GM1 ORGH.MGM.200(a) General requirements for the management system

SCALABILITY AND SUITABILITY OF AN OPERATIONAL AND EFFECTIVE MANAGEMENT SYSTEM

(a) All organisations, regardless of their size, are exposed to risks, some of which are potentially significant. This means that:

(1) all elements of a management system should apply;

(2) the effectiveness of the management system will depend on how appropriately its elements are designed, implemented and operated.

(b) However, an operating management system does not need to be complicated and expensive to be effective. It could be made scalable if it keeps on delivering as expected and provides an effective way to manage all key operational risks.

(c) Scaling a management system (including the SMS) does not mean choosing to apply only some elements of the system and not others. Scalability is about adapting the system to the specific operational context of the organisation.

(d) The following aspects are vital for any organisation to understand the context in which its management system operates, the purpose of the management system and the key risks that it must manage effectively (the list is not exhaustive):

(1) regarding the size of the organisation:

(i) number of employees, number of stations where GH services are provided, facilities, pieces of GSE utilised, internal and external interfaces and organisational structure;

(ii) type and variety of services provided;

(iii) number of aircraft operator customers and volume of serviced flights or passengers (as relevant);

(2) regarding the complexity of the GH activities performed and, consequently, of the risks to be managed:

(i) the GH organisation’s hazards log, the safety risk assessment reflected in the safety risk severity and tolerability levels, safety performance indicators, the complexity of mitigation measures and controls put in place to minimise the risks of a particular GH activity;

(ii) the number of personnel compared to the number and complexity of tasks to complete for a particular GH activity or for all GH services provided by a GH organisation;

(iii) the training programme to be completed by the personnel assigned to a particular GH activity;

(iv) the interfaces of a particular GH activity with other GH operations or other actors contributing to its execution;

(v) the communication layers among the individuals and entities involved in the execution of that activity, and the hierarchical levels involved in the communication chain;

(vi) the use of any GSE for the execution of a particular GH activity;

(vii) risks associated with the operating environment (e.g. congested aerodrome, mountainous, climate, geographical location, stations near conflicts zones), safety consequences of low safety performance of services provided, potential downtime, etc.;

(viii) risks associated with the business model (e.g. takeovers, mergers, extent of contracted services, services based on a short turnaround or operations under commercial pressure; GH organisation as part of a single GH organisation business grouping, a stand‑alone organisation, or part of an aircraft operator or aerodrome operator);

(ix) AltMoC granted by the competent authority;

(3) regarding other external and internal factors:

(i) societal and public expectations;

(ii) economic and commercial environment, competition, balance between the need to ensure stability of the business and the need for change;

(iii) experience in the business, adequacy and robustness of existing procedures;

(iv) safety culture, open reporting culture, prevention culture and just culture;

(v) state’s overall performance.

(e) This multidimensional complexity needs proper weighing. The topics below may be used for this evaluation. More details are provided in the Annexes to EASA’s Management System Assessment Tool.

(1) The safety policy may be a brief high‑level statement of the commitment of management, supported by safety objectives that address significant risks; it would be more detailed in a challenging environment. The regular updating of the safety objectives is necessary where the business/operations are continually evolving (due to changing operational activities, numerous deficiencies, crises, etc.).

(2) It is recommended that the communication of these safety objectives be commensurate with the resources of the organisation.

(3) The reporting policy, just culture policy and safety objectives could be combined with the safety policy for small organisations.

(4) The significance of the areas of greater risk (severity, likelihood), the robustness of the mitigation measures greatly affect the efficiency of the safety barriers;

(5) For organisations with a lower level of risk, the safety risk assessment model that they use may be very simple if the hazards identified are easy to mitigate. In addition, the organisation will strive to classify risks in a consistent manner; expert judgement may be sufficient to measure the efficiency of the safety barriers, especially when the volume of data or safety information does not support the precise evaluation of the likelihood and the severity of the consequences of the hazards.

(6) Focus on risks at interfaces will significantly depend on the criticality of the contracted services and the magnitude of the supply chain. The communication of changes and communication at the interfaces will certainly be more demanding in a large organisation or in an organisation contracting many activities.

(7) The management system documentation, hazard log and records (of safety risk assessments, decisions, actions, ownership and monitoring) should be clear and concise but sufficiently detailed to ensure the adequate management of risks. They should be consistent and complete. However, in a small GH organisation, they should not generate ‘red tape’.

(8) Human performance and human resources can be critical for organisations of all sizes, although the related issues may depend on organisations’ context and size: small organisations will be more affected by retirement, transfer of knowledge, sickness and a stressful environment, whereas large organisations experiencing major changes or significant growth will face major challenges.

(9) The degree of urgency of reaching a certain level of safety based on deficiencies, feedback from the compliance monitoring system, cultural factors or changes to rapidly manage any immediate/pressing safety issue, may affect the resources required for the timely achievement of the safety objectives.

(f) The implementation of industry standards and good practices directly relevant to a GH organisation’s activities will also be considered in the design and functioning of its management system.

(g) It is the responsibility of the GH organisation to determine the suitability and scalability of its management system and to demonstrate to its competent authority that its management system is appropriately designed and suitable to effectively deliver results as expected. An operating management system or SMS does not necessarily need to be complicated, time‑consuming and expensive to be effective and demonstrate that the significant risks are under control and that the organisation is safety‑data‑rich and therefore able to take the right managerial decisions.

(h) The following levels of maturity of a GH organisation’s management system and experience in the implementation of an SMS are expected to be achieved and demonstrated gradually in several steps, from ‘present’ to ‘effective’.

(1) Present. This means that the GH organisation is able to provide evidence that the components of its management system are defined and documented within its management system documentation.

(2) Suitable. This means that the components of its management system are appropriate and meaningful for its GH activities, its size and the complexity of the services it provides based on the inherent risk of its activities.

(3) Operating. This means that the GH organisation is able to provide evidence that the components of its management system are in use and that an output is being produced.

(4) Effective. This means that the components of its management system achieve the desired outcome, have a positive effect on safety and strive to ensure continued improvement; the desired effect is achieved when the safety objectives are achieved.

Management systems’ levels of maturity may change over time, as they depend on the challenges and changes that a GH organisation faces. As the management system of a GH organisation matures to ‘operating’ and ‘effective’, the criteria measuring the management system’s ‘suitability’ level may need to be revised.

(i) Details on the implementation of management systems and their suitability and scalability can be found in EASA’s Management System Assessment Tool, Annexes 1 and 2.