2-5. SAFETY ASSURANCE.
a. Safety Performance Monitoring and Measurement § 5 .71 Safety performance monitoring and measurement .
(a) T he certificate holder must develop and maintain processes and systems to acquire data with r espect to its operations, products, and services to monitor the safety performance of the or ganization. These processes and systems must include, at a minimum, the following:
(1) Mo nitoring of operational processes.
(2) Mo nitoring of the operational environment to detect changes.
(3) A uditing of operational processes and systems.
(4) E valuations of the SMS and operational processes and systems.
(5) I nvestigations of incidents and accidents.
(6) Investigations of reports regarding potential non-compliance with regulatory standards or other safety risk controls established by the certificate holder through the safety risk management process established in subpart C of this part.
(7) A confidential employee reporting system in which employees can report hazards, issues, concerns, occurrences, incidents, as well as propose solutions and safety improvements.
(b) T he certificate holder must develop and maintain processes that analyze the data acquir ed t hrough the processes and systems identified under paragraph (a) of this section and any other r elevant data with respect to its operations, products, and services.
Discussion: Safety performance monitoring focuses on the following data acquisition processes:
Monitoring of Operational Processes; Monitoring of the Operational Environment; Auditing of Operational Processes; Evaluation of the SMS and Operational Processes; Incidents and Accidents Investigations; Potential Noncompliance Investigations; and Confidential Employee Reporting System. Examples include, but not limited to;
• Monitoring. To observe the day-to-day, process-by-process, job-by-job performance of operational systems and their associated risk controls, to include reviewing data collected for operational purposes to look for anything of safety significance, and new or changed conditions.
• Auditing. To provide the process owners with a means to obtain information about the performance of systems in their area of responsibility.
• Evaluation. To provide a source of information to the organization regarding the safety performance of operational systems and the SMS.
• Investigation of Incidents and Accidents. To gather information on accidents and incidents to identify potential weaknesses in operational systems.
• Investigation of Potential Noncompliance. To obtain information to determine compliance with regulations, as well as underlying policies and procedures.
• Confidential Employee Reporting System. To provide a means for employees to communicate safety information to management.
S afety performance measurement focuses on the analysis of the data collected during the monitoring stage with the goal being to organize and examine the data to determine its meaningfulness in making safety dec isions. Analysis involves examining data acquired from various sources in order to make inferences about the safety performance of operational systems and the SMS.
b. Safety Performance Assessment.
§ 5 .73 Safety performance assessment .
(a) T he certificate holder must conduct assessments of its safety performance against its safety objectives, w hich include reviews by the accountable executive,to:
(1) E nsure compliance with the safety risk controls established by the certificate holder;
(2) E valuate the performance of the SMS.
(3) E valuate the effectiveness of the safety risk controls established under § 5.55(c) and identify any i neffective controls.
(4) I dentify changes in the operational environment that may introduce new hazards.
(5) I dentify new hazards.
(b) U pon completion of the assessment, if ineffective controls or new hazards are identified under pa ragraph (a)(2) through (a)(5) of this section, the certificate holder must use the safety risk m anagement process described in subpart C of thispart.
Discussion. Safety performance assessments are accomplished to make decisions regarding safety performance with reference to safety objectives and regulatory compliance. Safety performance data is analyzed, and the results are used for informed decision making. The assessment process is where these decisions are made. Decisions are made by personnel with assigned responsibility and authority. The SA process should consider who makes the decisions regarding whether the company’s safety performance is effective, and whether the company is meeting its safety objectives and expectations that are identified in the safety policy. Examples of “generalized outcomes” of an assessment include, but are not limited to:
• Performance is acceptable and objectives are being met.
• Performance is not acceptable, and analysis suggests the problem lies with conformity with regulations or company policy and procedures, or necessary resources have not been provided. In the event this occurs, corrective action would be warranted.
• Conformity with the risk controls and regulations appears to be satisfactory; however, desired results are not being obtained. In the event that this occurs, the SRM processes would be triggered.
