The Most Valuable SMS Tool in Your Organisation Is Probably Being Wasted
And It Happens Every Time You Run a Safety Training Session
Every year, maintenance organisations across Europe gather their engineers into a room, work through a set of slides, collect signatures, and file the records. The box gets ticked. The regulator is satisfied. Everyone goes back to the hangar.
And the most valuable safety intelligence of the year walks out of the door with them.
This is not a criticism of the people running those sessions. It is a description of a systemic problem that the industry has not yet resolved, and that the updated regulatory framework was specifically designed to address. Whether it is working is a different question entirely.
What the Regulation Actually Requires Now
Most people in the industry still refer to this as Human Factors training. That description is no longer accurate, and the gap between the old framing and the new requirement is more significant than many organisations have recognised.
Under Commission Implementing Regulation (EU) 2021/1963, which amended Regulation (EU) No 1321/2014 and became applicable from 2 December 2022, Safety Management System requirements were formally embedded into Part-145. The full compliance deadline for existing approval holders was 2 December 2024. For UK Part-145 organisations, the equivalent requirement under Aviation Safety (Amendment) Regulation 2023 (SI 2023 No 588) sets a mandatory SMS implementation deadline of 1 July 2026.
For Continuing Airworthiness Management Organisations, the requirement arrived earlier. Part-CAMO, introduced via Regulation (EU) 2019/1383, made SMS mandatory for CAMOs from September 2021.
The training requirement under GM1 145.A.30(e) now combines Human Factors and SMS into a single integrated requirement. It is no longer sufficient to deliver Human Factors awareness and consider the obligation met. The organisation must demonstrate that its personnel understand the SMS framework, know how to use internal reporting systems, and are competent to contribute to the organisation’s safety risk management processes.
In plain language: the training session is now a regulatory component of the SMS itself, not simply a standalone awareness exercise that sits alongside it.
The Tick-Box Problem
Understanding the regulation is straightforward. Implementing its intent is considerably harder, and the gap between the two is where most organisations are currently sitting.
The tick-box approach to safety training is not born from indifference. It is born from pressure. Training has to happen within operational constraints. Engineers are needed on the floor. Slots are limited. The training provider delivers the content, the signatures go on the sheet, and the organisation moves forward with its audit trail intact.
What this approach misses is the fundamental purpose of the session within an SMS framework. A Safety Management System is only as effective as the quality of information flowing into it. Hazard identification, risk assessment, and safety assurance all depend on people reporting what they observe, experience, and know. If the reporting culture is broken, the SMS is a procedural shell with nothing substantive inside it.
And in aviation maintenance, the reporting culture is frequently broken. Not because engineers do not care about safety. They care deeply. But because the conditions that produce genuine reporting, trust, psychological safety, and confidence that raising a concern will lead to action rather than consequence, are difficult to build and easy to damage.
The safety training session is one of the few structured opportunities to address that directly. Most organisations are not using it that way.
What Actually Happens in the Room
Ask any experienced engineer who has been through multiple cycles of mandatory safety training what they remember about the sessions. The answers tend to cluster around the same themes.
The slides cover the Dirty Dozen. Someone asks why near-misses never seem to get acted on. A discussion starts about a specific issue on the floor, a procedure that does not work in practice, a piece of equipment that is consistently problematic, a scheduling pressure that creates risk. The facilitator listens, notes it down, and moves on. At the end of the session, there is a vague commitment to “take that away.” Nothing comes back.
This is the vent session dynamic. Engineers use the safety training slot to say things they cannot or will not say through formal channels. The session functions as a pressure release valve rather than as an intelligence gathering mechanism. The concerns are real, the issues raised are frequently genuine safety signals, and almost none of them make it into the SMS in a form that can be acted on.
The reasons are well understood within the industry. Engineers do not raise Ground Safety Reports or Air Safety Reports because they do not always understand what those systems are for, do not trust that reporting will lead to improvement rather than individual scrutiny, and have learned through experience that the formal reporting route produces less response than saying something in the room.
The acronyms themselves are a barrier. GSR. ASR. MOR. Each organisation may use different terminology, and the purpose and destination of each report type is not always clearly explained. If an engineer does not know what an ASR is, cannot find the form, and has no confidence that completing it will change anything, they will not complete it. They will mention it in the next safety training session instead.
The Missed Intelligence Opportunity
Here is the reframing that changes how a safety training session should be designed and delivered.
A room full of engineers in a mandatory training session is not a compliance obligation. It is your highest quality, lowest cost, real-time safety data collection opportunity of the year.
These are the people who work on the aircraft every day. They know where the procedures do not match reality. They know which pressures lead to shortcuts. They know about the near-miss on the nightshift that never got formally reported because the AOG had to be cleared and there was no time, and then it felt too late. They know about the equipment that keeps failing in a particular way. They know about the communication breakdown between shifts that has happened more than once.
