal safety related events and potential events (Note: existing data sources such as Ouality Assurance inve:jtigations, reports or audits will be utilised where possible and will not be duplicated) To assess feedback from the Company confidential reporting system To identify adverse trends or deficiencies with the potential to impact on safety To make recommendations to the Accountable Manager and Senior Management with respect to remedial action required To monitor the implementation c ~ f corrective actions taken to address identified deficiencies To monitor and implement best industry p,ractice with respect to Safety Management Systems

11.5 SAFETY ACCOUN'TABILiT'Y

Every staff member is accounl.able for hislher own actions within the scope of their training and knowledge as it affects the quality and safety of the products and services of the company. More detailed accountabilities of depi3rtmental managers and other staff are contained within the relevant company manuals.

In exercising individual accourtability, staff are required to work in accordance with the relevant company manuals and procedures, aircraft and equipment manufacturers manuals and other approved data sources.

In addition, all staff have the re!;ponsibility to highlight any safety or airworthiness events or concerns that come to their attention via departmental management, the Quality Assurance Department or via the company Confidential Reporting Process as appropriate.

I 1.6 FIECORDING AND MONIT(3RING OF COMPANY SAFETY DATA

The Quality Assurance Department coll~!cts data with respect to safety events and documents this information within a monthly Quality Report. The data includes a listing of all occurrences reported to or identified by Quality Assurance and a categorisation of each event in terms of severity from an airworthiness safety perspectiv~?. A hist3rical comparison (trend analysis) with the previous year is also included. This report is rehiewed at each monthly Airworthiness and Quality Assurance Meeting.

The Monthly QA Report is one of the primary sources of data reviewed by the Safety Management System and, when taken in conjunction with the resulting QA investigation reports and recommendations, represents the major portion of the information evaluated by the system.

Use or disclosure on this pijge is subject to the restrictions on the title page of this document.

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SR lchnim @J MAINTENANCE Section: a 4

a OR GANlSATlON EXPOSlTlON

Page: 4 of 6

Ireland Effective Date Jan 2005

I 1.7 CONFIDENTIAL Rlf PORTING

As an alternative to open reporting to departmental management or Quality Assurance of safety concerns or incidents, staff ma!/ make reports on a confidential basis if desired. These reports may be made using the Quality Discrepancy Report I Incident Report Form (TD2000). These forms are readily available outside the C,A Office. Completed forms may be sent to the Quality Assurance Manager (MDl32) or the Technical Director I SMS Manager (MD240).

As an aliernative to completing the TD2000 form, staff may use the confidential reporting phone line (extension 6321 or from an outside line 8126321 or if using an Aer Lingus extension dial 66321) by leaving a voice mail. Messages on this line are accessible only by the SMS Manager or the Quality Assuranc.e Manager and will no!: be divulged.

When reporting using either of the above methods, staff are encouraged to avoid anonymous reporting (e.g. where no contact details are provided) as this presents significant difficulties should follow-up information be required to investigate concerns or incidents.

Where a staff member makes a confidctntial report in relation to an error or lapse that they were involved in, confidentiality of reporting is assured provided the event or occurrence concerned relates to an unpremeditated or inadvertent lapss by the employee concerned. In addition, no disciplinary or punitive action will be taken by the corrpany where a constructive attitude is demonstrated by the employet? in reporting such an event.

I 1.8 SAFETY MANAGEMENT SYSTEM REVIEWS

The functioning of the Safety Manage~nent System, including consideration of significant Gsues identified and their resolution status, will be reviewed quarterly with the Accountable Manager. Attendees at this meeting will irlclude rel~?vant Form 4 Managers and the Quality Assurance Manager in addition to the Accountable Manager and the SMS Manager. These meetings are minuted.

11.9 INTERNAL SAFETY EVEhlT INVESTIGATIONS

The primary responsibility for internal airworthiness safety event investigations rests with the Quality Assuranc;e Department which carries out these investigations with the assistance of the management of the relevant departments. The coiduct of these investigations is described in the Quality Assurance Manual and use MEDA prirciples to the extent required by significance of the event concerned.

The SM!; Manager may in certain circumstances elect to conduct additional enquiries in order to validate or supplement the conc:lusions fr3m the QA investigation.

Use or disclosure on this page is subject to the restrictions on the title page of this document.

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SR Tehhncs MEiI NTENANCE Section: 4 1

• l s V ~ Page: 5 of 6 OR GANISATION

EXPOSITION Ireland Effective Date Jan 2005

1 1 .I 0 FZEPORTING AND DlSSERnlNATlON

An essential element of a Sti'ety Management System is the dissemination of required actions, lessons Isarned or procedural c:hanges zrising from evaluations conducted as part of the SMS. The processes used to communicat~! information to affected staff includes but are not limited to:

Staff briefings Human Factors and initial and recurrent t'aining Airworthiness and Quality Meeti igs Technical or Quality Notices Continuation Training Company Procedures Technics TV Notice Boards

I I .I I INTERACTION WITH EXISTING PROCEDURES

The Saf~,ty Management System does not replace or duplicate any existing systems or processes associated with occurrence reporting or investigation. The existing processes continue to be the primary methodology for deal in!^ with maintenance events or errors as required by the organisational approval:; granted by various regulatory zuthorities.

