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.
Appendix F F-2 F.2 Safety Attribute Application. The following is a discussion of the safety attributes.
There are seven safety attributes, and this discussion will start with those that are directly associated with the aviation organization’s employee groups. These are referred to as personnel-related attributes. They consist of responsibility, authority, and safety ownership. There are four safety attributes that are related to the technical processes.
These are referred to as process-related attributes. These consist of controls, procedures, interfaces, and process measurement.
F.2.1 These attributes can be further broken down into four categories based on their characteristics. These are:
1. Employee roles and responsibilities. These are responsibility, authority, and safety ownership. They are the same as the personnel-related attributes.
2. The design and application of system processes. These are controls and procedures attributes.
3. Internal and external supplier impacts on the system. This addresses the interfaces attribute.
4. System performance and monitoring. This is where the process measurement attribute is addressed.
F.2.2 By organizing the safety attributes by their characteristics, this may improve understanding of how the foundations of system safety rely on both human and technical process areas to improve safety in all processes and procedures.
F.3 Responsibility Attribute. The responsibility attribute is defined as “A clearly identified individual who is accountable for ensuring financial and human resources to ensure the safety and quality performance of the certificate holder.” (Refer to Order 8900.1, Volume 10, Chapter 1, Section 4.) This attribute looks for “resource availability” that executive management allocates to support the aviation product or service. This could be adequate personnel and budgeting for facilities, parts, tooling, and any other resources required to ensure the success of the aviation organization. In aviation organizations with an SMS, this attribute is focused on the accountable executive and how they are ensuring the overall operational success of the aviation organization. In a non-SMS aviation organization, the responsibility attribute would be looking at the president, Chief Executive Officer (CEO), or owner or the individual ultimately responsible for the safe operations of the aviation activity.
F.3.1 In larger organizations, executive management o r business-tier managers are typically not technical process managers. Executive management (e.g., CEOs, Chief Financial Officers (CFO), Board of Directors (BOD), etc.) control the financial resources of the organization. The FAA’s position is that technical managers cannot maintain reliable technical processes unless executive management provides the human and financial support to do so. Once sufficient resources are distributed to the technical managers, they must appropriately apply those resources in a manner that supports the safety objectives of the aviation organization. In a less complex organization, the same individual could “wear multiple hats.” In these organizations, it is important to only look at the attribute
Appendix F F-3 being evaluated and only consider the position being evaluated. As the individual’s active duties change, the attribute being evaluated will also change. This is very common in a single-individual organization.
F.4 Authority Attribute. As mentioned above, the authority attribute seeks to determine if technical-level managers are managing process risk. The authority attribute is defined as “A clearly identifiable, qualified, and knowledgeable individual who effectively plans, directs, and controls resources; changes procedures; and makes key determinations including safety risk acceptance decisions.” (Refer to Order 8900.1, Volume 10, Chapter 1, Section 4.)
F.4.1 Technical-level management constitutes required regulatory personnel, managers, and all assigned process owners (e.g., lead engineer, fleet coordinator, or other authoritative positions without a manager title on the organizational chart) who “manage” specific technical functions. The description of these positions has been simplified by referring to them as “process owners.” Process owners speak with authority on behalf of the aviation organization in their process areas and may set additional workforce expectations not documented in FAA-approved or FAA-accepted manuals.
F.4.2 Process owners are responsible for properly utilizing resources provided to them, for accepting risk within their process area, and for changing processes or procedures as operations change.
F.5 Safety Ownership Attribute. This process characteristic is considered a key indicator of safety performance as it relates to an employee’s understanding of their contribution to the aviation organization’s safety goals and objectives. The safety ownership attribute helps determine whether an aviation organization is proactively ensuring employees understand how their day-to-day work activities support safety objectives in the workplace.
F.5.1 The safety ownership attribute is defined as “An individual’s understanding of how their role contributes to the overall safety of the organization.” (Refer to Order 8900.1, Volume 10, Chapter 1, Section 4.) Over time, data collected concerning this attribute may aid in determining the safety culture of an organization. A declining safety culture could be considered an indicator of risk.
