Appendix B B-6 Figure B-5. Risk Analysis and Assessment Summary Note: Refer to §§ 5.23(b) and 5.55(b).
Acceptance Authority (Sign Here and Initial Appropriate Columns):
Pre-Control Accept? Post-Control Accept?
Hazard Potential Consequences Severity Likelihood Severity Likelihood H1 H2 H3 H4 H5 H6 H7 H8 H9 H10
Appendix B B-7 Figure B-6. Risk Control Note: Refer to § 5.55(c) and (d).
System/Project:
Responsible Manager/Process Owner:
Hazard Control Substitute Risk Residual Risk H1 H2 H3 H4 H5 H6 H7 H8 H9 H10
Appendix B B-8 Figure B-7. Risk Control Documentation Note: Refer to part 5 subpart F.
System/Project:
Hazard Procedure Documentation H1 H2 H3 H4 H5 H6 H7 H8 H9 H10
Appendix C C-1 APPENDIX C. GUIDANCE FOR DEVELOPING A SAFETY POLICY AND CODE OF
ETHICS STATEMENT C.1 Safety Policy Statement.
C.1.1 Many aviation organizations have developed a safety policy statement. The safety policy must contain the requirements in 14 CFR part 5, § 5.21 and be signed by the accountable executive (§§ 5.21(b) and 5.25(b)(2)). It could make sense to combine the code of ethics and a safety policy statement into a single document. References (“pointers”) to other manuals or documentation that provide guidance on how each requirement is met should be embedded in the safety policy statement. For example, the requirement for an emergency response plan (ERP) could be met by referring to a separate document or an appendix in a Repair Station Manual (RSM) or General Operations Manual (GOM). By pointing to where the information is located, it makes it easier for employees to find that material. A secondary benefit is it prevents duplication of documentation. It is important to remember the safety policy is unique to the aviation organization and should be developed to meet the unique and specific needs, operating profile, and structure of the aviation organization.
C.1.2 P art 5 list s the specific documentation requirements that must be included in the completed safety policy (§ 5.95). A safety policy statement is a document that states what the organization will do and how employees are expected to act. The SMS processes and procedures define actions employees will take to meet the safety policy requirements and measurable objectives (i.e., how they are to perform their SMS duties and responsibilities). A safety policy statement (if developed as a separate document) and safety policy processes and procedures are necessary when developing and maintaining an SMS for completeness.
C.2 C ode of Ethics.
C.2.1 Aviation organizations are required to develop a code of ethics for all employees, including management personnel and officers. The safety policy must include a code of ethics that specifies that safety is the organization’s highest priority and applies to all employees, including management personnel and officers. This requirement is in § 5.21(a)(7). A code of ethics defines the aviation organization’s standards of conduct that employees are expected to uphold. The code of ethics should be a concise statement that outlines values the aviation organization holds and maintains in the course of business. A code of ethics is a very high-level statement that gives employees at all levels of the organization a general idea of what types of behavior and decisions are acceptable and expected in the conduct of business. A code of ethics may be combined with a safety policy statement at the discretion of the aviation organization.
C.2.2 A safety policy and code of ethics statement should not be confused with the requirements of § 5.95, which requires aviation organizations to document their safety policy. All that needs to be documented in the safety policy and code of ethics statement is the aviation organization’s expectations.
Appendix C C-2 C.3 Sample Statement. Figure C-1 is a sample safety policy and code of ethics statement.
Figure C-1. Sample Safety Policy and Code of Ethics Statement The Executive Management of [aviation organization’s name] recognizes that an effective Safety Management System (SMS) is vital to the success and longevity of the company. Therefore, the Executive Management is committed to maintaining a fully functional SMS and to the continuous improvement of safety throughout [aviation organization’s name]. This Safety Policy and Code of Ethics Statement applies to all employees in [aviation organization’s name] from the organization’s executive officers to line employees.
