When it comes to Safety Management, it is unclear to many people how it is applied at European Level, National Level and within an organisation. If you have ever wondered how to tell your SSP from your EPAS and what these have to do with operational safety management within an organisation, here are the answers!
While the terms “Safety Management” and “Safety Management System” are understood by most people in aviation, there is a lack of understanding about the relationship between the “SMS” of an organisation, the Safety Plan for Aviation Safety (SPAS)/ State Safety Programme (SSP) at National Level and the European Plan for Aviation Safety (EPAS) at European Level and State Level.
Each aviation organisation is responsible for the safety of its own operations.
SMS is the way safety is managed in aviation organisations. It must be focused on managing safety risks in the actual operational activities that individual organisations undertake. Managing aviation safety risk within an SMS is something that organisations do as an integral part of their day-to-day operations. It extends much further than a document that lives on the shelf. To be effective, it must be a living process focussed on protecting lives, not a ‘tick-box’ exercise made up of processes and risk matrices. Effective coordination and collaboration between all parties in the aviation system means we can prioritise the way we deploy resources to manage risks effectively. An organisation is guided by European and State Safety Plans, but needs to tailor them to apply to the specific organisation.
In other words, the SSP at National Level is not just a copy of the EPAS - and SMS at organisation level is not just a copy of the SSP. Details of each instrument are given below:
The European Plan for Aviation Safety (EPAS) – Safety Management at European Level
The purpose of the EPAS is to ensure that the principles of safety management are applied within the European Aviation Community so as to continually improve safety performance. It is driven by Regulation (EU) 2018/1139, known as the European Union Aviation Safety Agency (EASA) Basic Regulation, to ensure the application of ICAO safety management principles that are fundamental to the continuous improvement of civil aviation safety. The EPAS seeks to anticipate emerging industry safety risks and make best use of technical resources through a common framework for prioritising, planning and implementing safety improvement actions.
EASA develops the EPAS in close collaboration with the Member States and other relevant stakeholders. The EPAS is produced annually and looks ahead to the following four years. It examines relevant safety information sources (notably occurrences), prioritisation of issues and evaluates options to address them. It identifies the main areas of concern affecting the European aviation safety system. It then sets out the strategic actions necessary to mitigate those concerns and return safety risk back to an acceptable level.
The EPAS is supported by the EASA Annual Safety Review (ASR) that includes dedicated safety risk portfolios which focus on the various operational domains in Europe. It also monitors the implementation of the related mitigation actions including, where appropriate, related Safety Performance Indicators (SPIs).
The ultimate objective of the EPAS is to ensure that, together, the European Commission, EASA and the Member States continuously improve aviation safety in a growing industry.
The EPAS is the outcome of an active process that manages aviation safety risk at European Level. That said, it cannot possibly cover every conceivable variable in every part of the aviation system in every corner of Europe and in every aviation domain. The EPAS is, in effect, a Safety Management System in the context of the EASA Member States: it relies on Member States and their industries to manage safety effectively themselves.
Safety management at National Level – The State Safety Programme (SSP) and the State Plan for Aviation Safety (SPAS)
The SSP is an integrated set of activities aimed at improving safety at National Level. It takes the EPAS into account but looks also at the specific safety challenges of the Member State. It is nevertheless important that the SSP incorporates the actions identified in the EPAS in addition to using data and safety information at National Level, so as to identify the main threats to safety risk control affecting a Member State’s civil aviation safety system.
The SSP is generated through an active process that manages the main risks at National Level. The necessary actions to mitigate those risks are then outlined in the annual SPAS, which is also called the National Aviation Safety Plan (NASP) in ICAO terminology.
At this level however, it cannot possibly cover every conceivable variable in every single aviation organisation in their borders.
Whilst the risks identified at European Level in the EPAS should inform the development of the SPAS, it is not simply a copy and paste. Depending on the context of the Member State’s aviation activities, there are some issues in the EPAS that may be irrelevant. For example, risks associated with the operation of Offshore Helicopters feature in several EPAS actions, but this is unlikely to be of significance to a landlocked Member State. Another example is countries that experience severe winter weather conditions, where attention is needed for the specific risks associated with these operations. When a Member State considers that an EPAS risk and related action(s) are not relevant for its national aviation safety system, it must substantiate this.
Member States must identify and assess specific issues that might not have been identified at European Level, including the issues faced by its approved organisations.
Safety management at organisational level – Safety Management Systems (SMS)
Each aviation organisation is responsible for the safety of its operations. SMS is the way organisations manage safety and is designed specifically for the needs of that organisation. It will include relevant EPAS or SSP/SPAS topics, but it should also cover risks specific to the organisation and its activities. SMS is not a one size fits all undertaking; it should not be a copy-paste from any another organisation as no two organisations have the same risk profile.
The SMS must address the day-to-day activities of the organisation as a continuous process and focus on protecting lives.
Compliance regulations already contain many risk assessed controls: SMS must go beyond compliance to provide the foundations for safety. Answering the question “How well does our organisation comply with the rules?” is only the starting point of SMS. A better question would be “How well does our compliant organisation control its risks?”
It is for this reason that, as far as possible, the EASA regulatory framework includes compliance (‘ensurance’), compliance monitoring (‘assurance’) and safety risk management (focus on safety control measures) in its integrated management system approach.