ED Decision 2020/002/R
SAFETY RISK MANAGEMENT — INTERFACES BETWEEN ORGANISATIONS
(a) Safety risk management processes should specifically address the planned implementation of, or participation of the organisation in, any complex operational and maintenance arrangements (such as when multiple organisations are contracted, or when multiple levels of contracting/subcontracting are included).
(b) Hazard identification and risk assessment start with an identification of all the parties involved in the arrangement, including independent experts and non-approved organisations. This identification process extends to cover the overall control structure, and assesses in particular the following elements across all subcontract levels and all parties within such arrangements:
(1) coordination and interfaces between the different parties;
(2) applicable procedures;
(3) communication between all the parties involved, including reporting and feedback channels;
(4) task allocation, responsibilities and authorities; and
(5) the qualifications and competency of key personnel with reference to point CAMO.A.305.
(c) Safety risk management should focus on the following aspects:
(1) clear assignment of accountability and allocation of responsibilities;
(2) that only one party is responsible for a specific aspect of the arrangement, with no overlapping or conflicting responsibilities, in order to eliminate coordination errors;
(3) the existence of clear reporting lines, both for occurrence reporting and progress reporting;
(4) the possibility for staff to directly notify the organisation of any hazard that suggests an obviously unacceptable safety risk as a result of the potential consequences of this hazard.
(d) The safety risk management processes should ensure that there is regular communication between all the parties involved to discuss work progress, risk mitigation actions, and changes to the arrangement, as well as any other significant issues.
Guidance on safety risk management for interfaces between organisations in complex maintenance arrangements, covering hazard identification, responsibility allocation, reporting lines, and regular communication.
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