• New or uncontrolled hazards are discovered. This may be due to new hazards having arisen since the system was designed, or discovery of factors that were overlooked. In this case, as in the previous, the SRM processes should be followed.
The conclusions of the safety assessments are reported to the accountable executive, who possesses ultimate authority to act on such conclusions, as necessary.
Discussion. Safety Promotion provides employees with effective SMS training commensurate with their safety responsibilities, and creates a means to deliver organization-wide safety communication. It is imperative to assure that employees attain and maintain the competencies necessary to perform their assigned duties relevant to the operation and performance of the SMS.
“Competency” is an observable, measurable set of skills, knowledge, abilities, behaviors, and other characteristics that individuals exhibit as they successfully perform work functions. For example, a Safety Risk and Data Analyst will probably need more detailed SMS training (such as safety risk analysis, system evaluation, system assessment, data mining, auditing, and inspections) than will a package handler. Line managers may need to know more about the potential consequences of safety failures and system failure modes than line employees. Line employees may only need an overview of safety management fundamentals for their operational department (e.g., instructions on how to identify and report safety concerns). It is the responsibility of your organization to determine and communicate its own training needs based on competency requirements.
b. Safety Communication.
§ 5.93 Safety communication.
T he certificate holder must develop and maintain means for communicating safety information that, at a minimum:
(a) E nsures employees are aware of the SMS policies, processes, and tools relevant to their r esponsibilities.
(b) C onveys hazard information relevant to the employee’s responsibilities.
(c) E xplains why safety actions have been taken.
(d) E xplains why safety procedures are introduced or changed.
Discussion. It is important for organizations to ensure that employees have current and pertinent safety information. Effective communication involves adjusting the content of the communication and manner in which the information is delivered to match the target employee’s role in the Discussion. This process provides the organization’s decision makers with a means to correct safety performance deficiencies identified in the safety performance assessment process. It is designed to facilitate an organization to continuously improve safety performance.
2-6. SUBPART E: SAFETY PROMOTION.
a. Competencies and Training.
08/04/23 AC 120-119
c. Continuous Improvement.
§ 5.75 Continuous improvement.
T he certificate holder must establish and implement processes to correct safety performance deficiencies identified in the assessments conducted under § 5.73.
§ 5.91 Competencies and training.
T he certificate holder must provide training to each individual identified in § 5.23 to ensure the individuals attain and maintain the competencies necessary to perform their duties relevant to the operation and performance of the SMS.
organization. The accountable executive should ensure communication mechanisms are available and are effectively utilized. The delivery system should be appropriate according to the size and complexity of the organization. Safety policy and information could be provided as text; visual media, such as posters or short videos; orally; or through examples. Messages should be consistent and in a form that employees at each level can relate to, and be delivered using whichever media the organization has available. For example, hazard communications regarding risks to aviation and the hazards some products and materials can pose may be in the form of posters, videos, and demonstrations.
2-7. SMS DOCUMENTATION AND RECORDKEEPING.
a. SMS Documentation.
Discussion. It is expected that organizations adopting an SMS establish and maintain SMS information, in either paper or electronic form, describing the safety-related processes and procedures, and interfaces between these. Additionally, organizations should also implement a distribution system to ensure that the documents dealing with these processes and procedures are promptly updated whenever there is a change in one or more of these processes or procedures.
b. SMS Records.
§ 5 .95 SMS documentatio n.
T he certificate holder must develop and maintain SMS documentation that describes the certificate holder’s:
(a) S afety policy.
(b) S MS processes and procedures.
§ 5 .97 SMS records .
(a) T he certificate holder must maintain records of outputs of safety risk management processes a s described in subpart C of this part. Such records must be retained for as long as the control r emains relevant to the operation.
(b) T he certificate holder must maintain records of outputs of safety assurance processes as de scribed in subpart D of this part. Such records must be retained for a minimum of5 years.
(c) T he certificate holder must maintain a record of all training provided under § 5.91 for each i ndividual. Such records must be retained for as long as the individual is employed by the certificate hol der.
