Phase 0 of the Safety Management Systems SMS

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Phase 0 of the Safety Management Systems (SMS) Pilot Project Federal Aviation Administration The Beginning! SMSPP Phase 0 Federal Aviation Administration 1

AGENDA 1. Introductions 5 min 2. Overview of SMS 45 min 3. The SMS Table 30 min 4. Break 15 min 5. Use of the SMS Guidebooks 10 min 6. Summary SMS Audit/Gap Analysis Tool 10 min 7. Detailed SMS Audit/Gap Analysis 10 min 8. Pilot Project Implementation Plan 15 min 9. Open Discussion 40 min SMSPP Phase 0 Tools Federal Aviation Administration 2

INTRODUCTIONS SMSPP Phase 0 Federal Aviation Administration 3

Overview of Safety Management Systems (SMS) SMSPP Phase 0 Federal Aviation Administration 4

Really? At this airline, safety is our first priority SMSPP Phase 0 Federal Aviation Administration 5

What is the primary objective of a business organization? SMSPP Phase 0 Federal Aviation Administration 6

Safety Management – Rationale • In order to achieve its production objectives, the management of any aviation organization requires the management of many business processes. • Managing safety is one such business process. • Safety management is a core business function just as financial management, HR management, etc. • This brings about a potential dilemma for management. SMSPP Phase 0 Federal Aviation Administration 7

The management dilemma Resources Protection SMSPP Phase 0 Management levels Resources Production Federal Aviation Administration 8

The management dilemma R esou r ces Man age leve ment ls Res our ces Protection Production Catastrophe SMSPP Phase 0 Federal Aviation Administration 9

The management dilemma e urc o R ent gem ana els s rce M lev ou es s Res Production Protection Bankruptcy SMSPP Phase 0 Federal Aviation Administration 10

Safety Space Protection Bankruptcy Catastrophe Source: James Reason SMSPP Phase 0 Production Federal Aviation Administration 11

Safety Management – The response to the dilemma • Safety issues are a byproduct of activities related to production/services delivery. • An analysis of an organization's resources and goals allows for a balanced and realistic allocation of resources between protection and production goals, which supports the needs of the organization. • The product/service provided by any aviation organization must be delivered safely (i. e. protecting users and stakeholders). SMSPP Phase 0 Federal Aviation Administration 12

What is safety? • Safety is not equivalent to risk free (U. S. Supreme Court, 1980) • Carelessness and overconfidence are more dangerous than deliberately accepted risk (Wilbur Wright, 1901) • Practical safety is risk management SMSPP Phase 0 Federal Aviation Administration 13

Mitigating to “Acceptable Risk” “Safety in a system may be defined as a quality of a system that allows the system to function under predetermined conditions with an acceptable minimum of accidental loss. ” System Safety Engineering & Management, 2 nd Edition, John Wiley & Sons 1990 ISBN 0471618160 SMSPP Phase 0 Federal Aviation Administration 14

Why SMS? An imperfect system System design Baseline performance Operational deployment SMSPP Phase 0 Op er ati on al “Practical drift” pe rfo rm an ce Federal Aviation Administration 15

Risk Management is…. New Info? Tracking …. a continuous process …. a closed loop process …. cross discipline Modify Process Evaluate Hazard Controls Analyze Hazard(s) Manage Risk SMSPP Phase 0 Identify Hazards Assess Risk Federal Aviation Administration 16

A Risk Assessment Matrix Example Risk severity Risk probability Catastrophic Hazardous Major Minor Negligible A B C D E Frequent 5 5 A 5 B 5 C 5 D 5 E Occasional 4 4 A 4 B 4 C 4 D 4 E Remote 3 3 A 3 B 3 C 3 D 3 E Improbable 2 2 A 2 B 2 C 2 D 2 E Extremely improbable 1 1 A 1 B 1 C 1 D 1 E SMSPP Phase 0 Federal Aviation Administration 17

