Acceptable Means of Compliance & Guidance Material to UK Regulation (EU) No 1321/2014 SMS in Part-145 and Occurrence Reporting

Overview

The CAA is proposing to amend UK Regulation (EU) No. 1321/2014 as regards safety management systems (SMS) in maintenance organisations and correcting that regulation. 

This document presents the proposed changes to the Acceptable Means of Compliance (AMC) and Guidance Material (GM) material associated with the rule changes described above together with background and explanatory information regarding this consultation. 

These amendments are required as a consequence of amendments to UK Regulation (EU) No. 1321/2014 which will be revised to:

• introduce safety management principles that implement International Civil Aviation Organisation (ICAO) Annex 19; a management system for Part-145 maintenance organisations and a management system for the CAA in relation to the oversight of Part 145 maintenance organisations.
• harmonise general organisation provisions and CAA procedures with those of Part-CAMO (Annex Vc to UK Regulation (EU) No 1321/2014);
• foster an organisational culture for effective safety management and effective occurrence reporting in accordance with UK Regulation (EU) No 376/2014.

The CAA expects by doing such an amendment, safety will be enhanced through:

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

Our independent conclusion is that the legal changes to UK Regulation (EU) No. 1321/2014 should closely follow what has been published by EASA and will be published, together with the accompanying AMC and GM, in the first quarter of 2023.

AMC and GM

AMC are means by which the requirements in the Implementing Rule and the Essential Requirements of the Basic Regulation to which it relates can be met. However, entities may show compliance by other means. 

An entity may choose to offer an alternative means of compliance (AltMoC) which must be reviewed and accepted by the CAA. However, it is important to note they will lose the presumption of compliance provided by the CAA AMC so it is essential for the operator to demonstrate that the AltMoC meets the intent of the Implementing Rule and the Essential Requirements of the Basic Regulation. 

GM is non-binding and provides explanatory and interpretation material on how to achieve the requirements in the law and the AMC. It contains information, including examples, to assist the applicant with the interpretation of the legislative provisions.

This consultation

To support the transposition of the ICAO Annex 19 Standards and Recommended Practices (SARPs) in the maintenance domain, and facilitate the implementation of the SMS requirements introduced by UK Regulation (EU) No 1321/2014, the UK CAA is proposing to amend the AMC and GM to Part-145 (Annex II) in respect of the following topics:

• Introduction of the SMS for Part-145 maintenance organisations; 
• Introduction of the SMS for the CAA in relation to the oversight of Part 145 maintenance organisations;
• Revise Part-M, Part-CAO, and Part-66, such that these remain consistent with the amended Part 145 regulatory material.
• Occurrence reporting
• Revise Part-CAMO to address an implementation issue in relation to the qualification of the safety manager.

This AMC and GM consultation document relates only to Part-145, Part-M, Part 66, Part-CAMO and Part-CAO of UK Regulation (EU) No 1321/2014.

• AMC/GM Part 145
• AMC/GM Part 66 
• AMC/GM Part CAO 
• AMC/GM Part M 
• AMV/GM Part CAMO

Why your views matter

It is important to the CAA that everyone has an opportunity to voice their opinion on matters that could affect them. There is also a legal requirement to consult when creating or amending AMC and GM, due to the legal status of these documents.

We welcome comments from every sector of the community. This includes the general public, government agencies and all sectors of the aviation industry, whether as an aviator, aviation consumer and/or provider of related products and services.

How to respond

This consultation will close on 14 April 2023. We cannot take into account comments received after this date. We will assume that all responses can be published once the consultation has closed. There is an option to request for your name to remain private, but in any event your email address will never be published.

Please submit your comments using the online survey link below. 

What happens next

At the end of the response period, we will review and publish each comment and submission received.

Your feedback will be considered as we refine the AMC and GM and guide the development of the regulatory changes.