A Military Regulator s Perspective The UK MAA s CAMO Example

Transcription

1 A Military Regulator s Perspective The UK MAA s CAMO Example RAeS Outsourcing of Aircraft Support Workshop Bob Simmons 30 October 2014

2 Session agenda The regulatory backdrop The implementation of Continuing Airworthiness Management Organisation (CAMO) approvals The MAA role Current challenges 2

3 The regulatory back-drop (MAA01) The Director General of the UK Military Aviation Authority sees himself as an enabler for Defence aviation, assuring that there is a state of freedom from unacceptable risk of; injury to persons or damage to Defence Air Systems, and that the Air domain s contribution to Defence is efficient and effective. This is done through a very simple concept personal accountability achieved via the Duty Holder concept and Haddon-Cave s principles of Leadership, Independence, People and Simplicity. 3

4 Accountability (MAA01) Aviation Duty Holders. have a personal duty of care to the personnel under their command, others within their Areas of Responsibility (AoR) and the public. hold legal accountability to provide for the safe operation of systems and the upkeep of Air System Safety Cases within their AoR. 4

5 Responsibility RA 1016 Continuing Airworthiness Management Organization (CAMO) Aviation Duty Holders are responsible for continuing airworthiness and they require the support of a Continuing Airworthiness Management Organization (CAMO) to effectively fulfil these responsibilities. Each DDH should appoint a SQEP Crown Servant as the MOD Continuing Airworthiness Manager (MOD CAM) to manage and control all continuing airworthiness activity 5

6 Compliance Accountable Managers. Are responsible for complying with the Regulations and specifically the terms of the organization s approval. In reality, how does airworthiness accountability flow down into approved organisations? Compliance with CAMO or MRP Part 145 requirements Expositions should reflect contractual or interface arrangements and ensure clarity of responsibilities Compliance with Exposition procedures (CAME / MOE) 6

7 The flow of Continuing Airworthiness accountability /responsibility Aviation Duty Holder (Accountable) Safe Operation inc. Platform Airworthiness MOD CAM (Responsible - Manage and Control) CAMO Contractors Accountable Managers (Comply) Approval Terms Exposition 7

8 Continuing Airworthiness Management Duty Holder / Operator CAM CAMO Responsibility for aircraft continuing airworthiness CAMO Approval IBA / SLA / Sub-contract Partnered Organization CAMO Functions Contract AMO (Maintenance)

9 The MAA Role The MAA develops, promulgates and enforces a regulatory framework to promote an active safety culture and assure appropriate standards are being met in the delivery of Air Safety through an independent end-to-end assurance process. 9

10 So, how should the CAMO work? CAMO Inputs Designer / TAA / MTCH Approved Data (ADS) Technical Instructions Operator s data / info. Maintainer s data / info. Faults/Findings Global platform data Safety data (inc. ASIMS) Regulatory mandates Ops planning Analysis & Decisions Targets Problem resolution Planning Maintenance Modifications AMP development (not approval) Optimisation Configuration control Reliability data Outputs Plans Operations support Maintenance tasking Safety reports Draft AMP changes ADS change requests Spending requests Information sharing Logistics support requests

11 Current challenges CAMO performance Determining and managing against performance targets Understanding the role, responsibilities and intent of CAMO requirements Establishing relationships to get things done Assurance of CAMO performance, not just compliance Organisation interfaces Legacy contracts and arrangements that don t reflect current CAMO requirements In the defence model, contracts (Management, and Technical elements) are not subject to review and acceptance / approval 11

12 The Road to High Performance in Continuing Airworthiness Management Active Leadership Proactive Culture Safety Management Managed Competence Human Factors, & Error Management Compliance Monitoring Supportive Capability Regulatory Compliance Effective Management System Robust Assurance

13 Summary Accountabilities, Responsibilities and Compliance requirements are clearly defined in the MRP The MAA has implemented a regulatory model that gives them the tools to effectively regulate CAMO activity end to end. There are some understanding and interface challenges Legacy contracts and support arrangements need to be influenced to achieve full potential for CAMO performance 13

14 Thank you for your attention