Risk Acceptance • Risk is inherent in aviation operations • Risk results from aspects of the environment and byproducts of operational activities • Operator is responsible for risk management (Title 49 – FA Act) • A fundamental concept of risk management is acceptance of risk • Risk management is fundamental to the SMSPP Phase 0 Federal Aviation Administration 18

Four “Pillars” of SMS Policy: (Structure) Risk Safety Mgmt. Assurance Safety Promotion: (Culture) SMSPP Phase 0 Federal Aviation Administration 19

SMS is the toolbox for… • Policies & management practices • Risk Management processes • Safety Assurance processes • Confidential reporting processes/employee involvement SMSPP Phase 0 Federal Aviation Administration 20

What is the Regulator’s Duty? • It is NOT safety achievement …or “management” • It IS safety “oversight” SMSPP Phase 0 Federal Aviation Administration 21

What is the Provider’s Duty? • Safety achievement is the responsibility of the “provider” The FAA’s resources are best applied in assisting / enabling safety management by the business or operation SMSPP Phase 0 Federal Aviation Administration 22

Is ATOS the same as SMS? • ATOS: An Oversight System used to fulfill FAA safety responsibilities • SMS: A Management System used to fulfill operator safety responsibilities SMSPP Phase 0 Federal Aviation Administration 23

ATOS and SMS FAA (ATOS) Oversight Program Management (8 Modules) DA PA Production Protection Objective: Public Safety FAA’s Safety Management System (SMS-O) Direct sampling (e. g. surveillance) Objective: Serve customer requirements S A S R M Air Carrier’s SRM/SA SMSPP Phase 0 Operator’s Safety Management System (SMS-P) Inputs Process Outputs are Products / Services Objective: Manage safety actions as part of “business” processes Federal Aviation Administration 24

SMS for “Providers” is… … a top-down program starting with “Top Management” SMSPP Phase 0 Federal Aviation Administration 25

A SMS Organization… Develops a “Just Culture” or “Safety Culture” to: Capture the operational knowledge and experience of the employees Involve the employees in the safety achievement process SMSPP Phase 0 Federal Aviation Administration 26

A Positive “Safety” Culture is… …An informed culture where People understand hazards and risks. • Staff work continuously to identify and overcome threats …A reporting culture where • • • People are encouraged to voice safety concerns Those concerns are analyzed and appropriate action is taken The workforce knows and agrees on what is acceptable and unacceptable (shared values) SMSPP Phase 0 Dr. Aviation Federal. James Reason 27 Administration

A Positive “Safety” Culture is… …A learning culture where: • People are encouraged to develop and apply their skills and knowledge to enhance organizational safety • Management updates staff on safety issues • Safety reports are fed back to staff so everyone learns …A just culture where: • The workforce knows and agrees on what is acceptable and unacceptable (shared values) • Errors are understood but willful violations are not tolerated SMSPP Phase 0 Federal Aviation Administration 28

What’s in a “Just Culture? ” • The immediate response is to find “what happened and why, ” not “who to blame and punish” • Acceptance that more can be learned through full reporting and detailed investigation than by blame and punishment • Partnership in identifying hazards and root causes SMSPP Phase 0 Federal Aviation Administration 29

SMS…emphasizes Risk Management …It integrates safety with Line Management SMSPP Phase 0 Federal Aviation Administration 30

The International Picture ICAO safety management requirements Ø Annex 11 - Air Traffic Services Ø Annex 14 - Aerodromes Ø Annex 6 - Operation of Aircraft Ø Annex 6 - Maintenance of Aircraft SMSPP Phase 0 Federal Aviation Administration 31

ICAO Annex 6 Requirements • “…a safety management system acceptable to the State of the Operator that, as a minimum: • identifies safety hazards; • ensures that remedial action necessary to maintain an acceptable level of safety is implemented; and • provides for continuous monitoring and regular assessment of the safety level achieved. ” • …and, aims to make continuous improvement to the overall level of safety (proposed amendment) SMSPP Phase 0 Federal Aviation Administration 32

