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.
Appendix G G-2 Table G-1. Small Aviation Organization Implementation Strategies and Considerations Section Implementation Strategies Considerations for Small and Single Individual Organizations Subpart B – Safety Policy.
§ 5.21, Safety policy. The safety policy and code of ethics statement requirements are not expected to vary between aviation organizations; however, the processes and procedures described in part 5, § 5.95 SMS documentation and how they are documented could vary due to the complexity of the processes being described. The safety policy and code of ethics statement could be a part of the organization’s safety manual or included in other existing documentation or manuals. For aviation organizations not required to maintain manuals, it could be integrated into a compliance statement discussing how the organization meets the requirements. Under part 5, the safety policy and SMS processes and procedures only need to be documented.
A single-individual organization is not required to have a process to communicate safety information throughout the aviation organization.
Note: The following section does not apply to those organizations with a single pilot who is the sole individual performing all necessary functions in the conduct and execution related to, or in direct support of, the safe operation of the aircraft: §§ 5.21(a)(4), (a)(5), and (c).
§ 5.23, Safety accountability and authority.
Aviation organizations are required to define the duties and responsibilities of the accountable executive. The accountable executive has the ultimate responsibility for safety management within the organization.
In single-individual organizations, the personnel structure will be very simple and consist of the person in charge being the accountable executive, who is responsible for ensuring all required duties and activities are accomplished. In a small organization, other management personnel should be identified since they would have a role in how the organization is managed on a day-to-day basis.
In single-individual organizations, this structure will be very simple and consist of the sole individual being the accountable executive and assuming the various roles and responsibilities, which would normally be assigned to other members of management. The single individual would also be responsible for accepting all risks associated with the aviation organization’s products or services.
As their organizational duties change, which could happen many times during the day, the single individual could be said to be changing hats as their role changes as they manage the activities required in § 5.23.
Note: The following section does not apply to those organizations with a single pilot who is the sole individual performing all necessary functions in the conduct and execution related to, or in direct support of, the safe operation of the aircraft: §§ 5.23(a)(2), (a)(3), and (b).
§ 5.25(a) and (b), Designation and responsibilities of required safety The accountable executive is responsible for ensuring that sufficient management personnel are clearly designated for ensuring the safety of operational and SMS processes.
In a single-individual operation, these duties would be filled by the accountable executive.
Note: The following section does not apply to those organizations with a single pilot who is the sole individual performing all necessary
Appendix G G-3 Section Implementation Strategies Considerations for Small and Single Individual Organizations management personnel.
Accountable executive.
In smaller organizations, the accountable executive may directly supervise operational processes. This individual may serve in multiple positions within the organization.
Small organizations may not have the resources for a designated representative to monitor the effectiveness of the SMS as a full-time position. A small organization may add the safety manager duties to an existing role (e.g., operations manager).
functions in the conduct and execution related to, or in direct support of, the safe operation of the aircraft: § 5.25(b)(3).
§ 5.25(c), Designation of management personnel.
These responsibilities may be carried by the accountable executive as defined in § 5.23(a)(1) or as collateral duties by managers referred to in § 5.23(a)(2), or the aviation organization could assign the tasks of supporting SMS functions to other management personnel.
In a single-pilot organization, the accountable executive would perform these designated duties as part of their duties under § 5.25.
Effective communication of safety information is still important, even in a single-pilot or single-individual organization. Communication would be focused outside of the organization (i.e., regular communication with aviation system stakeholders, industry associations, clients, the FAA, and other organizations).
Note: The following section does not apply to those organizations with a single pilot who is the sole individual performing all necessary functions in the conduct and execution related to, or in direct support of, the safe operation of the aircraft: § 5.25(c).
§ 5.27, Coordination of emergency response planning.
A small, noncomplex organization’s emergency response plan (ERP) might consist of a checklist of simple steps involving who to call when and what information to impart and a regularly updated list of contact details. When considering the ERP, succession planning should be considered. If a member of management is removed from their position to address an emergency, there should be another individual trained and competent to step into the position to ensure the organization continues to function as designed. This could even take place when the individual is away for other reasons. Common sense must prevail; processes need to be workable and tailored for the operation. In other words, do not over think it!
Effective communication of safety information is important, even in a single-pilot organization. In an organization with a single pilot or single individual, the communication focus may be outside the organization (e.g., regular communication with aviation system stakeholders, industry associations, clients, the FAA, and other organizations). Interfacing with maintenance, fixed-based operators, and flight followers (if one is used) all require communication so they are aware of the aviation organization’s activities. This will aid in scheduling support activities as well as having someone keep an eye out in case plans do not go as predicted.
