CAA has mandated that all existing aviation businesses must have an operating SMS by 2021. When CAA rolled out this decree they did 'roadshow' and stated that if a business had an effective health and safety system in place those businesses would have few issues meeting the CAA criteria. I am currently working through the process with an organisation and would beg to differ.
One of the issues is that CAA have no place for 'health' within their parameters 'as it about operational risk' and I have been told by a CAA auditor to remove any reference to health from the documentation. I was asked to remove the word 'health' from the 'Health & Safety Meeting Minutes' form that we use as the word 'health' was considered confusing. (I guess we don't have to worry about pesky things such as noise in the aviation industry)
My take is that from 1992 businesses have been required to have a system in place. The HSWA is legislation and CAA are making rules. Legislation over rides rules! I see no reason to lower our standards to meet theirs.
Please bear in mind that any time dicussion is entered into with CAA the charge out rate is $284 + GST. Not a bad little cashcow as all audits are carried out by CAA staff only. A difficult cost to take for a company 4 people.
Thanks for raising this. I have not had time to review the content yet.
I think it would be pretty short sighed of CAA not to include health risks in their 'operational risks', especially given the national focus and obvious risks in this industry.
CAA SMS doesn't consider Health, because the Health and Safety at Work Act adequately covers it. For that matter, SMS doesn't cover a lot of what he HSaW covers; it isn't concerned with what happens on a day-to-day basis, that doesn't cover aviation risks. Although there is a lot of overlap with the HSaW, in that there is enough commonality in methodology, the focus of the SMS is Aviation Safety, and really outwardly focussed, while HSaW is inwardly focussed.
I's be interested to hear who you have been dealing with, as at the recent CAA SMS forum, it was made very clear that a company's SMS should be their manual and system, and preferably combined with the H&S policies. I'd stand your ground with that issue. CAA are a very different regulator to Worksafe - they are (in my experience) are a lot more open to different ways of complying.
P.S. if they're charging for you to talk to them, then you're talking to the wrong group. The SMS team generally aren't charged out.
Happy to talk off-forum if you want to discuss specifics.
Which SMS is the CAA talking about? I can't think of any SMS that doesn't refer to health. And if NZ aviation businesses decide to use ISO45001 they will have to include health (see clause 6.1.2.1) - or explicitly say it has been excluded. That will then lead to the need to explain and justify the exclusion.
Health is surely an operational matter.
I look forward to talking to CAA people in one of the NZISM Masterclasses on ISO45001!
I think that all the major SMS in current use are likely to be withdrawn now that ISO45001 has been published. Standards Australia has already flagged AS/NZS4801 as an "aged standard" for withdrawal. The ILO had a major hand in developing ISO45001 so its standard document will go. Similarly, OHSAS and others.
Plus ISO45001 is in the ISO "family" of management system standards so it is very compatible with ISO9001 (surely the basis of best practice in running an aviation business?).
CAA set their own SMS and audit standard based on ICAO's, there is a really good A3 page of how it aligns with an OHSMS. https://www.caa.govt.nz/Advisory_Circulars/AC100-1.pdf - Chris, this link will take you to part 100 - SMS.
In a previous role I was involved in the development of a SMS for an aviation business, and the SMS referred to 'aviation and workplace safety and health', we refused to have 2 SMS's, one for aviation and one for workplace. It took a while for them to understand that what they were trying to get us to do, we were already doing, and understand that they way you manage workplace safety (and health) and aviation safety is exactly the same.