Annex 6 requirements (cont. ) • “An accepted safety management system shall clearly define lines of safety accountability throughout the operator’s organization, including a direct accountability for safety on the part of senior management. ” SMSPP Phase 0 Federal Aviation Administration 33

An Industry Answer? ICAO, FAA, overseas Regulators, Air Carriers, ALPA, IATA, IBAC SMS Launching a common idea and a new approach: SMSPP Phase 0 Federal Aviation Administration 34

FAA Support of the SMS Concept • U. S. Response to the Annex 6 proposal endorsed the SMS concept • Prior U. S. implementation of system safety-based oversight systems • ATOS • SASO • FAA (AVS) will also apply safety management concepts to oversight activities SMSPP Phase 0 Federal Aviation Administration 35

The SMS Standard • First FAA SMS standard was delivered on June 22, 2006 in Advisory Circular AC 120 -92. • SMSs are currently voluntary in the United States • The standard is organized around the “four pillars” • The standard is based on an extensive review of existing SMSs around the world • The format of the SMS standard is similar to that of the ISO standards SMSPP Phase 0 Federal Aviation Administration 36

Rulemaking Effort • Part 121 Rulemaking Project Record (RPR) opened Nov. 2006 • Project cancelled Jan. 2008 • Project team commissioned to create integrated SMS Rule for all CFR parts • Objective: harmonization of requirements • Strategy is being formulated • ARC is a possibility SMSPP Phase 0 Federal Aviation Administration 37

Testimonials – • “Why didn’t TC do this years ago? ” (705 Operator) • “We are now much more aware of our safety responsibilities and liabilities. ” (AMO) • “My employees are involved in developing the SMS processes. They tell me they feel safer at work. ” (small AMO) • “It is too early to realize all the benefits of SMS, but already employees and customers have an increased confidence in the company. (AMO) • “Already we are seeing the benefits of recording and tracking incidents and hazards” (FTU) • “The idea of SMS is much scarier than the actuality. ” (702, 703 Helicopter Operator). SMSPP Phase 0 Federal Aviation Administration 38

Others ü Air Transat initially saved over $1 million per month ü Skyservice saved $5 million in first year of SMS operation SMSPP Phase 0 Federal Aviation Administration 39

The SMS Table SMSPP Phase 0 Federal Aviation Administration 40

The SMS Table (Top View) External Audit Are data sources accurate, complete and timely? External Audit Are policies, procedures, and organizations appropriate? Internal Eval. Operational Employee Data Reports Change Management System & Task Analysis External Audit Is there a safety culture? Is there adequate training & communication? SMSPP Phase 0 External Audit Are risk mitigations effective? When not, is the risk re-introduced into SRM for re-analysis? External Audit Is there a Voluntary Reporting System? External Audit Are all hazards identified? External Audit Are identified hazards analyzed correctly? External Audit Are risk mitigation strategies appropriate? © 2006 The MITRE Corporation. All Rights Reserved. Federal Aviation Administration 43

The SMS Table (Top View) External Audit Are data sources accurate, complete and timely? External Audit Are policies, procedures, and organizations appropriate? Internal Eval. External Audit Are risk mitigation strategies appropriate? External Audit Is there a safety culture? Is there adequate training & communication? SMSPP Phase 0 External Audit Are risk mitigations effective? When not, is the risk re-introduced into SRM for re-analysis? External Audit Is there a Voluntary Reporting System? External Audit Are all hazards identified? External Audit Are identified hazards analyzed correctly? © 2006 The MITRE Corporation. All Rights Reserved. Federal Aviation Administration 44

BREAK SMSPP Phase 0 Federal Aviation Administration 45

SMS Implementation and Tools SMSPP Phase 0 Federal Aviation Administration 46

SMS Guidebooks The purpose of the Guidebooks is to provide a framework and offer developmental guidance to aid organizations in defining their organizational safety structure. SMSPP Phase 0 Federal Aviation Administration 47

