Human Factors Implications

The three-part document, which addresses all aspects of Maintenance SMS for operators and regulatory authorities, is nearly 500 pages. EASA considers not only safety but also costs.

Section 145.A.30(b) Personnel Requirement

EASA calls for the explicit identification of someone with the title and responsibility for “Compliance Monitoring” and/or “Safety Manager.” Depending on the size of the organization this can be one person but they must report directly to the accountable manager, who can also serve this responsibility. The responsibilities for this role are described in the AMC.

Section 145.A.30(e) Qualification of HF Training Personnel

There is little change in the familiar HF requirements for maintenance personnel.

“… all maintenance organization personnel should have received an initial and continuation human factors training …” Page 55, Part C.

It includes requirements for initial and continuation HF training. This section also describes who and what shall be included in the training. They recognize that training must be altered to the size of the organization and the type of work completed. That language helps ensure that there is not excessive burden to small organizations.

EASA pays attention to the qualifications of a human factors trainer. It bears repeating:

A competent human factors trainer should meet the following criteria:

1. attended training that is equivalent to the EASA Part 145 HF syllabus … GM1 145.A.30(e)

2. received instruction in training techniques…

3. has worked a minimum of three years within aviation industry, or possesses a suitable academic background

4. has an appropriate level of human factors (knowledge) … in relation to the organization’s HF program.

The organization must develop and document how each HF trainer is deemed to be qualified, capable, and fully competent as not only a HF expert but also as a trainer. An evaluation matrix is offered on pages 62-65, Part C.

Section 145.A.47 Production Planning — Fatigue Risk Management

This is a new section that addresses the fatigue related risk in maintenance organization. It is extremely detailed containing about five pages of excellent information. It will be covered in an upcoming AMT article. The document contains all the requirements for documenting a fatigue risk management scheme to include details like: maximum scheduled hours/day and/month, maximum hours with overtime, minimum rest between shifts (based on shift length), and minimum uninterrupted rest hours per week. All of the above must also consider the time of day of the work shift. That section also says: “Reasonable work hour limits should not be exceeded merely for management convenience even when staff is willing to work extended hours …” Page 78, Part C.

The Fatigue Risk Management must adhere to EU (European Union) Working Time Directive 2003/88/EC, which is contained in the AMC. This is one case where you must consider the exceptions as well as the possible changes.

While the EU Directive, at a glance, seems very prescriptive there are a number of cases in which it can be over-ridden when the employer and the employee agree to longer than prescribed hours and shorter than prescribed rest. In such cases a fatigue risk assessment is needed to determine what is safe and reasonable. EASA mentions that the EU Directive is subject to change for aviation workers. Such a change, which could take a long time, could impact U.S. EASA certificate holders.

The AMC also refers FRMS topics to the UK Civil Aviation Publication CAP716 Appendix P.

Section 145.A.62 Reporting Systems

The NPA calls for a beefed up “internal occurrence reporting system.” The system is like the FAA’s Aviation Safety Action Program (ASAP), meaning there will be no changes needed for current U.S. ASAP users. It is likely to encourage additional U.S. companies to adopt the many positive aspects of ASAP. EASA also prescribes training for all who are involved as investigators and participants. Referring to such programs EASA says: “This is important as a strong safety culture is an essential ingredient for effective safety management.” (Page 11, Part C).

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