Assessment of changes to functional systems in ATM/ANS and the oversight thereof Entry Point North Seminar: The changing landscape of ATM Safety Malmo, 26 th -27 th May 2015 Jose L Garcia-Chico Gomez ATM/ANS Regulations Officer FS4.2 ATM/ANS section jose-luis.garcia-chico@easa.europa.eu Flight Standards Directorate, EASA 1
Background Functional system Underpinning Principles Safety & Safety Support Assurance Multiactor changes Proxies 2
What the new regulation introduces Evolution from current regulations EU 1034/2011 and 1035/2011 Less process-based support and extend current practices Reduce subjectivity Add flexibility: alternatives to risk assessment not all service providers to perform safety assessments 3
Where in the future ATM/ANS rule structure? Provisions distributed in several Aneexes Annex I Definitions Regulation ATM/ANS Annex II Part-AR General requirements Part-AR: Authority requirements Part-OR: Organisation requirements Specific service requirements Annex III Part-OR Annex V Part-MET Annex IV Part-ATS Annex VI Part-AIS Part-ATS: Air Traffic Services Part-MET: Meteorological services Part-AIS: Aeronautical Information Services Annex VII Part-DAT Annex IX Part-ATFM Annex XI Part-ASD Annex VIII Part-CNS Annex X Part-ASM Annex XII Part-NM Part-DAT: Data providers Part-CNS: Communication, Navigation, Surveillance Part-ATFM: Air Traffic Flow Management Part-ASM: Airspace Management Part-ASD: Airspace Design Part-NM: Network Manager Annex XIII Part-PER Part-PER: Personnel requirements 4
Timeline for assessment of changes 24 Jun. 14 NPA2014-13 (Assessment of Changes to Functional system) 16 Dec. 14 Opinion 03-2014 (with CRD to NPA2014-13) Today May 15 Draft AMC/GM Dec 15 NPA2 (Update AMC/GM) Jul 14 Oct 14 Jan 15 Apr 15 Jul 15 Oct 15 01/06/2014 31/12/2015 Jan 15 SSC 55 (Presentation) Mar 15 SSC 56 (SSC workshop results) Jun 15 SSC 57 (Agreed) Oct 15 SSC 57 (Vote) 2016 EC Adoption 5
Background Functional system Underpinning Principles Safety & Safety Support Assurance Multiactor changes Proxies 6
Scope: what services are addressed? air navigation services ANS air traffic management air traffic services ATS communication services navigation services CNS air traffic control services ATC surveillance services - area control service - approach control service - aerodrome control service alerting service meteorological services MET air traffic advisory service flight information services aeronautical information services AIS airspace management ASM Navigation data providers DAT air traffic flow management ATFM Other ATM network functions Network Function ATM 7
Planned changes to functional system What is a functional system? A combination of equipment (SW and HW), procedures and human resources organised to perform a function within the context of ATM/ANS and other ATM network functions 8
Two types of changes Unplanned change*: due to people adapting their behaviour to suit the operational circumstances e.g.: seeking improvements - self motivated changing their goals/motives, adapting to unforeseen circumstances: wrongly designed technical systems or services changes in the operational context Planned change: Somebody notices that a change is needed and gets permission for the organisation to make a change (*) These should be identified by monitoring the functional system and corrected where necessary through planned changes 9
Examples of changes Examples: Airspace changes-reorganisation; Changed or introduction of communication, navigation, or surveillance system; Changes or new approach procedure; Introduction of automation to replace/assist human actions; New automatic meteorological information; Introduction of time-based separation; Etc 10
Background Functional system Underpinning Principles Safety & Safety Support Assurance Multiactor changes Proxies 11
Principles: ATM/ANS providers (I) The ATM/ANS provider should be aware when a change to the operational (functional) system is necessary and it should make the change in a timely manner (Change Drivers proactive change) No change should be made unless it can be shown that the ATS will be acceptably safe, via a valid assurance case, prior to its implementation. The CA is notified of the intention to make a change. Notification should give the CA sufficient time to review it. Where a CA review is to be performed, it has to be approved by the CA, before implementation. (Notification involved simpler for routine changes) Even if the CA doesn t review the change the provider must ensure that a valid assurance case exists before the change is implemented. 12
Principles: ATM/ANS providers (II) Changes by ATS providers require safety assessment and assurance to show they are acceptably safe. Changes by other service providers require safety support assessment and assurance to show they are acceptably trustworthy (safety assurance/safety support assurance) Changes often involve change by many independent stakeholders, these should be managed as though they were a single change ( Coordination of multi-actor changes) The provider must monitor the behaviour of the system using monitoring criteria included in the assurance case and, where necessary, introduce new changes. (Change Drivers monitoring) 13
Principles: ATM/ANS providers (III) The acceptable level of safety for the change must be decided and declared by the service provider in terms of safety risk or other measures related to safety risks. (Proxies, recognised standards/practices) Safety criteria should be based on the notion that the operational (functional) system should support the improvement of safety whenever reasonably practicable; be at least as safe after the change as it was before; or the loss on safety is Temporal: to be offset in the future Permanent: other beneficial consequences (Objective for safety) 14