Format of the Guidebook • (OBJ) are objectives. This information describes or outlines what you will be expected to develop in this specific area of your Safety Management System documentation, in order to meet an SMS standard. • (STD) are standards. This is the specific language of the standard that the organization will be held to in order to meet the statement of requirements conveyed in the policy/procedure section. • (DG) is developmental guidance This provides instruction regarding how you can develop your policy, procedures, and controls to address each specific requirement of the Safety Management System. SMSPP Phase 0 Federal Aviation Administration 48

Example Section of the Guidebook • 4. 4 Safety Planning (OBJ) The expectation of this section is that you describe your safety management plan to meet the objectives described by your above stated safety policy. (STD) - FAA Advisory Circular AC 120 -92 Appendix 1 4. 4. Safety Planning The organization shall establish and maintain a safety management plan to meet the safety objectives described in its safety policy. (DG) Management has historically been defined as planning, organizing, directing, and controlling. Therefore a Safety Management System will start with a plan to meet the Safety Objectives. A plan should be set by Top Management that will direct and sequence the implementation of the Safety Management System. Planning at one level becomes direction at the next level. The first thing to plan is how much and on what time table the various portions of the Safety Management System will be created, who will be responsible for the overall system and the various portions of it. SMSPP Phase 0 Federal Aviation Administration 49

Summary Audit/Gap Analysis Tool • High level assessment tool • To be utilized for initial screening or audit summary • Questions at the objective level • Evaluates the organization’s existing systems to determine conformance to the SMS standards SMSPP Phase 0 Federal Aviation Administration 50

Summary Audit/Gap Analysis Tool • Evaluate Objectives utilizing assessment scales • Measure the level of development for each objective 0 – No action 1 – Action initiated 2 – Implemented 3 – Integrated 4 – Evaluated and Sustained 5 – State of Art SMSPP Phase 0 Federal Aviation Administration 51

Summary Audit/Gap Analysis Tool No action = 0 Action initiated=1 Implemented=2 Integrated=3 Evaluated and Sustained=4 State of Art=5 SMSPP Phase 0 Federal Aviation Administration 52

Audit/Gap Analysis Tools • Detailed assessment of the organization’s existing systems to determine conformance to the SMS standards • Used to determine what needs to be developed • After implementation, to assess continued performance of the system • Final gap analysis prior to implementation planning must be based on the full set of tools to ensure that all of the standard's requirements are included in the system design SMSPP Phase 0 Federal Aviation Administration 53

Audit/Gap Analysis Tools System 8. 0 of the Air Transportation Oversight System (ATOS): • Includes the SMS pillars as subsystems 8. 1 Policy 8. 2 Safety Risk Management 8. 3 Safety Risk Assessment 8. 4 Safety Promotion • 13 Design Assessment Tools based on major sub-clauses of the Standard SMSPP Phase 0 Federal Aviation Administration 54

Audit/Gap Analysis Tools 8. 1. 1 8. 1. 2 8. 1. 3 8. 2. 1 8. 2. 2 8. 2. 3 8. 2. 4 8. 3. 1 8. 3. 2 8. 3. 3 8. 4. 1 8. 4. 2 Organizational Management Documentation and Records Management Emergency Preparedness and Response System and Task Analysis Hazard Identification Safety Risk Analysis and Assessment Safety Risk Controls Data Acquisition Data Analysis and System Assessment Corrective and Preventive Action Communication and Awareness Personnel Qualifications and Training SMSPP Phase 0 Federal Aviation Administration 55

Detailed Audit/Gap Analysis Tools • Utilizes ATOS SAI format • Has a stated functional objective - expectations and outcomes • Questions in the procedures section of each element are based on specific requirements in the standard • Requirements evaluated utilizing assessment scales and scales measure the level of conformance with each requirement 0 – No action 1 – Action initiated 2 – Implemented 3 – Integrated 4 – Evaluated and Sustained 5 – State of Art SMSPP Phase 0 Federal Aviation Administration 56