1 1 . I2 HUMAN FACTOR8 AFFEClTING MAINTENANCE

In implementing this Safety Management System, and during the conduct of investigations into safety related events, cognisance will be taken (by use of MEDA and similar investigation tools) of the potential for human errors taking place. In most events, a series of contributory factors (human factors and other factors) together influence the outcome that leads to an error or safety event.

The majority of maintenance errors occ:ur due to an unpremeditated or inadvertent lapse by the employee! concerned. By thorough investigation using best human factors practice, the full range of factors contributing to an event will be isolated for consideration by the Safety Management System when identifying adverse trends requiring remedial action by the company.

Notwithslanding the fact that the majorit!/ of errors are inadvertent, it may be appropriate during the investigation of serious events to susperid company approvals of personnel involved with the event pending the completion of the investigatisn. This procedure is documented in the Quality Assurance procedures manual. When this action is taken it has the objective of protecting the organisation and the individual and is not to be in:erpreted as disciplinary action.

-

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MAINTENANCE SR Rrrhnics 83 Section: 11

OR'GANISATION Page: 6 of 6 E.KPOSITION

Ireland Effective Date Jan 2005

I I . I3 NEGLIGENT OR Dlf LIBERATE BEHAVIOUR

Negligent behaviour or actions designed to cause deliberate harm or damage are thankfully rare in the aviation sector. Since the majority of maintenance errors or events are inadvertent and staff, typically, participate fully in the investigation process in the interest of airworthiness safety, disciplinary actions are not appropriate or warranted.

However, there are certain occ;~sions where implementation of company disciplinary procedures are required on an exceptional basi:.. Examp es of where this may be appropriate are as follows:

1. The persons actions we-e intended to cause harm or damage 2. The person concerned does not have a constructive attitude towards complying with safe

operating procedures 3. The person concerned knowingly violated procedures that were readily available, workable,

ir~telligible and correct 4. The person concerned has been ~nvolved previously in similar events or lapses 5. The person concerned has attempted to hide their lapse or part in a mishap 6. The persons actions show a substantial disregard for safety

In 6. above "substantial disregard" is defined as follows:

In the case of certifying staff, the act or .'ailure to act was a substantial deviation from the degree of care, judgement and responsibility reasor~ably expected of such a person In the case of a person holding no maintenance certification responsibility, the act or failure to act was a substa~?tial deviation from the degree of care and diligence expected of a reasonable person in those circ:umstances

The degree of culpability would vary depending on any mitigating circumstances that are identified as a result c f an investigation conc ucted using MEDA principles. Consequently, any action taken by the organisation would also be on i 3 sliding scale varying, from corrective measures such as re-training, through to dismissal of the individual in extreme cases.

I I . I4 ZiAFETY MANAGEMENT SYSTEM DEVELOPMENT

The Conlpany Safety Management System will develop and evolve with time to take account of lessons learned, staff suggestic~ns and r~?gulatory changes. It is not intended to be a static process but instead one that takes accol~nt of industry trends and best practice with the objective of supporting management and staff to improve the safety standards applied to the services being provided.

Use or disclosure on this paage is suk~ject to the restrictions on the title page of this document.

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C E R T I F I C A T E OF R E G I S T R A T I O N

Q u a l i t y M a n a g e m e n t S y s t e m

SR Technics Ireland Limited Qualiity Assurance

Operate a Quality Management System

which complies wi th the requirements o f

for the activities detailed in the scope of

registration.

,,Originally registered: 3 Nov 1988

QUALIN MANAGEMENT

Certificate No: FM 00417

MGMT. SYS. R v A C 030

003

This is not a legal document a r d cannot be used as such. This certificate does not expire. To check its validity telephone +44 (0)20 8996 9001 or visit uvww.bsi-gl~~baI.comlClientDirectory Further clarifications regarding the scope o f this certificate and the applicability o f IS0 9001:2000 requirements may be obtained by consulting the organization. The British Standxds lnstitut'on is incorporated by Royal Charter. Group Headquarters: 389 Chiswick High Road, Loncon W4 4AL, UK.

Management Systems

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C E R T I F I C A T E OF R E G I S T R A T I O N ,.. ,., , , , . . . . . . . - . .

Q u a l i t y ' M a n a g e m e n t S y s t e m

This is t o certify that:

SR Technics ireland Limited Quality Assurar~ce MD A32 Dublin Airport Dublin Ireland

a Hold Certificate No., FM 00417

and operate a Quality Management System which complies wi th the requirements o f BS EN IS0 9001 :2000 for the follovying $ope:

The overhaul, inspection, m~dific~ation an13 management of heavy civil transport aircraft and associated co~nponents. This includes thc? necessary services in support of these activities, e.g facilities mairitenance, grouncl equiprrlent maintenance, planning and engineering service~;fi~ance, sales and marketing, training and human resources.

For and on behalf c ~ f 1351:

P

Certification Manager, Systems Assessment

Originally registered: 3 Nov 1988 Latest issue: 8 Apr 2005

MGMT. SYS. RvA C 030

Page: 1 of 1

This certificate remains the property o f BSI and :hall be returned immediately upon request. This certificate does n o ! expire. To check its validity telept one: 944 (0)20 8996 9007 or visit 92 www.bsi-global. comlCIi entDirectory. Further c1;trifications regarding the scope of this certificate - - and the applicability of I S 0 9007:2000 requirem~?nts may be obtained by consulting the organization. - - - The British Standards Iratitution is incorporated by Royal C'harter. ._ - Group Headquarters: 309 Chiswick High Road, L o n d ~ n W4 4AL, UK.

Management Systems

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