Principles: competent authorities The CA, when notified of the intention to make a change, seeks the data on which the decision, whether to review the change or not, will be based The CA decides whether to review the change or not The decision should use objective risk based criteria (Risk posed by the change) The rigour of the review (its breadth and depth) should be proportional to risk (Risk associated with the change)*. Changes involving several providers may also involve several CAs. These CAs need to cooperate in reviewing the change (multi-actor change) (*) Not present in the rule at the moment. 15
Background Functional system Underpinning Principles Safety & Safety Support Assurance Multiactor changes Proxies 16
The view of safety* - 1 ATS providers can: communicate with Aircraft provide traffic information understand the intent of traffic provide separation They: can intervene if they see an unsafe situation developing have a view of safety *Safety related to aircraft separation 17
The view of safety - 2 ATM/ANS providers other than ATS providers are unable to: communicate with Aircraft provide traffic information understand the intent of traffic provide separation They only have partial knowledge can not intervene when an unsafe situation develops do not have a view of safety 18
Safety assessment & Safety support assessment: The need and the focus All service providers need to assess changes they make to their functional system, but demonstrate, via safety criteria, that the change to ATS service is acceptable safe (Safety Assurance Case) ATS Providers Safety Assessment ATM/ANS provider (other than ATS) Safety Support Assessment Demonstrate the trustworthiness of the specification (Safety Support Assurance Case) Risk Analysis Behavioural Analysis Safety Risk Levels Severity x probability Use of proxies e.g., head-down time at TWR e.g., integrity, accuracy of navigation signal in space 19
Safety Assurance & Safety Support Assurance: an example of interaction The service is delivered into an airspace. It may not be delivered to a particular user. The service is accessed and used by a conforming a/c as part of an ATS Service Specification Safety Support Case ATSP Separation Service Safety Case 20
Background Functional system Underpinning Principles Safety & Safety Support Assurance Multiactor changes Proxies 22
Service Service Service Multiactor changes (notion) 1 Operational Context Operational Context Operational Context Text Text Text Service Text Operational (functional) System Rules & Procedure s Text Dat Service Operational (functional) System Rules & Procedure s Nav Service Text Operational (functional) System Rules & Procedure s Separation Service Text Operational Context Navigation Data Provider Operational Context Navigation Provider Operational Context Air Traffic Service Provider Operational Context Regulated service Unregulated service Independent organisations 23
Multiactor changes (notion) 2 24
Description seems straight forward, but is it really? Any change to the functional system of an ATM/ANS provider affecting other ATM/ANS providers and/or aviation undertakings 25
The need for specific provisions dealing with changes affecting multiple actors is real Account for cascade effects of changes to third parties and feedback effects ATM system is a complex and interconnected system Multiple interdependencies Different view of safety of ATM/ANS providers 26
When a change affects other stakeholders: dependencies & interdependencies A change may modify: Service (e.g., reduction of separation) Operational environment (e.g., airspace structure) Other ATM/ANS or aviation undertaking may be affected: (as end user) Use the affected service Operate in the affected environment (if they deliver service to others) Deliver a service making use of the affected service Deliver a service in the affected environment 27
The ATM/ANS provider proposing a change affecting multiple actors 1 Notify all affected stakeholders to the CA 2 Coordinate activities with other affected ATM/ANS providers to: a. Identify all dependencies b. Identify assumptions and mitigations that relate to multiple actors 3 Use only aligned and agreed assumptions and common mitigations or alternatively: a. use an additional body of evidence, b. engage a representative body of av. undertakings, 28
Competent authorities coordinating in MAC Only when the service providers are not under the oversight of a single CA 1 2 Use the process to establish coordination arrangements with other CAs Ultimate aim is to ensure effective selection and review of related changes CAs will decide the best way to ensure it Within FABs, suitable coordination may be based on current FAB arrangements 29
Background Functional system Underpinning Principles Safety & Safety Support Assurance Multiactor changes Proxies 30
Flexibility introduced about HOW Safety criteria: specific and verifiable criteria used for the safety acceptability of a change explicit quantitative acceptable safety risk levels; or Proxies; or recognised standards and/or codes of practice; or the safety performance of the existing system or a similar system elsewhere 31
Proxies used as a surrogate of safety risk PROXY: A measurable property that relates to safety risk, but is more accessible than safety risk 1 Justifiable casual relationship exists between the proxy and the safety risk 2 Sufficiently isolated from other proxies 3 Measurable to an adequate degree of certainty Examples of proxies: head-down time, workload, error rate, false alert rates, service continuity 32
Why the use proxies? to facilitate the focus on the analysis and mitigations of the identified hazards: positive effects of changes to save resources when extra effort to identify, describe, and analyse the complete sequence of events from hazards to accidents has no added value to compensate for the lack of evidence on the probability of some events to facilitate the recognition of safety issues by operational staff Facilitating communication and buy-in of changes 33
Take away messages Evolution of current rules (less process-based) Safety assessment vs Safety support assessment Multiactor changes Alternatives to use explicit risk metric 34
Questions? 35