SMS in Part 145

Continuous Safety provides the following customised training, helping Part-145 Certified organizations in matching their Management System integration.

As per Article 1 of Reg (EU) 2021/1963 amending Article 4 of Reg (EU) 1321/2014 the full
compliance with the Part-145 requirements applicable on 2 December 2022 shall be
implemented by 2 December 2024.


The new Part-145 applicable headings for an aircraft maintenance organisation are the following:


145.A.10 Scope
145.A.15 Application or an organisation certificate
145.A.20 Terms of approval and scope of work
145.A.25 Facility requirements
145.A.30 Personnel requirements
145.A.35 Certifying staff and support staff
145.A.37 Airworthiness review staff
145.A.40 Equipment, and tools
145.A.42 Components
145.A.45 Maintenance Data
145.A.47 Production Planning 145.A.48 Performance of maintenance
145.A.50 Certification of Maintenance
145.A.55 Record-keeping
145.A.60 Occurrence Reporting
145.A.65 Maintenance procedures
145.A.70 Maintenance Organisation Exposition (MOE)
145.A.75 Privileges of the organisation
145.A.80 Limitations on the organisation
145.A.85 Changes to the organisation
145.A.95 Findings
145.A.120 Means of compliance
145.A.140 Access
145.A.155 Immediate reaction to a safety problem
145.A.200 Management system
145.A.202 Internal safety reporting scheme
145.A.205 Contracting and subcontracting

Definitions contained in
GM1 to Annex II (Part-145) Definitions are reviewed.

Part-145.A.15 Terms of Approval and Scope of Work
The intent of the internal pre-audit referred to in point 145.A.15(b)(1) is to ensure that the organisation
has internally verified its compliance with the Regulation.

Part-145.A.30 Personnel requirements
The Accountable Manager shall nominate persons or group of persons responsible to manage the
shall be pursuant to the level stated in AMC1 145.A.30(cc) Personnel requirements
The functions of the Safety Manager should be those defined in AMC1 145.A.30(c);(ca).
The organization shall conduct a competency assessment of the nominated person based on the
requirements of Part-145.A.30 (e), skills and aptitude of the nominee, the complexity, size and nature
of operation of the organisation. This assessment shall be sent to TM CAD with the application.

GM2 145.A.30(e) Personnel requirements COMPETENCY ASSESSMENT ELEMENTS for the
Safety Manager in addition to the other staff.
GM4 145.A.30(e) also covers training of compliance monitoring personnel:
Those responsible for managing the compliance monitoring function should receive training on this
task. Such training should cover the requirements of compliance monitoring, manuals and procedures
related to the task, audit techniques, reporting, and recording.
Nominated persons would be accepted by TM CAD following an assessment process of the nomination
of the person.
The nominated persons and Compliance Manager within a Part 145 AMO need to assign a portion of
their available time to the implementation and documentation of the safety management system. In
large and medium sized organisations they will also be required to be part of the Safety Review Board.
In the case of small organisations, the Safety Review Board and Safety Action Group may be deemed
not required.


The importance of Compliance Monitoring

AMC1 145.A.200(a)(6) Management system COMPLIANCE MONITORING — GENERAL
(a) The primary objectives of compliance monitoring are to provide an independent monitoring
function on how the organisation ensures compliance with the applicable requirements, policies
and procedures, and to request action where non-compliances are identified.

(b) The independence of the compliance monitoring should be established by always ensuring
that audits and inspections are carried out by personnel who are not responsible for the functions,
procedures or products that are audited or inspected.

GM1 145.A.200(a)(6) Management system provides technical guidance on the use of remote
information and communication technologies (ICT) to support regulated organisations when
conducting internal audits/monitoring compliance of their organisation with the relevant requirements,
and when evaluating vendors, suppliers and subcontractors.
Part-145.A.200 (c) states:
(c) Where the organisation holds one or more additional organisation certificates within the scope of
Regulation (EU) 2018/1139 and its delegated and implementing acts, the management system may
be integrated with that required under the additional certificate(s) held.

This means that the Management System of Part-145 AMO which forms part of an organization holding
various approvals such as an AOC/CAMO should be integrated. This integration entails that various
units within the AOC holder and TM CAD working together and adopting a more inclusive approach to
comply with the requirements and to cover all the aspects of safety management within all the domains
of an operation.

AMC1 145.A.200(a)(3) Management system
3.1 Hazard identification and safety risk management schemes
3.2 Internal safety reporting and investigations
3.3 Safety action planning
3.4 Safety performance monitoring
3.5 Change management
3.6 Safety training (including human factors) and promotion
3.7 Immediate safety action and coordination with the operator’s emergency response plan (ERP)
3.8 Compliance monitoring
3.8.1 Audit plan and audit procedures
3.8.2 Product audit and inspections
3.8.3 Audit findings — corrective action procedure
3.9 Certifying staff and support staff qualifications, authorisation and training procedures
3.10 Certifying staff and support staff records
3.11 Airworthiness review staff qualification, authorisation and records
3.12 Compliance monitoring and safety management personnel
3.13 Independent inspection staff qualification
3.14 Mechanics qualification and records
3.15 Process for exemption from aircraft/aircraft component maintenance tasks
3.16 Concession control for deviations from the organisations’s procedures
3.17 Qualification procedure for specialised activities such as NDT, welding, etc.
3.18 Management of Control of manufacturers’ and other maintenance external working teams
3.13 Human factors training procedure
3.19 Competency assessment of personnel
3.20 Training procedures for on-the-job training as per Section 6 of Appendix III to Part-66 (limited to
the case where the competent authority for the Part-145 approval and for the Part-66 licence is the
3.21 Procedure for the issue of a recommendation to the competent authority for the issue of a Part-
66 licence in accordance with point 66.B.105 (limited to the case where the competent authority for
the Part-145 approval and for the Part-66 licence is the same).
3.22 Management system record-keeping
In case this section is integrated in the Safety Manual / Management System Manual, the MOE has to
make clear reference to it for traceability and proper review and management of the procedures. Such
manuals shall be also sent for review together with the MOE.

It is recognized that one size does not fit all and customization of the management system and its
procedures in terms of the organisation size, complexity and working environment to enable a
management system which is sustainable and effective.


  1. Safety Policy & Objectives(added by Continuous Safety)
  2. Hazard identification processes
  3. Risk management processes
  4. Internal investigation
  5. Safety performance monitoring and measurement
  6. Management of change
  7. Continuous improvement
  8. Immediate safety action and coordination with the operator’s Emergency Response Plan

Leave a Reply

Your email address will not be published. Required fields are marked *