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Opinion No 04/2020

Embodiment of the SMS requirements into Annex II (Part-145) to Regulation (EU) No 1321/2014 and into Annex I (Part 21) to Regulation (EU) No 748/2012

The objective of this Opinion, with reference to ICAO Annex 19 ‘Safety Management’ as regards civil aviation and in particular the initial and continuing airworthiness domains, is to establish a safety management system (SMS) framework for design and production (Part 21) as well as maintenance organisations (Part-145), which are the remaining two domains for which ICAO Annex 19 has not been fully transposed yet into the European Union regulatory framework. In addition, Annex II ‘Essential requirements for airworthiness’ to Regulation (EU) 2018/1139 explicitly calls for design, production and maintenance organisations to implement and maintain a management system (MS), including the management of safety risks, and aim for its continuous improvement, supported by the establishment of an occurrence-reporting system.

By establishing such an MS framework, aviation safety will be enhanced through:

  • the establishment of safety policies and objectives associated with sufficient resources;
  • the systematic identification of hazards and a risk management system;
  • safety assurance systems, giving consideration to the safety performance of organisations; and
  • safety promotion and communication.

The proposal of this Opinion is in line with the regulatory concept of MS established for other domains, such as Air Operations or Aerodromes, or for continuing airworthiness management organisations (Part-CAMO).

By aligning the MS provisions across all aviation domains, it will be ensured that the organisations which have to comply with several MS requirements in different domains can implement a single MS, and that competent authorities that oversee different organisations in different domains can plan and organise their oversight activities on the basis of the same regulatory principles.

It may happen that some differences in the numbering or the contents or even in the terminology used may still exist but, all in all, the same principles are intended to apply in all domains consistently. The main rationales behind these differences are that the Part 21 requirements for design and production are more product-centric whereas the requirements in other domains, such as Part-145, are more organisation-centric, and that the amount of regulatory amendments has been kept as low as possible.