Example: Design Assessment Tool SMSPP Phase 0 Federal Aviation Administration 57

Example: Design Assessment Tool: Detail SMSPP Phase 0 Federal Aviation Administration 58

Standard and Audit/Gap Analysis Tools SMSPP Phase 0 Federal Aviation Administration 59

SMS Pilot Project • A set of confirmatory trials that consist of voluntary SMS development and interface with oversight systems • The purpose is to gather data to be used in further development of guidance material, implementation strategies, and oversight systems SMSPP Phase 0 Federal Aviation Administration 60

Industry & FAA SMS Implementation • Should follow a phased approach • The processes underlying the four pillars will be modularized • “Growth” or “increasing maturity” will then be emphasized for each process and the system as a whole SMSPP Phase 0 Federal Aviation Administration 61

SMS Implementation Process Continuous Improvement 4 3 2 1 0 SMSPP Phase 0 Proactive Processes Reactive Processes Planning & Organization Orientation & Commitment Federal Aviation Administration 62

Purpose and Methodology of SMS • Phased implementation: a logical process for building the SMS • Management capability: Each step in the model will increase and strengthen management capability • Process based upon • ICAO recommendations and • Capability Maturity Model (CMM) concepts SMSPP Phase 0 Federal Aviation Administration 63

Who’s Involved in Implementation? • The Operator • The Certificate Management Organization (CMO, FSDO, CHDO) • The Standardization and Assistance Team (SAT) SMSPP Phase 0 Federal Aviation Administration 64

Level Zero: Orientation and Commitment (Today) • Outreach presentations • Understanding what’s ahead • Establishing the relationship • Securing the commitment from top management SMSPP Phase 0 Federal Aviation Administration 65

Level 1: Planning & Organization Charting the Course • The Gap Analysis: Evaluating existing processes, programs, and practices for safety management • The Implementation Plan • Organizing for Implementation SMSPP Phase 0 Federal Aviation Administration 66

Level 1 - Meetings Session 1 • SAT to Brief: • SMS Process Map • SMS Objectives • Summary Audit/Gap Analysis Tool • Detailed Audit/Gap Analysis Tools • Jointly Perform Summary Gap Analysis • Schedule Operator’s Gap Analysis Out Brief • The operator may require 4 to 6 months to complete the detailed gap analysis. SAT and CMT will be available on call while the operator is performing this task. SMSPP Phase 0 Federal Aviation Administration 67

Level 1 - Meetings Session 2 • Operator to Brief: • • • Overview of their Gap Analysis Gaps found and how they may develop processes to close the gaps. Operator to Discuss Documentation • • Operator to Identify Resource and Training Needs • • • SAT may provide additional training if necessary as a result of this discussion. SAT to Brief on Planning Process Schedule for Operator’s SMS Implementation Plan Out Brief • • Operator to present objective evidence of conformity The operator may require 2 to 4 months to complete the detailed implementation plan development. Estimated time for this session is one day of presentation of gap analysis by the operator. Half to one day of SAT presentation and discussions of the planning processes. SMSPP Phase 0 Federal Aviation Administration 68

Level 1 - Meetings Session 3 • Operator’s Presentation of Implementation Plan • • Consensus on Plan • • Agreement on the implementation plan among operator, CMT and SAT Exit Level 1 • • Detailed presentation and discussion of their SMS implementation plan involving the operator, CMT and SAT Agreement among operator, CMT and SAT that the participant is ready to move the next phase of the pilot project. Estimated time for this session is one day of presentation by the operator. SMSPP Phase 0 Federal Aviation Administration 69