F.5.2 Safety in the workplace includes everyone, whether a direct hire employee or contract aviation organization that supports the aviation product or service.
F.5.3 Safety ownership provides some insight as to the aviation organization’s proactive pursuit of a positive safety culture. It is well known that organizational culture directly affects the organization’s outcomes. The presumption is that employees who can explain or demonstrate their role in supporting safety initiatives in their daily work activities actually do participate in those safety efforts. Those employees who cannot explain their job-related safety contributions may not be participating to the extent they could be. For an aviation organization to leverage the eyes and ears of all its employees in identifying hazards and disposing safety concerns, action should be taken to solicit and encourage
Appendix F F-4 that support. Employee training events, supervisor reinforcement of safety objectives at regular meetings, safety discussions during employee performance evaluations, safety policy documentation in employee manuals, safety articles in organization newsletters, and providing positive feedback to employees who participate in hazard identification and reporting are a few ways that can be used to meet safety goals and objectives.
F.6 Controls Attribute. The controls attribute aids in determining if integrated controls are mitigating systemic risks as intended by the process design. Subactivities are those individual processes that could stand alone but are connected together to make a larger procedure. The controls attribute is defined as “The checks and restraints that exist within a process that ensure the potential effects of risks are reduced to an acceptable level.”
(Refer to Order 8900.1, Volume 10, Chapter 1, Section 4.) In short, the entire procedure and its subordinate process steps constitute a “procedural control” that employees are expected to follow. It is not necessary to try to distinguish between controls and noncontrols when referencing an entire process/procedure. However, when process gaps are identified or certain activities in the procedures fail to mitigate unacceptable risk, then those segments of the procedure are referred to as “failed risk controls.” Once new or revised risk control segments are integrated in the procedure, we cease to call those activities “controls” and just refer to the string of procedural activities as the “procedure.”
F.6.1 To address the controls attribute, aviation organizations must determine if the process or procedure is meeting its intended outputs with its current set of controls. Over time, changes occur in the operational environment that can degrade the performance of any process. Previously effective controls may no longer function properly in the changed operational environment. Therefore, it is important to monitor system processes to detect negative trends in operational performance.
F.7 Procedures Attribute. The procedures attribute is used to evaluate whether an aviation organization is maintaining regulatory compliance and employees are following approved processes and procedures. The procedures attribute is defined as “Methods or practices that are written or unwritten, regulatory or nonregulatory, designed into a process that a certificate holder/applicant uses to accomplish a desired result.” (Refer to Order 8900.1, Volume 10, Chapter 1, Section 4.)
F.7.1 “Following approved processes and procedures” also means that employees are meeting management expectations when documentation is not available. During certification, an applicant is required to develop process designs that meet regulatory requirements. This is true for all aviation organizations whether they are a single-pilot air tour operator, a large air carrier, or a repair station.
F.8 Interfaces Attribute. The interfaces attribute looks at how effective the interdependent processes and process owner “handoffs” to other process owners are. This also includes interfaces between aviation organizations. The interfaces attribute is defined as “Interactions between processes that must be managed in order to ensure desired outcomes.” (Refer to Order 8900.1, Volume 10, Chapter 1, Section 4.) Another way to think about the interfaces attribute is “How well do various processes and procedures communicate with each other?” The same can be evaluated with the process owners and
Appendix F F-5 other employees in an organization. Interface failures are target-rich environments. It is easy to think of process interfaces in terms of linear handoffs between process owners.
An example of a linear handoff would be the flight crew notifies maintenance control of an aircraft write-up. Maintenance control notifies dispatch of a maintenance delay.
Dispatch notifies the gate agent and crew scheduling, etc. The linear handoffs continue until the flight is finally dispatched. There may be perpendicular interfaces as well. These are typically training requirements, documentation procedures, and recordkeeping activities that are ancillary to the linear interfaces.
