ORGH.GEN.130 Management of changes

ASSESSMENT OF CHANGES

(a)Changes may affect the safety performance of a GH organisation and may result in the inadvertent introduction of new hazards that could expose the organisation to new or increased risks if they are not properly managed.

(b)Examples of major changes affecting operations, organisations and personnel:

(1)provision of new GH services;

(2)new types of equipment, including GSE, or equipment based on new technologies;

(3)new types of aircraft for which GH services will be provided;

(4)new stations or schedules;

(5)new training methods or training providers;

(6)new AltMoC;

(7)new or significantly amended regulations, industry standards, good practices or operational procedures, if these have not already undergone a safety risk assessment;

(8)changes in security arrangements;

(9)changes to organisational structure (change of ownership, mergers);

(10)significant changes in personnel affecting key personnel and/or large numbers of personnel (e.g. high volume of newly hired personnel, high staff turnover, insufficient personnel);

(11)transfer of GH services between service providers or between a GH organisation and an aerodrome operator (e.g. PRM handling, operation of PBBs);

(12)changes in the economic situation of an organisation (e.g. commercial or financial).

(c)Effective management of change starts by identifying the scope of the change (why it is necessary, its range, its objective), the magnitude of the change, its safety criticality and its potential impact on human performance. Then, the GH organisation follows the same steps as for a safety risk assessment (hazard identification, risk assessment, risk mitigation). The assessment should be supported by the following data and information obtained through:

(1)conduct of safety cases, safety risk assessments focused on aviation safety. A safety case is a structured argument, supported by evidence, intended to justify that a system is acceptably safe for a specific application in a specific operating environment;

(2)the involvement of key stakeholders in the change management process as appropriate;

(3)the review of previous safety risk assessments, existing hazards and mitigation measures applied; where present;

(4)transparent communication on the implementation plan and progress against the plan.

(d)The assessment of changes is normally initiated by the team that proposes and/or implements them. However, a change can only be successfully implemented if all the personnel affected by the change participate in the process.

(e)The management of change is effective if it is meaningful to the GH organisation and adjusted to its size and complexity.

(f)It is recommended that the process be reviewed upon closure, to identify gaps and lessons learned for future assessments.

CHANGES NOT AFFECTING THE DECLARATION

(a)The intention of point ORGH.GEN.130(b) is to also cover changes that are not directly reflected in the declaration but could influence the discharge of the responsibility for the provision of GH services as declared. Such changes — for example, a change to the organisation’s financial structure or human resource procedures, may have an indirect effect on the organisation’s management system, but they do not have to be reported to the competent authority. That is why it is important that they are managed appropriately.

(b)GH organisations are not expected to inform the competent authority every time they change their documentation. For example, changes such as amendments to their GH manuals or procedures they follow, or updates to their training programmes, station representatives or GSE maintenance programmes, do not need to be reported to the competent authority.

(c)A GH organisation only needs to ensure that the competent authority has the latest version of its documentation, including the items mentioned above, in due time before an inspection or audit.