Compliance is about CASA confirming that the SMS meets the regulatory requirements. As has been stated, compliance for entry control will not in all likelihood meet compliance for effective and functioning. Compliance standards will evolve as the SMS matures.
It is a problem if industry see SMS as a compliance issue only, and not recognise the finanical, safety and efficiency benefits that having an effective SMS offers. Read the following CASA discussion paper which discusses how SMS should be viewed as more than just a compliance requirement.
The following pages are a checklist for SMS entry control compliance only. It suggests the sort of questions an organisation should be asking of itself to confirm that the SMS is Present and Suitable. It does not mean that the SMS is Operational and Effective. The resources tab contains audit criteria for established SMS which could reasonably be expected after 2-3 years of SMS operation to be operational and effective.
Performance Based Oversight
It’s not just about a Yes/No Audit – old way of thinking – not outcome based legislation.
Is the SMS really working?