In a submission to the Civil Aviation Authority (CAA), Aviation Safety Management Systems Ltd (ASMS) say that Safety Management Systems are already mandatory under the Health & Safety in Employment Act (HSE Act). Paraphrasing the Royal Commission on the Pike River Coal Mine Tragedy, ASMS say that “the HSE Act requires CAA to take all reasonable steps to ensure that the act is being complied with. This can only be achieved by mandatory implementation of SMS.” ASMS considers that the legal basis for mandatory SMS is already in place and that the CAA’s proposed changes might be able to be implemented by a simple change of policy.
At the end of May the CAA released a consultation document on whether mandatory risk management or safety management systems should be required for operators in New Zealand’s aviation industry. This consultation document was supported by a series of forums held around the country in early June.
ASMS recommends that the CAA should avoid trying to “reinvent the wheel”, and focus on the implementation of SMS that complies with Australian/New Zealand Standard 4801:2001 Occupational Health & Safety Management Systems (AS/NZS 4801:2001). ASMS states that this standard provides an excellent basis for the implementation and audit of SMS. “This standard can be applied to all industries, including high hazard industries of which aviation is just one example. AS/NZS 4801:2001 is endorsed by the Ministry of Business, Innovation and Employment (MBIE) and the Institute of Directors as providing the guidelines for an effective safety management system. It has also been recognised by the New Zealand Defence Force as the appropriate framework for safety management, and it is the basis for the ACC’s audit standard.”
ASMS also recommends that mandatory SMS should be extended to the Adventure Aviation sector, which includes activities such as tandem parachutes and hot air ballooning. Regulation under Part 115 brought the Adventure Aviation sector up to the same standard as other sectors of general aviation. However, like the rest of aviation, Adventure Aviation should be subject to SMS. ASMS state “every other Adventure Tourism activity is subject to mandatory SMS and must be audited against the Safety Audit Standard for Adventure Activities published by MBIE. Adventure Aviation was only granted an exemption from being covered by these regulations on the basis that CAA was about to pass CAR Part 115 and that Part 115 would provide the necessary safety management systems.”
ASMS’ submission is available
here.