[Aviation organization’s name] believes the highest priority of our organization is ensuring the safety of our employees and customers. Every effort has been given to ensure this is always first and foremost in everything we do.
The Executive Management of [aviation organization’s name] has established specific safety-related objectives and periodically publishes and distributes to all employees those objectives and plans.
Specific objectives are located in the [state location of objectives] for regular employee review.
These safety objectives are monitored, measured, and tracked to ensure overall corporate safety objectives are met. All employees and individuals in the company have the responsibility to perform their duties and activities in the safest practical manner.
[Aviation organization’s name] Accountable Executive is committed to providing the necessary financial, personnel, and other resources to maintain a fully functional SMS.
[Aviation organization’s name] Executive Management recognizes that open communication is critical to our success and is dedicated to maintaining a confidential employee reporting system for reporting all hazards, accidents, incidents, and safety issues without fear of reprisal. [Aviation organization’s name] encourages all employees to provide suggestions on how to improve processes and procedures as well as how to reduce workplace hazards they encounter during the course of their duties. Specific reporting procedures are located in the [state location of procedures].
Activities involving intentional disregard for FAA regulations and company policies and procedures, illegal activities, and/or drugs or alcohol may be subject to disciplinary action. [State location of unacceptable behaviors and disciplinary actions].
As a component of the SMS, [aviation organization’s name] Executive Management is committed to maintaining and periodically exercising an emergency response plan that provides for the safe transition from normal to emergency operations. [State location of emergency response plan].
[Aviation organization’s name] Executive Management will convey this expectation to all employees through postings, the intranet site, the company newsletter, and any other means to ensure all employees are aware of the company’s SMS, their duties and responsibilities, and our safety policy.
This Safety Policy and Code of Ethics Statement will be periodically reviewed by Executive Management to ensure it remains relevant and appropriate to the company.
[Signed], Accountable Executive [Additional management personnel optional]
Appendix D D-1 APPENDIX D. GUIDANCE FOR DEVELOPING A COMPLIANCE STATEMENT D.1 Compliance Statement. The purpose of a compliance statement is to ensure aviation organizations adequately address the applicable sections of 14 CFR part 5 during the development and implementation of an SMS. The compliance statement must list all part 5 sections and subsections that apply to the aviation organization’s operation. Next to each part 5 requirement (section and subsection), the applicant/aviation organization must provide a specific reference to a manual or other document, if required, and may provide a brief narrative description that describes how they will comply with each section or subsection. This statement also serves as a master index to the aviation organization’s documentation system to expedite the FAA’s oversight of the SMS. Aviation organizations are encouraged to maintain and routinely update their compliance statement, which is a living document, as changes are made to their SMS.
D.2 How to Prepare a Compliance Statement.8 Preparation of the compliance statement benefits the aviation organization by systematically ensuring all applicable regulatory aspects are appropriately addressed during the SMS acceptance and oversight process. It can also serve as a master index to the aviation organization’s system documentation.
8 Refer to AC 120-49, Parts 121 and 135 Certification.
D.2.1 To develop a compliance statement:
1. List all applicable sections contained in part 5.
2. Next to each subparagraph, provide a specific reference to a manual or other document where the method of compliance is documented. Aviation organizations not required to maintain a manual system are encouraged to provide a brief narrative description of how compliance with each regulation will be met; however, this description is not required.
3. The location of each reference should be as specific as possible and should contain the name of the manual, chapter, section, and paragraph number(s). Using manual page numbers in a compliance statement may produce inaccurate reference locations due to repagination problems. There may be multiple references for one requirement found within one manual, or there may be multiple reference locations found in several different manuals. It is not acceptable to enter references such as “ABC Airlines will comply with this requirement,” “ABC Airlines understands this regulation and will comply,” or “Noted.”
4. The compliance statement is an important document during certification and the SMS oversight process. After the SMS is determined to be acceptable to the Administrator, the compliance statement should be kept current in the aviation organization/applicant’s system.