In a single-pilot or single-individual organization, this could be met by simply filing flight plans with air traffic control (ATC) or leaving an
Appendix G G-4 Section Implementation Strategies Considerations for Small and Single Individual Organizations envelope with emergency contact information at the local Fixed-Base Operator (FBO) if the aircraft does not return on time.
Note: The following section does not apply to those organizations with a single pilot who is the sole individual performing all necessary functions in the conduct and execution related to, or in direct support of, the safe operation of the aircraft: § 5.27(a) and (b).
Subpart C – Safety Risk Management.
§ 5.51, Applicability. Aviation organizations must document (where required) when the Safety Risk Management (SRM) processes are to be implemented based on the requirements in § 5.51.
In small or single-pilot, sole-individual organizations, all of the risk management tasks could be accomplished by the accountable executive.
§ 5.53(a) and (b), System analysis and hazard identification.
The system analysis could be performed by the owner/manager and/or another assigned employee(s). An analysis could consist of a discussion among managers, such as the Director of Operations (DO) and/or Chief Pilot or other individuals designated by them.
SRM elements and their intended outcomes are the same regardless of the size and complexity of an organization. The breadth and degree of analysis is where the aviation organization will tailor the processes to their size, complexity, and operating environment.
Aviation organizations should consider how their service providers and contractors interact with the organization. Identify the areas where risk could be introduced into the operations.
Outputs of the system analysis, which define the function and purpose of the system, the system’s operating environment, an outline of the system’s processes and procedures, and the personnel, equipment, and facilities necessary for the operation of the system, should be retained. Appendix B, Sample Safety Risk Management (SRM) Worksheets, provides an example of a set of SRM worksheets that could be used as paper records or converted to a variety of software applications, including In small or single-pilot, sole-individual organizations, all of the risk management tasks could be accomplished by the accountable executive.
In single-individual organizations, the accountable executive already has a good idea of the core risks and any control measures that can easily be applied. The accountable executive does not have to be a risk specialist because they will most likely know the risks in the organization already.
Consider whether the SRM processes and procedures developed are simple and work for the organization to actively look for safety issues.
In a small organization, the question “how does the organization identify safety issues from occurrence or incident reports?” should be asked.
These organizations could record the outputs of their system analysis in a simple recording medium, such as a worksheet or a notebook, a common desktop software, or a third-party software program or provider (e.g., WBAT).
Appendix G G-5 Section Implementation Strategies Considerations for Small and Single Individual Organizations desktop spreadsheets or the Web-Based Application Tool (WBAT) (see Appendix H, References and Additional Information).
§ 5.53(c), System analysis and hazard identification.
While there is no appreciable difference between the expected outcomes in a single-individual organization versus a larger organization, how you store, communicate, and track aspects associated with risk management may vary based on the size and complexity of the organization. For example, it may be accomplished by using worksheets completed manually, computer spreadsheets, or commercial software.
The output of hazard identification could be recorded in a simple recording medium, such as a spreadsheet, paper files, or a third-party software program or provider (e.g., WBAT).
Hazard identification could be performed by the owner/manager (accountable executive) and/or another employee(s), often as part of the system analysis.
In small or single-pilot, sole-individual organizations, all of the risk management tasks could be accomplished by the accountable executive.
In single-individual organizations, the accountable executive already has a good idea of the core risks and any control measures that can easily be applied. The accountable executive does not have to be a risk specialist because they will most likely know the risks in the organization already.
Consider whether the SRM processes and procedures developed are simple and work for the organization to actively look for safety issues.
In a small organization, the question “how does the organization identify safety issues from occurrence or incident reports?” should be asked.
§ 5.55(a), Safety risk assessment and control.
In smaller or lower complexity aviation organizations, risk analysis could be performed by the owner/manager (accountable executive) and/or another employee(s).
It might be performed in conjunction (by the same individual/group) with system analysis, hazard identification, risk assessment, and risk control.
In small or single-pilot, sole-individual organizations, all of the risk management tasks could be accomplished by the accountable executive.
In single-individual organizations, the accountable executive already has a good idea of the core risks and any control measures that can easily be applied. The accountable executive does not have to be a risk specialist because they will most likely know the risks in the organization already.
Consider whether the SRM processes and procedures developed are simple and work for the organization to actively look for safety issues.
In a small organization, the question “how does the organization identify safety issues from occurrence or incident reports?” should be asked.