Level 1 – Completion Criteria • Identify and assign safety responsibilities to managers. 1. 1 Management commitment and responsibility (4. 2 B, 4. 5 A, 4. 5 B) 1. 2 Safety responsibilities of managers (4. 5 D, 4. 1) • Identify the person responsible for implementing the SMS. 1. 3 Appointment of key safety personnel (4. 5 C) • Describe the system. 1. 4 SMS implementation plan (4. 4, 4. 1) • Conduct a gap analysis of existing resources compared to SMS requirements. 1. 4 SMS implementation plan (4. 4) • Develop an SMS implementation plan. 1. 4 SMS implementation plan (4. 4) • Develop documentation relevant to safety policy and objectives. 1. 6 Documentation (4. 9) • Develop and establish means for safety communication. 4. 2 Safety communication (7. 2) • Communicate the SMS implementation to all employees. 4. 2 Safety communication (7. 2) • Develop an initial training plan for all employees. 4. 1 Training and education (7. 4) SMSPP Phase 0 Federal Aviation Administration 70

Level 1 Assessment Criteria The assessment will be accomplished using the Audit/Gap Analysis Tools below: • • 8. 1. 1. 8. 1. 2. 8. 4. 1. 8. 4. 2. Organizational Management Document and Records Management Communication and Awareness Personnel Qualification and Training All questions on these tools should achieve a score of at least 1, as defined on the next slide. All individual questions receiving less than a score of 1 will be reviewed by the Participant, the CMO and the SAT for creation of a mutually agreeable solution. SMSPP Phase 0 Federal Aviation Administration 71

Level 1 Assessment Scale SAI Assessment Scale Score Assessment Word Picture 0 No Action No action has been taken on this requirement of the standard. 1 Action Initiated Identifiable actions have been taken to satisfy this requirement of the standard. All responsibilities, processes and procedures are documented. However, the implementation of those defined actions is not complete. Example: 8. 1. 1 Section 2, Question 1. Does the operator have a control or controls in place to ensure that all SMS processes are documented, monitored, measured, and analyzed? To achieve a score of 1, the Participant must have policies and procedures defined and written on how the process will be monitored, measured analyzed, but does not have to have taken any actions to actually do the monitoring, measuring or analysis. SMSPP Phase 0 Federal Aviation Administration 72

Level 1 - Documents • • Management Commitment Letter Management responsibilities defined Safety Policy and Objectives Safety responsibilities for managers defined Results of Gap Analysis for the department/area under the Pilot Program SMS Implementation Plan for the entire organization All Employee Letter or equivalent advising employees of the SMS implementation SMS Training Plan for all employees SMSPP Phase 0 Federal Aviation Administration 73

Level 1 - Expectations • Development Partner – Sessions 1 • – Session 2 • • – Complete summary gap analysis Completed detailed gap analysis utilizing the detailed audit/gap analysis tools for Level 1 Brief gap analysis results Brief gaps and how they will be addressed Provide evidence of conformity Session 3 • • SMSPP Phase 0 Present implementation plan Complete the required documents Meet the requirements of the exit criteria for this phase Provide process inputs to the SAT Federal Aviation Administration 74

Level 1 - Expectations • Oversight Organization – Review and utilize (if desired) audit/gap analysis tools – Attend audit/gap analysis meetings with the operator – Participate in meetings with the SAT and operator – Review the operators implementation plan and other documents – Discuss the requirements of the exit criteria for this phase with the operator and SAT – Provide input to the SAT regarding the SMS implementation, documents and audit tools SMSPP Phase 0 Federal Aviation Administration 75

Level 1 - Expectations • SAT – All Levels – Provide assistance, as requested, to the Development Partner and its Oversight Organization throughout the Pilot Project period. – Participate in meetings with the CMT and operator, if requested – Review the operators implementation plan and other documents – Discuss the requirements of the exit criteria for this phase with the operator and CMT – Receive Pilot Project inputs from the Development Partner and Oversight Organization – Report on summarized data gathered from the Pilot Project SMSPP Phase 0 Federal Aviation Administration 76

Level 2: Reactive Processes Basic Risk Management • Setting up the information infrastructure and processes • Going after known problems: Reactive Hazard Identification • Designing and implementing risk controls • Documentation • Training • General initial training • Specialist training SMSPP Phase 0 Federal Aviation Administration 77