D.2.2 The following tables are examples of formats that may be used to present the list of specific requirements and subparts, including all subparagraphs.
Appendix D D-2 Table D-1. Sample Compliance Statement for Aviation Organizations That Are Required to Maintain a Manual System Section/ Subsection Text Reference § 5.21(a)
(a) Any person required to have an SMS under this part must have a safety policy that includes at least the following:
§ 5.21(a)(1) (1) The person’s safety objectives. Repair Station Manual (RSM), paragraph 2-37 § 5.21(a)(2) (2) The person’s commitment to fulfill the safety objectives. RSM introductory message § 5.21(a)(3)
(3) A clear statement about the provision of the necessary resources for the implementation of the SMS.
RSM introductory message § 5.21(a)(4)
(4) A safety reporting policy that defines requirements for employee reporting of safety hazards or issues.
RSM, paragraph 241;
Training Manual, Chapter 7 § 5.21(a)(5) (5) A policy that defines unacceptable behavior and conditions for disciplinary action. Human Resources Manual, Chapter 3, paragraph 3-17 § 5.21(a)(6)
(6) An emergency response plan that provides for the safe transition from normal to emergency operations in accordance with the requirements of § 5.27.
Emergency Response Manual § 5.21(a)(7)
(7) A code of ethics that is applicable to all employees, including management personnel and officers, which clarifies that safety is the organization’s highest priority.
Employee Handbook and displayed in workplace
Appendix D D-3 Table D-2. Sample Compliance Statement for Aviation Organizations That Are Not Required to Maintain a Manual System Section/ Subsection Text Sample Verbiage § 5.21(a)
(a) Any person required to have an SMS under this part must have a safety policy that includes at least the following:
§ 5.21(a)(1)
(1) The person’s safety objectives. Our safety objectives are located in our company compliance statement and are updated annually or as required.
§ 5.21(a)(2)
(2) The person’s commitment to fulfill the safety objectives.
We will always operate at the highest levels to ensure the safety of our personnel and passengers.
§ 5.21(a)(3)
(3) A clear statement about the provision of the necessary resources for the implementation of the SMS.
We will ensure that resources are provided to ensure aircraft maintenance and pilot training are always maintained and in accordance with current regulations.
§ 5.21(a)(4)
(4) A safety reporting policy that defines requirements for employee reporting of safety hazards or issues.
We participate in the Community Aviation Safety Action Program (ASAP) and will report hazards and issues through their web portal.
§ 5.21(a)(5)
(5) A policy that defines unacceptable behavior and conditions for disciplinary action.
Drug and alcohol abuse are strictly forbidden in this company. Violations of this will result in termination.
§ 5.21(a)(6)
(6) An emergency response plan that provides for the safe transition from normal to emergency operations in accordance with the requirements of § 5.27.
We will provide a copy of the flight dispatch log in case of emergency so the route of flight will be known to emergency services.
§ 5.21(a)(7)
(7) A code of ethics that is applicable to all employees, including management personnel and officers, which clarifies that safety is the organization’s highest priority.
We have our code of ethics statement posted in the workplace.
Appendix E E-1 APPENDIX E. IDENTIFYING THE ACCOUNTABLE EXECUTIVE E.1 To assist aviation organizations with selection of the accountable executive, Figure E-1, Accountable Executive Decision Process, and Figure E-2, Verifying the Accountable Executive, provide flowcharts with a series of questions. Figure E-1 identifies different organizational structures and how those structures may determine the accountable executive. These flowcharts cannot address all possible organizational structures. Any questions concerning the selection of the accountable executive should be addressed to the responsible Flight Standards office.
E.2 O nce the accountable executive is identified (see Figure E -1), the questions in Figure E-2 will assist in verifying that the individual in the selected position is the correct choice. All questions must receive a “yes” answer as they are validating the requirements of 14 CFR part 5, § 5.25(a). Should any of the quest ions result in a “no” answer, the selection process should be initiated again with the new candidate.