Appendix G G-6 Section Implementation Strategies Considerations for Small and Single Individual Organizations § 5.55(b), Safety risk assessment and control.
In a small or lower complexity aviation organization, risk assessments could be performed by the owner/manager (accountable executive) and/or other employee(s) making the risk decisions. Risk acceptance would also probably be conducted by this individual/group. While similar to a Flight Risk Assessment Tool (FRAT), the risk assessment required by § 5.55 is to determine if the residual and associated risks to the process are acceptable. Quite often, a risk matrix is utilized to determine if any residual risk or substitute risk are acceptable to the aviation organization. A FRAT would be used to determine if conditions are acceptable for a specific flight to commence. It is important not to confuse the purpose of these two distinctly different tools and their application.
The outputs of this process could be recorded on paper or via an electronic medium, such as a third-party software program or provider (e.g., WBAT).
In small or single-pilot, sole-individual organizations, all of the risk management tasks could be accomplished by the accountable executive.
In single-individual organizations, the accountable executive already has a good idea of the core risks and any control measures that can easily be applied. The accountable executive does not have to be a risk specialist because they will most likely know the risks in the organization already.
Consider whether the SRM processes and procedures developed are simple and work for the organization to actively look for safety issues.
In a small organization, the question “how does the organization identify safety issues from occurrence or incident reports?” should be asked.
§ 5.55(c) and (d), Safety risk assessment and control.
In aviation organizations with a lower complexity or size, the risk control process could be a documented activity performed by the owner/manager (accountable executive) and/or other employee(s) designing and evaluating the risk controls. It might be performed in conjunction (by the same individual/group) with system analysis, hazard identification, risk analysis, and risk assessment.
While there is no appreciable difference between the expected outcomes in a single-individual organization versus a larger organization, how you store, communicate, and track aspects associated with risk management will vary based on the size and complexity of the organization.
Small organizations should consider how their service providers and contractors interact with the organization. In a small organization, the question “where are areas that risk could be introduced into the operations?” should be asked.
In very small organizations, individuals across the organization should be aware of the organization’s biggest risks and what actions are in place to mitigate them.
SRM for single-individual organizations does not need to be overly complex. In a single-person organization, the question “are you looking for and documenting hazards?” should be asked.
Appendix G G-7 Section Implementation Strategies Considerations for Small and Single Individual Organizations For any of these organizations, tracking or storing SRM outputs could be accomplished by using worksheets that are completed manually, computer spreadsheets, or commercial software, such as WBAT.
§ 5.57, Notification of hazards to interfacing persons.
Aviation organizations must provide hazard notifications to interfacing organizations that, to the best of their knowledge, could address a hazard or mitigate the hazard’s risk (§ 5.57).
This requirement is limited to hazard notifications to those interfacing organizations that contribute to the safety of the products or services you provide.
Note: Per § 5.3, a ha zard is defined as “a condition or an object that could foreseeably cause or contribute to an incident or aircraft accident.” Reporting under § 5.57 should only occur for issues you have identified as hazards, and the report should only be provided to the interfacing organization you believe can best address the hazard or mitigate its risk. Section 5.57 does not require the reporting of concerns that are not hazards
(e.g., commercial issues between companies) as the intent of § 5.57 is to facilitate timely sharing of safety information.
A small organization could communicate identified hazards to another organization via email, telephone call, or other means as appropriate.
Subpart D – Safety Assurance.
§ 5.71(a)(1), Safety performance monitoring and measurement.
Monitoring o perational processes.
Some aviation organizations might utilize the line managers and departmental or key management personnel to observe and review day-to-day activity, noting work task inconsistencies and potential safety issues.
Flight operations quality assurance (FOQA) and Line Operations Safety Audit (LOSA) programs may also be sources of information to monitor operations.
In small or lower complexity organizations, most of the data/information-gathering for monitoring of operational processes will likely occur as a normal business process by the management personnel (e.g., accountable executive) who are directly involved in the day-to-day operations. For example, regularly reviewing
(e.g., weekly, monthly, or quarterly) the flight dispatch logs and crewmember duty records is a form of monitoring and could be conducted during the normal course of duties.
§ 5.71(a)(2), Safety performance monitoring and measurement.
Processes used will vary based on the size and complexity of the organization and the aviation service the organization provides or supports. Monitoring of the operational environment involves practices that are similar to those of monitoring operational processes. For example, seasonal weather conditions may Small or single-individual organizations might keep a log tracking operational issues or deviations from existing processes and procedures. This information could be used to detect changes in the operating environment. Information sharing with other organizations could also provide input to changing operational environments.