Level 2 – Completion Criteria • Implement safety risk management (SRM) for reactive processes. 2. 1 Hazard identification process (5. 2) 2. 2 Risk assessment and mitigation processes (5. 3, 5. 4, 5. 5) 2. 3 Internal safety investigations (6. 3. 5) • Perform training relevant to SMS implementation plan and SRM components. 4. 1 Training and education (7. 4) • Develop documentation relevant to SMS implementation plan and SRM components (reactive processes). 1. 4 SMS implementation plan (4. 4) 1. 6 Documentation (4. 9) • Initiate a non-punitive voluntary employee reporting system. (6. 3. 6, 4. 2 B 5) SMSPP Phase 0 Federal Aviation Administration 78

Level 2 - Documents • Processes and procedures for operating the SMS to the level of assessment and actions reactively • Voluntary employee reporting program SMSPP Phase 0 Federal Aviation Administration 79

Level 2 – Audit/Gap Analysis Tools • • • 8. 1. 2 Document and Records Management 8. 1. 3 Emergency Response 8. 2. 2 Hazard Identification 8. 2. 3 Risk Analysis and Assessment 8. 2. 4 Risk Control 8. 3. 1 Data Acquisition 8. 3. 2 Data Analysis/System Assessment 8. 3. 3 Preventive/Corrective Action 8. 4. 1 Communication and Awareness 8. 4. 2 Personnel Qualification and Training SMSPP Phase 0 Federal Aviation Administration 80

Level 3: Proactive Processes Looking Ahead • System and task analysis of the operational (production) systems • Proactive Hazard identification • Updating: • the risk controls • Updating the documentation • Additional specialist training SMSPP Phase 0 Federal Aviation Administration 81

Level 3 – Completion Criteria • Implement safety risk management for proactive and predictive processes. 2. 1 Hazard identification process (5. 2) 2. 2 Risk assessment and mitigation processes (5. 3, 5. 4, 5. 5) 2. 3 Internal safety investigations (6. 3. 5) • Perform training relevant to proactive and predictive processes. 4. 1 Training and education (7. 4) • Develop documentation relevant to proactive and predictive processes. 1. 4 SMS implementation plan (4. 4) 1. 6 Documentation (4. 9) • • • Perform a system and task analysis for one department (5. 1) Incorporate hazards from system and task analysis into SRM (5. 1 – 5. 5) Develop policies and procedures for safety assurance (6. 2) • • • SMSPP Phase 0 Information acquisition (6. 3) Analysis of data (6. 4) System assessment (6. 5) Preventive and corrective actions (6. 6) Management reviews (6. 7) Federal Aviation Administration 82

Level 3 - Documents • All processes and procedures for operating the SMS. • Safety assurance policy and procedures must be documented. SMSPP Phase 0 Federal Aviation Administration 83

Level 3 – Audit/Gap Analysis Tools • • • 8. 1. 2 Document and Records Management 8. 2. 1 System and Task Analysis 8. 2. 2 Hazard Identification 8. 2. 3 Risk Analysis and Assessment 8. 2. 4 Risk Control 8. 3. 1 Data Acquisition 8. 3. 2 Data Analysis/System Assessment 8. 3. 3 Preventive/Corrective Action 8. 4. 1 Communication and Awareness 8. 4. 2 Personnel Qualification and Training SMSPP Phase 0 Federal Aviation Administration 84

Level 4: Continuous Improvement Continued Assurance • Mature safety assurance process • Analysis of data • System performance assessment • Corrective/Preventive action: Maintaining the controls • Identifying new and emerging hazards • Management Reviews: Formal involvement • Documentation & Training as required SMSPP Phase 0 Federal Aviation Administration 85

Level 4: Continuous Improvement • This is the final stage of maturity of the SMS • Continuous improvement is based on: • Continuous risk management, and • Continuous safety assurance SMSPP Phase 0 Federal Aviation Administration 86