Appendix E Figure E-1. Accountable Executive Decision Process Start Accountable Executive Is the proprietorship? organization a sole YES Proprietor is the Accountable Executive. Confirm selection by answering the questions in Figure E-2.
Proprietor is the Accountable Executive.
Nominate a Confirm selection by Is the organization a partner as answering the partnership between YES Accountable questions in individuals? Executive. Figure E-2.
Nominated partner is the Accountable Executive NO Has the Board Confirm selection Is the organization appointed a CEO or Board of Directors? controlled by a YES equivalent to manage the organization? YES by answering the questions in Figure E-2.
CEO is the Accountable Executive Chairman of the Board is the Accountable Executive What corporate position has the authority and the ultimate Who in the responsibility to expend corporate organization holds resources for aviation-related this position?
activities?
Confirm selection made, re-evaluate organization If a clear selection cannot be by answering the questions in YES Identified individual is the Accountable Executive.
and begin process again.
Figure E-2 E-2
Appendix E Figure E-2. Verifying the Accountable Executive Start Identify individual Select an other by name. candidate.
Does the individual have § 5.25(a)(1) final authority over the service provider's operations?
Does the individual control § 5.25(a)(2) the financial resources for the NO aviation organization's operation?
Does the individual control § 5.25(a)(3) the human resources for the aviation organization's operation?
Does the individual retain the the safety performance of the ultimate responsibility for NO § 5.25(a)(4) aviation organization's operations?
YES This individual is the Accountable Executive.
E-3
Appendix F F-1 APPENDIX F. SAFETY ATTRIBUTES F.1 Safety Attributes. Safety attributes represent the core characteristics of any system that should be integrated into all processes and procedures. All aviation organizations use technical processes and procedures to provide their aviation product or service. However, some FAA regulations do not require certain operations to have manuals or documentation defining how they will operate. Even a “single-individual shop” follows an assortment of processes that may be undocumented to ensure the continued viability of the business. The extent to which the processes and procedures are described in writing is not as important as how effective they are in practice. As the complexity of an operation increases, the need for written procedures increases to ensure clear communication of organizational policies and priorities as well as a consistent and fair application of rules.
Aviation organizations communicate these processes to their personnel in various ways
(e.g., training curricula, employee briefings, new-hire discussions, etc.). Required records are generated using these organizationally developed processes. Processes scale the regulations to the scope and complexity of the operation. Processes also provide the balance between the economic and safety objectives of the organization.
F.1.1 For aviation organizations with an SMS, it is easy to assign specific “SMS requirements” to the related process attributes. That can be done because SMS required activities are just extensions of certain safety attributes. Therefore, by understanding the safety attributes, there will be a better understanding of SMS concepts. It is important to note these are safety attributes, and they will not fully evaluate an SMS.
F.1.2 Effective processes and procedures include provisions for the systematic identification, evaluation, and prevention or control of specific job hazards and potential hazards that may arise from foreseeable conditions.
F.1.3 Although compliance with FAA regulations is an important objective, effective processes and procedures look beyond the requirements of the regulations to address all hazards.
Aviation organizations should seek to prevent aviation-related injuries and illnesses whether or not compliance is at issue.
F.1.4 The key to compliance with FAA regulations lies in the reliability of the aviation organization’s processes.
F.1.5 One way to determine the effectiveness of an aviation organization’s processes is by looking for attributes that are embedded within good processes and procedures. Once the attributes are understood, these questions are relatively easy to apply. These common questions apply to those organizations that have an SMS as well as to aviation organizations that do not have an SMS.
F.1.6 Every process includes certain characteristics that support ongoing reliability over time.
That means every procedure and the associated processes should have these characteristics integrated into the process design and be updated when processes begin to fail due to changes in the organization’s operational environment.