UK Part-145 SMS and 'safety training including human factors': what changes for maintenance organisations

UK CAA Part-145 SMS mandatory 2026 — what is the human factors training change?

Since 1 July 2024 the UK Part-145 rule has required a management system that includes safety management, and the CAA has set 1 July 2026 as the date by which approval holders must have implemented it. The competency clause, UK 145.A.30(e), now demands that staff understand the application of safety management principles, including human factors and human performance, which is why the training is called “safety training including human factors” rather than plain human factors training.

This guide sets out what the UK introduced and when, how the new training name differs from the human factors courses most organisations already run, who has to be trained, how it fits the existing 2-year cycle, and what an EASA organisation with UK customers should take from it.

What did the UK CAA introduce, and when?

The instrument is the Aviation Safety (Amendment) Regulations 2023, Statutory Instrument 2023 No. 588. It amended UK Regulation (EU) No 1321/2014, the assimilated version of the EU continuing airworthiness regulation, and its Part-145 provisions came into force on 1 July 2024. The CAA’s Part 145 SMS implementation page states the consequence plainly: the amendment requires Part 145 approval holders to implement a Safety Management System by 1 July 2026, and an on-site verification of the approval will be planned within the next two years as part of routine oversight.

Three UK clauses matter for training:

• UK 145.A.200, Management system. The organisation must establish, implement and maintain a management system that includes safety management, mirroring the EU clause introduced by Regulation (EU) 2021/1963.
• UK 145.A.30(e). The competency clause. The wording is the EU text with the CAA named as competent authority.
• UK 145.A.35(d). The 2-year training requirement for certifying staff and support staff, again the EU wording.

One structural difference: the UK numbers its nominated persons 145.A.30(b)(1), (2) and (3), where the EU text uses (b), (c) and (ca). Cross-references in your Maintenance Organisation Exposition (MOE) need to follow the UK numbering.

The SI also contains a transitional rule. A Part-145 organisation must correct any findings of non-compliance related to the implementation of the safety management system requirements before 1 July 2026, or the approval certificate may be revoked, limited or suspended. That date has now passed. An organisation still carrying such findings should treat closing them as the first priority of its next oversight cycle.

What does ‘safety training including human factors’ cover that classic HF did not?

The name comes from AMC4 145.A.30(e), whose heading is “Safety training (including human factors)”. The change is best seen by placing the GM1 145.A.30(e) syllabus next to a classic human factors programme of the kind CAP 716 supported in 2003.

GM1 145.A.30(e) topic	Classic human factors course	New with the SMS wording
1. General, introduction to safety management and human factors	Partly (introduction to HF)	Adds safety management framing
1a. Safety risk management: hazard identification, risk assessment, mitigation, effectiveness	No	Yes
2. Safety culture and organisational factors: justness, trust, commitment, adaptability, awareness, behaviour, information	Partly (organisational culture)	Reframed around just culture
3. Human error	Yes	—
4. Human performance and limitations	Yes	—
5. Environment	Yes	—
6. Procedures, information, tools and practices	Yes	Adds critical maintenance tasks and error-capturing methods
7. Communication	Yes	—
8. Teamwork	Yes	—
9. Professionalism and integrity	Yes	—
10. Organisation’s safety programme: safety policy and objectives, just culture, internal safety reporting scheme, investigation	Partly (reporting)	Ties to 145.A.200 and 145.A.202

The classic content survives intact. What the SMS amendment adds is the front and back of the syllabus: how the organisation identifies and manages risk, and how the individual’s reports feed the organisation’s safety programme. A course that stops at the Dirty Dozen no longer covers the syllabus.

A word on CAP 716. The CAA still lists Aviation Maintenance Human Factors (EASA Part-145), Issue 2 of 18 December 2003, as a current publication. It remains the CAA’s human factors guidance, and it is a good source for error theory and organisational culture material. It was written two decades before the SMS clause, so the safety risk management and safety programme topics must be taken from the current AMC and GM and from your own management system.

Who must be trained?

The UK rule text does not list job titles; the AMC does. The EASA AMC4 145.A.30(e) list, from which the UK material was carried over at EU exit, is the reference used here; the UK AMC and GM sit in the CAA regulatory library, which requires registration, and should be checked for CAA-specific wording. The population is:

• nominated persons, line managers and supervisors;
• certifying staff, support staff and mechanics;
• planners, engineers and technical records staff;
• compliance monitoring and safety management staff, including those running internal investigations and safety training;
• specialised services staff;
• stores and purchasing staff;
• ground equipment operators.

Everyone on that list should receive initial safety training before starting the job function, with a 6-month allowance for new directly employed staff under direct supervision, and then further training in each 2-year period. The organisation should assess all other personnel for the need for training and record the outcome. Under the SMS the safety manager is a natural owner of this record alongside the compliance monitoring manager.

How does this fit the continuation cycle you already run?

The cycle itself is unchanged: initial, then in each 2-year period under AMC4 145.A.30(e)(c), with 145.A.35(d) making the 2-year requirement mandatory for certifying and support staff. Two things change inside the cycle.

Content. AMC4(c) says the purpose of further training is to keep staff current in SMS principles and human factors and to collect feedback on safety and human factors issues. AMC1 145.A.35(d) lists what the session should cover: changes to the requirements such as Part-145 itself, changes to procedures, safety policy and objectives, safety issues identified from internal or external analysis, and cases where procedures were not followed and why. The SMS amendment is itself a “change to the requirements” that belongs in the next session.

Feedback loop. AMC4(c) asks for a procedure so that trainers report feedback formally through the internal safety reporting scheme, and suggests involving compliance monitoring and key safety management personnel in the training. Under UK 145.A.200 and 145.A.202 that scheme is now a regulatory component of the management system, so training records and safety reports should reference each other.

Duration remains a judgement. AMC1 145.A.35(d) talks of days rather than weeks for an organisation with few findings, several weeks for one with many, and a review of the programme at least once every 24 months.

What should EASA organisations take from the UK timeline?

The UK ran a two-year implementation window with a hard deadline and an announced verification visit. EASA organisations have lived with 145.A.200 since Regulation (EU) 2021/1963 and their authorities audit it through routine oversight without a single published cut-off. If you hold both approvals, or serve UK customers from an EASA organisation, three points follow:

1. Your training syllabus already has to cover safety management under the EU clause, so a single GM1 145.A.30(e) course serves both approvals; only the MOE cross-references differ.
2. Certificates that name the clause served, the date and the issuer are easier to present to a CAA surveyor checking SMS implementation than certificates that say only “Human Factors”.
3. The UK’s nominated-person numbering and any CAA-specific AMC wording need to be reflected in the UK MOE, not assumed from the EU version.

Related courses. Part-145 Safety Training including Human Factors — Initial follows the eleven GM1 145.A.30(e) topics, including safety risk management and the organisation’s safety programme; the Continuation course serves the 2-year cycle for staff who already hold an initial certificate.