All of that knowledge is in the room. The question is whether the session is designed to surface it and capture it in a form that can enter the SMS, or whether it is designed to deliver content at the audience and collect signatures.
These are fundamentally different design philosophies, and they produce fundamentally different outcomes.
What Good Actually Looks Like
A safety training session that functions as a genuine SMS input looks different from a compliance delivery event in several specific ways.
It creates the conditions for honest reporting. This means addressing Just Culture explicitly, not as a slide topic but as a real conversation about what it means in this organisation, in this hangar, with these managers. Engineers will not report if they believe reporting carries personal risk. The session needs to demonstrate, not just assert, that the organisation’s approach to reported information is proportionate and constructive.
It explains the reporting system clearly and specifically. What is a GSR and when should one be raised? What happens to an ASR after it is submitted? Who reads it, who acts on it, and how does the person who raised it find out what happened? These are basic questions that many engineers cannot answer, and the inability to answer them is a direct barrier to reporting. The session should close that gap practically, not theoretically.
It captures what is raised in the room. When an engineer describes a recurring issue during a discussion, that observation has safety value. A well-designed session has a mechanism to capture those observations formally, not just as notes that disappear after the event, but as inputs to the hazard identification process that feeds the SMS. This does not require complex systems. It requires a deliberate decision to treat the session as a data source rather than a delivery event.
It closes the loop. If engineers raised issues in last year’s session, the current session should open with what happened to those issues. What was investigated, what changed, what could not be changed and why. This single element, more than almost anything else, determines whether engineers believe the reporting process is worth engaging with. The absence of feedback is the loudest possible signal that nothing was done.
It is delivered by people who know the operational environment. Generic Human Factors content delivered by someone with no knowledge of Part-145 operations, AOG culture, shift handover dynamics, or the specific pressures of maintenance environments will not land with the audience. Engineers can tell immediately whether the person at the front of the room understands their world. Credibility is not negotiable.
The Accountable Manager’s Questions
The SMS framework places specific responsibilities on accountable managers that extend beyond signing off the training records. Under Part-145 as amended by Regulation (EU) 2021/1963, the accountable manager is responsible for ensuring the management system is established, maintained, and effective.
Effective is the operative word. A management system that processes no safety reports, generates no hazard data, and produces no risk mitigations is not effective regardless of how complete the training records are.
The questions every accountable manager should be asking are simple and uncomfortable.
When did engineers in this organisation last raise a GSR or ASR? If the answer is months or years ago, that is not evidence of a safe operation. It is evidence of a broken reporting culture, and the distinction matters enormously in the event of an incident investigation.
Do engineers know what those reporting systems are and how to use them? If the training session has never addressed this practically, the answer is probably no.
What came back from the last safety training session? Were the issues raised investigated? Were the people who raised them informed of the outcome? If not, the session functioned as a vent and nothing more.
Is the safety training session on the calendar because it has to be, or because the organisation understands what it is for?
The Regulatory Direction of Travel
The introduction of SMS into Part-145 and Part-CAMO is not the end of the regulatory evolution in this area. EASA has consistently signalled that SMS maturity will be assessed progressively, and that the expectation for organisations will increase over successive oversight cycles.
An organisation that can demonstrate a functioning, data-rich SMS, with evidence of genuine safety reporting, closed-loop feedback to staff, and risk management decisions informed by operational intelligence, is in a fundamentally different position from one that can demonstrate only that the training sessions took place and the signatures were collected.
The regulatory floor is the minimum. The organisations that treat it as the ceiling are the ones that will find subsequent audits increasingly uncomfortable.
What OAT’s Safety Training Covers
OAT’s mandatory safety training is built around the combined HF and SMS requirement under GM1 145.A.30(e). It covers Human Factors principles including the Dirty Dozen and SHELL model, the SMS framework and its four components, internal reporting systems including practical guidance on GSR and ASR completion, Just Culture principles and their operational meaning, and fatigue risk awareness.
It is designed to be delivered to engineers who work in real maintenance environments, not to a generic aviation audience. The content reflects the operational pressures, cultural dynamics, and regulatory obligations specific to Part-145 and Part-CAMO organisations.
Initial and continuation courses are available individually and in bulk for organisations requiring training at scale. Custom delivery and LMS hosting options are available for organisations wishing to integrate the training into their own management systems.
Visit www.oat.aero or contact info@oat.aero for course information, bulk pricing, and LMS hosting options.
Summary
Safety training is now a regulatory component of the SMS, not a standalone compliance exercise. The session is the most direct access point most organisations have to the operational safety intelligence held by their engineers. Whether that intelligence is captured and used, or lost in a vent session that produces no actions, is a design and culture decision that sits with the organisation.
The engineers in the room know things the SMS needs to know. The question is whether the session is designed to hear them.