(d) T he certificate holder must retain records of all communications provided under § 5.93 for a m inimum of 24 consecutive calendar-months.
Discussion. The timeline associated with the retention of the documents for outputs of SRM processes would be for as long as they remain relevant to the operation. For risk assessments, this may mean for as long as the organization engages in the activity for which the risk assessment was conducted. For risk controls, it may mean for as long as the risk control remains in effect. The intent to maintain records of outputs, training, and communications does not in itself create any requirement to submit those records to the FAA. However, these records should be made available to the FAA to assist organizations in implementing their voluntary SMS program and to ensure appropriate oversight of the voluntary SMS. Additionally, the recordkeeping component of a voluntary SMS program is not intended to require an organization to retroactively maintain or recreate records of activity before its SMS implementation. Rather, the retention of documents refers to SMS records that apply during and after SMS implementation.
CH APTER 3. SMS IMPLEMENTATION PROCESS
3-1. Introduction. As stated in Chapter 2, to initiate the process of implementing a voluntary SMS within your organization and ultimately gaining FAA acceptance of the SMS, your organization would develop and submit an SMS implementation plan to the FAA Office of Hazardous Materials Safety. The paragraphs below outline an acceptable means, but not the only means, of developing an implementation plan.
3-2. Developing an SMS Implementation Plan. An implementation plan is a document that outlines the steps the organization plans to take to ensure that it has an SMS that the FAA would accept. The implementation plan does not need to be complex or excessively detailed, but should provide a basic roadmap (e.g., tasks/milestones/resource assignment) for the organization to meet the SMS principles outlined in this AC. The first step in developing an SMS is mapping out and analyzing your organization and its operational environment. More importantly, the plan includes a brief description explaining how your organization already complies with each specified SMS principle and/or how you plan to comply with each principle.
a. Gap Analysis. To build an implementation plan, you need to understand your current state of compliance with the SMS principles, as well as programs you may already have that could be used to satisfy the SMS requirements. A gap analysis involves analyzing and assessing your existing programs, systems, processes, and activities with respect to voluntary SMS requirements.
Your organization may use any technique to identify what needs to be done to implement an SMS.
If you choose to use a gap analysis, the completed gap analysis will provide input for development of your implementation plan.
b. Organizational Processes. Most organizations have many of the elements of an SMS in their current operational processes, although those processes may not entirely fulfill the requirements of the principles (e.g., they may be limited in scope (do not cover the entire organization) and interoperability (do not interface sufficiently to form a “system”)). If you determine that a process in your organization satisfies an SMS requirement, your gap analysis should document how that process meets the requirements. This may be accomplished by referencing the process or procedure in your system where the requirement is discussed.
3-3. Organizational SMS Implementation Plan Submissions and FAA Acceptance.
a. SMS Implementation Plan Submission. An organization should submit its implementation plan using the contact information specified in Chapter 1, paragraph 1-7. Upon the FAA receiving the implementation plan, the FAA will review it and notify the organization of its acceptance. Notification should be in the form of electronic correspondence, specifically via the contact information specified in Chapter 1, paragraph 1-7.
b. FAA and Organization Collaboration. The FAA Office of Hazardous Materials Safety encourages continual collaboration with organizations actively implementing accepted plans.
Periodic consultations between the FAA and organizations during the process are encouraged to ensure organizations are successful in fully implementing their voluntary SMS.
c. FAA Acceptance of an Implemented Voluntary SMS. The organization implements its voluntary SMS when all SMS process documentation (e.g., implementation plan, policies) are complete and published; all process personnel are available and trained; and all hardware/software is available and in the location of its intended use. Upon the FAA reviewing the organization’s completion of the implementation, the FAA will validate whether the voluntary SMS is consistent with the principles outlined in this AC. Upon successful validation, the FAA will notify the 17
o rganization of its acceptance as possessing an implemented voluntary SMS. Notification will be in the form of electronic correspondence, specifically via the contact information specified in Chapter 1, paragraph 1-7.