Level 4 – Completion Criteria • Implement an operational safety assurance program (6. x) 3. 1 Safety performance monitoring and measurement (6. 3. 1 - 6. 3. 3) 3. 2 The management of change (5 B 4, 5 E) 3. 3 Continuous improvement of the safety system (6. 8, 4. 2 B 2) • Develop acceptable level(s) of safety (4. 7) • Develop safety indicators and targets (4. 7) • Perform training relevant to operational safety assurance. 4. 1 Training and education (7. 4) • Develop documentation relevant to operational safety assurance. 1. 6 Documentation (4. 9) SMSPP Phase 0 Federal Aviation Administration 87

Level 4 - Documents All SMS program documents that have been previously developed should be reviewed to ensure that any changes, amendments or maturity in the processes or procedures have been appropriately documented. SMSPP Phase 0 Federal Aviation Administration 88

Level 4 – Audit/Gap Analysis Tools • • • 8. 1. 1 Organizational Management 8. 1. 2 Document and Records Management 8. 3. 1 Data Acquisition 8. 3. 2 Data Analysis/System Assessment 8. 4. 2 Personnel Qualification and Training SMSPP Phase 0 Federal Aviation Administration 89

Interfaces and Integration • Regulatory Oversight • ATOS • Safety Assurance • CASS • IEP • Employee Reporting • ASRS • ASAP • Compliance and Enforcement: Interfaces • VDRP • EDT SMSPP Phase 0 Federal Aviation Administration 90

Voluntary Implementation of SMS • Advisory Circular has been Drafted • Process Based on AC 120 -92 • Interim Solution while rulemaking is ongoing • Award System • Bronze: Maturity Level 2: Risk Management Program • Silver: Maturity level 3: SMS (provisional) • Gold: Maturity Level 4: SMSPP Phase 0 Federal Aviation Administration 91

Draft AC 120 -XX Contents • Description of Levels • Implementation Process • Gap Analysis Tool • Functional Objectives • Maturity Rating • Cross Reference to Detail Design Assessment Tools • Cross Reference to ICAO Framework SMSPP Phase 0 Federal Aviation Administration 92

SMS Pilot Projects 4 Phase 2: Experience 1 0 SMSPP Phase 0 Proactive Processes 3 2 Reactive Processes Planning & Organization Orientation & Commitment Continuous Improvement Phase 1: Readiness Federal Aviation Administration 93

Summary • Phased implementation of SMS Ø Four levels plus a “zero” level Ø Approximate three-year estimated time to complete • Integration of existing programs encouraged • SMS Pilot Projects underway to refine: Ø Oversight practices and interfaces Ø Implementation strategies • SMS gap analysis and system assessment tools provided • Additional guidance and advisory material being developed SMSPP Phase 0 Federal Aviation Administration 94

Are we done yet? • Aviation systems are open systems that operate in a dynamic rapidly changing environment • Safety management is, therefore, never “done” • Continuous improvement is based on continuous risk management and assurance SMSPP Phase 0 Federal Aviation Administration 95

CONTACT INFORMATION Dr. Donald N. Arendt, Manager Federal Aviation Administration AFS-940 Suite 131 45005 Aviation Drive Dulles, VA 20166 -7537 (703) 661 -0516 Don. Arendt@faa. gov Keith D. De. Berry FAA, AFS-940 Suite 131 45005 Aviation Drive Dulles, VA 20166 -7537 (571) 423 -8720 Keith. D. De. Berry@faa. gov Bill Jarrott Lead System Engineer The MITRE Corporation 7515 Colshire Drive Mc. Lean, VA 22102 -7539 (703) 983 -1842 bjarrott@mitre. org http: //www. mitrecaasd. org/SMS/documents. html SMSPP Phase 0 Federal Aviation Administration 96

OPEN DISCUSSION SMSPP Phase 0 Federal Aviation Administration 97