F.9 Process Measurement Attribute. The process measurement attribute assesses the “monitoring activities” each aviation organization and process owner uses to determine ongoing operational performance. The process measurement attribute is defined as “A method to monitor and measure the outputs and performance of a process, and to identify problems, or potential problems, in order to take corrective action.” (Refer to Order 8900.1, Volume 10, Chapter 1, Section 4.) Often, we mistakenly only think of auditing programs when assessing this attribute. However, understanding what constitutes the activity called “audit” actually broadens our perspective on performance measurement.
Generally speaking, an audit is gathering data and reviewing that data to determine whether intended performance expectations are being met. Most large or complex operations use formal auditing programs (e.g., audit schedules, qualified auditors, checklists, formal reports, etc.) as part of their performance monitoring.
F.9.1 There are many types of data collection activities that occur throughout an organization.
For example, a fleet manager might routinely review documentation of flight crew training and checking failures documented by instructors or pilot examiners. This data review allows the fleet manager the opportunity to evaluate the effectiveness of the training and to check the processes related to determining pilot competency. A maintenance shift manager might review Required Inspection Item (RII) documentation at the end of a shift to determine that qualified personnel accomplished all required verification checks/signoffs before returning the aircraft to service. This activity confirms process performance of the RII process. These examples fit the definition of an audit without all the bells and whistles.
F.9.2 As performance reporting is elevated to higher management levels, the data becomes more broad-based and more refined. For example, a maintenance department manager may not be interested in the outcome of RII shift reviews, but they may be interested in the on-time, return-to-service performance that the RII checks support. By the time the performance reporting reaches the CEO, the reports may be refined to something that represents meeting or not meeting a financial target associated with scheduled maintenance. For example, a CEO might want to know whether the organization met its cost targets for on-time performance for heavy maintenance. The CEO performance report is dependent on subordinate process monitoring and performance management by assigned process owners. When high-level performance targets have not been met, the organization will begin to backtrack and review the data that was collected by subordinate levels of management to determine root cause. In this light, process measurement is critical to Root Cause Analysis (RCA) and corrective action.
Appendix F F-6 F.9.3 Technical managers and process owners are expected to know how data is used to monitor process performance under their purview.
Table F-1. Safety Attributes and Part 5 Reference Attribute Definition Part 5 Responsibility A clearly identified individual who is accountable for ensuring financial and human resources to ensure the safety and quality performance of the certificate holder.
Title 14 CFR part 5, §§ 5.23(a) and 5.25(a), (b), and (c).
Authority A clearly identifiable, qualified, and knowledgeable individual who effectively plans, directs, and controls resources; changes procedures; and makes key determinations including safety risk acceptance decisions.
Section 5.23(b).
Safety Ownership An individual’s understanding of how their role contributes to the overall safety of the organization.
Sections 5.23, 5.71, 5.91, and 5.93.
Controls The checks and restraints that exist within a process that ensure the potential effects of risks are reduced to an acceptable level.
Sections 5.51, 5.53, and 5.55.
Procedures Methods or practices that are written or unwritten, regulatory or nonregulatory, designed into a process that a certificate holder/applicant uses to accomplish a desired result.
Technical process standards through applicable specific regulatory requirements, ACs, and FAA Order 8900.1 guidance. While part 5 requires procedures relevant to the SMS be documented under § 5.97, this is not considered a procedure for the purposes of this attribute.
Interfaces Interactions between processes that must be managed in order to ensure desired outcomes.
Sections 5.57 and 5.71(a)(8).
Process Measurement A method to monitor and measure the outputs and performance of a process, and to identify problems, or potential problems, in order to take corrective action.
Sections 5.71, 5.73, and 5.75.
Appendix F F-7 F.10 Summary. Since FAA regulations define required mitigation actions for aviation organizations, each aviation organization is obligated to determine what processes will effectively maintain regulatory compliance for the size and scope of their operations.
Once aviation organizations determine what processes they will use and the FAA validates technical process effectiveness during certification, the aviation organization is obligated to maintain the reliability of its processes in an ever-changing operational environment. This concept stands regardless of whether a formal SMS exists or not.
