Risk management should be conducted IAW DASR SMS, supported by guidance within Advisory Circular 003/2008 Risk Management in the DASP. The following paragraphs provide general guidance on applying seven-step risk management associated with a DASR 145 MO authorising non-MAML staff as certifying or support staff. DASA does not seek to interfere in the decision-making that properly belongs to the Command Chain, or substitute its judgment for that of the Commander. The purpose of this guidance is to support clear articulation of the risk by MAOs to enable DASA to provide timely independent assurance over the decision making process. The approach described by this guidance maybe tailored relative to the available time to document the risk assessment rationale and specific context of the operational need.
Step 1 – Establish the context, including a robust operational need statement. What is the resulting cost to capability (including capability preparedness) associated with the lack of sufficient MAML holders at the 145 MO? This should:
Explain the hazard context (airworthiness impact) as it relates to the issue of a CRS or acting as support staff (DASR 145.A.50, 145.A.35, 145.A.30 & 66.A.20).
Consequence (not likelihood) associated with granting certification authorisation to personnel not holding an appropriate MAML (eg the granting of unrestricted CRS authorisation equivalent to privileges of a Category B MAML would involve complex flight-critical maintenance and the hazard level would need to reflect this).
Detail insufficient numbers of certifying staff.
Asset vs requirement (rank independent) – requirement needs to be contextualised (e.g. the MAO needs to be able to maintain five separate deployed locations but current operations/tempo only allow three).
Numbers should not include total maintenance staff – focus should be on certifying staff only and be expressed in absolute quantities rather than percentages.
Can include information on number of category B MAML holders with MAML E62 exclusion who can only certify maintenance they have personally performed.
Can include information on MAML holders who are not able to certify for maintenance due to essential command and management duties.
Describe what capability risk would be realised if the DASA 145 MO did not authorise non-MAML staff as certifying or support staff (the operational need).
Can include immediate effect on operations or impact on Raise, Train, Sustain activities that would lead to a future degradation of capability.
Be as specific as possible but can include commentary on generalised capability deficiencies that would likely occur such as failure to meet preparedness objectives (DASA assurance will focus the documented evidence defining a clear and unambiguous capability need not the validity of the capability need).
Describe how the DASR non-compliance is being remediated.
For short-term exchanges / secondments of foreign-trained personnel, obtaining a MAML may be grossly disproportionate. In these cases, cancelling risk-based authorisations as soon as they are no longer needed may be a reasonable remediation action. By contrast, gaining a MAML is likely to be a reasonable action for a permanent lateral recruit.
Step 2 – Be reasonably informed. Through understanding the risk controls inherent in a holding a MAML (e.g. categorisation, exclusions and type ratings). This should address:
What is the Qualification, Training and Experience (QTE) difference from DASR 66 requirements?
Needs to be based on individual documented QTE and could include relevant prior authorisations.
Should not just look at collective Initial Employment Training (IET) comparisons but may contain this analysis.
Can include an assessment of experience against specific basic knowledge elements (e.g. specific aircraft systems).
Does each individual have a military aircraft type rating or equivalent?
If not, describe the risk associated with this person certifying maintenance in a DASA 145 MO.
Could include information related to experience working on relevant or similar types.
Has each individual held a certification authorisation within an EMAR 145 organisation?
If not, describe the risk associated with this person certifying maintenance in a DASA 145 MO.
If so, what was the scope of this authorisation (e.g. currency as well as trade limitations and any restrictions) and the risk associated with this person certifying maintenance in a DASA 145 MO.
Has each individual completed unit operational induction, including instruction/training specific to the MOE, maintenance recording/management systems, and all relevant unit instructions/procedures?
If not, describe the risk associated with this person certifying maintenance in a DASA 145 MO.
Step 3 – Eliminate risk SFARP. This should address:
Why is it grossly disproportionate not to restrict capability (e.g. reduce ROE or restrict number of operating locations)?
Why is it grossly disproportionate not to limit authorisations to Task Sign Off?
For example why is it unreasonable for foreign-trained personnel to perform but not certify maintenance in terms of capability impact. This includes authorising personnel as supervisors (not certifying staff) as detailed in AMC to DASR 145.A.65(b)3.
Where existing MAML holders are not available due to command and management duties, is it possible to have others backfill command and management duties or leave command and management duties unfulfilled?
Step 4 – Minimise risk SFARP. This should:
Identify any area of remaining risk.
Describe how controls will be implemented to minimise risk including: type training, locally developed training, limiting the scope of certification authorisation, and completion of unit operational induction. If controls are not implemented, describe why those controls are grossly disproportionate.
Will non-MAML staff as certifying or support staff only be used in the absence of certifying staff with a MAML? If not, why it is grossly disproportionate to do this?
Describe how the scope of authorisation will be limited to particular systems or complexity of work to minimise risk.
Describe any additional controls/restrictions that can reasonably be placed on non-MAML staff as certifying or support staff to minimise risk SFARP.
Step 5 – Characterise risk. This is to be done in accordance with the MAO SMS.
Step 6 – Decision to Proceed. Describe why the residual risk is reasonable to retain in the context of the capability impact that would occur if the risk were not retained.
Step 7 – Review risk. This should:
Describe risk review process
Include a plan, including a timeline, to remediate non-compliance with DASR.