F.10.1 As stated, leveraging the safety attributes is relatively easy. Once understood, they can be applied to any process. Simply put, the attribute questions can be evaluated as follows:
1. Responsibility attribute: Are there enough resources available to support the aviation service?
2. Authority attribute: Are process owners effectively managing process risk?
3. Safety ownership attribute: Do employees understand how their day-to-day work activities support safety objectives?
4. Procedures attribute: Are adequate procedures provided to all personnel to follow in performing their duties to meet management expectations in the performance of their work?
5. Controls attribute: Are the technical processes reliable (meeting expected outcomes) if personnel execute them as designed?
6. Interfaces attribute: Are the process handoffs and operational support between organizational groups reliable?
7. Process measurement attribute: Are process owners collecting and reviewing data to monitor process performance and make improvements?
F.10.2 If the answer is “no” to any of the above process characteristics, this could be an indicator of increased risk and potential regulatory noncompliance that could result in an incident or accident. Leveraging safety attribute characteristics and their associated SMS requirements (when applicable) can improve an aviation organization’s ability to better manage risk in their operations.
Note: While incorporation of safety attributes are the core characteristics of a good management system, a lack of any or all the attributes does not mean a technical process may not meet the regulatory requirements in that area.
F.10.3 As discussed in this appendix, safety attributes represent the core characteristics of any system that should be integrated into all processes and procedures. This does not mean that each attribute should be specifically addressed when developing operational procedures, but rather the characteristics of the attributes should be identifiable. The attribute applications apply to both aviation organizations with a formal SMS and those without an SMS. All aviation organizations have a management philosophy that guides their operations. That philosophy and related activities can be referred to as a “management system.” Aviation organizations have to determine what processes will be implemented to deliver their aviation product or service. Those processes are referred to
Appendix F F-8 as “technical processes.” As previously mentioned, it is crucial that an aviation organization’s processes, both managerial and technical, are capable of meeting the organization’s safety objectives.
Appendix G G-1 APPENDIX G. SMALL OPERATOR IMPLEMENTATION G.1 General. This appendix provides potential methods smaller aviation organizations could use to meet the pertinent SMS requirements and how they can be scaled to the size and complexity of their organization. The Safety Management International Collaboration Group (SM ICG) SMS for Small Organizations9 document defines a small organization as one with between 5 and 20 staff and a very small organization as one with less than 5 staff. The FAA does not define these organizations because an SMS is designed to be adaptable based on the size and complexity of the organization. So, it is possible for an organization to be very small but highly complex and a large organization to be low complexity based on the aviation activity they are involved with.
9 SM ICG guidance documents can be downloaded from https://skybrary.aero/enhancing-safet y/sm-icg-safetymanagement-produ cts.
G.1.1 A one -size-fits-all approach to scaling the aviation organization’s response to each section of 14 CFR part 5 is not advisable. Recognizing aviation organizations have different operational environments and different levels of resources needs to be acknowledged when developing and implementing an SMS. Less complex organizations could use simple methods for conducting the processes within the SMS. More complex organizations may require more detailed processes within the SMS.
G.1.2 For organizations that have only a single pilot or technician and perhaps minimal support staff to carry out daily responsibilities, this appendix suggests utilizing a commonsense approach to SMS implementation and maintenance. In the case of a single-pilot operator, that single pilot could be the one to develop, implement, and use the SMS process. At medium and large organizations, the complexity and departmentalization of duties may require that more personnel be involved in the SMS. Regardless of the organization’s size, many aviation organizations will find their existing processes and procedures can serve as the foundation for portions of their SMS. Integration of these existing processes should be used as much as practical.
Note: Implementation strategy discussions are for illustration only and neither impose requirements nor mandate specific resource allocation by an aviation organization. Aviation organizations should integrate methods and procedures that best fit their organizational structure and that leverage processes and procedures already in place to the greatest extent possible. For additional guidance, see Chapter 3, Safety Management System (SMS) Components Explained.
G.2 Table G-1, Small Aviation Organization Implementatio n Strategies and Considerations. The table below describes ways in which the requirements could be met by small aviation organizations.