Appendix G G-8 Section Implementation Strategies Considerations for Small and Single Individual Organizations Monitoring operational environment.
require aviation organizations to change their scheduling, routes, and aircraft utilization.
§ 5.71(a)(3), Safety performance monitoring and measurement.
Auditing operational processes and systems.
Organizations should develop procedures for auditing that describe the audit process, criteria, scope, frequency, method for selecting auditors, and methods of documentation and recordkeeping. Audit planning should take into account the safety criticality of the processes to be audited and the results of previous audits.
The results of audits can be recorded in paper format (e.g., a common logbook-style binder) or in electronic media (e.g., a desktop spreadsheet program or a program such as WBAT).
In smaller or lower complexity aviation organizations, the auditing process could be carried out periodically by the accountable executive/owner, key management person, or a trained employee as a collateral duty. Audits may also be carried out as a subfunction of normal business processes. For example, comparisons of deferred maintenance logs and repair part receipts are a form of safety auditing that are probably already accomplished routinely.
A single-individual organization should review their records on a defined interval to look for trends in operational performance that could identify ineffective processes and procedures.
§ 5.71(a)(4), Safety performance monitoring and measurement.
Evaluations of the SMS and operational processes and systems.
In a small organization, the evaluation process could be carried out periodically by the accountable executive/owner. In larger organizations, evaluations could be performed by a key management person or designated employees as a collateral duty. The process could be accomplished by the Director of Safety (DOS) or the safety department on a monthly, quarterly, or other periodic basis, as determined by the information needs of the accountable executive or other senior management decisionmakers.
A single-individual organization should review their records on a defined interval to look for trends in operational performance that could identify ineffective processes and procedures.
Appendix G G-9 Section Implementation Strategies Considerations for Small and Single Individual Organizations § 5.71(a)(5), Safety performance monitoring and measurement.
Investigations of i ncidents and accidents.
Aviation organizations need to define the types of incidents and accidents that require investigations. Part 5 only requires incidents and accidents that directly affect the aviation product or service be investigated.
Processes used will vary based on the size and complexity of the organization and aviation service the organization provides or supports. Investigations should focus on what went wrong rather than who caused the error and emphasize improvement of safety performance.
In smaller or less complex aviation organizations, investigations can be conducted by the accountable executive or assigned employees.
Investigations can be conducted by a safety department with additional assigned line personnel providing technical expertise.
Investigation is a necessary activity within any SMS, regardless of the organization’s size. If, as a single-individual organization, you do not have a process to conduct investigations, consider using industry resources outside of your organization or contracting services from a third-party provider. As a one-person organization, you know exactly how it operates. With a sound documented process to conduct an investigation, you should be able to come up with relevant conclusions as long as you remain objective.
§ 5.71(a)(6), Safety performance monitoring and measurement.
Investigations of reports of potential non-compliances.
An SMS does not relieve aviation organizations from other regulatory requirements. This also includes documented processes and procedures that may be contained in maintenance manuals or Aircraft Flight Manuals (AFM) or those that are organization specific.
Methods of conducting investigations of potential noncompliance could be accomplished in a manner similar to that for investigations of accidents and incidents.
§ 5.71(a)(7), Safety performance monitoring and measurement.
Confidential e mployee reporting system.
An employee reporting system need not be highly sophisticated to be effective. The employees might report a hazard either orally or in a note or email to their supervisor. Several industry groups provide an employee reporting program for small aviation organizations and provide management and de-identification of information. They also provide access to other de-identified reports so identified hazards can be integrated into the participating aviation organization’s SMS.
Aviation organizations on the higher end of the size or complexity spectrum may have an existing online employee reporting system or Aviation Safety Action Programs (ASAP) for some employee groups.
In small organizations, data collection for the reporting system can take many forms, from a simple suggestion box to organizational websites or intranets or a dedicated email address. Data management can be accomplished with a common desktop spreadsheet, database software, or specialized software, such as WBAT.
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: § 5.71(a)(7).
Appendix G G-10 Section Implementation Strategies Considerations for Small and Single Individual Organizations § 5.71(a)(8), Safety performance monitoring and measurement.
Investigations of hazard notifications.
Documentation and retention of these notifications can be in a spreadsheet, notebook, or other means that would ensure the hazard is appropriately addressed.
Single-individual organizations should have a process for documenting and managing hazards shared from other organizations transmitted to them in the course of operations. Methods of conducting investigations of hazard notification could be accomplished in a manner similar to that for investigations of accidents and incidents.
§ 5.71(b), Safety performance monitoring and measurement.
Data analysis.
The outputs from data analysis could be recorded in a simple recording medium (e.g., a notebook, paper files, a common desktop software, specialized systems, or a third-party software, such as WBAT).
In a small aviation organization, data acquisition may consist of making notes about how things did not go as planned, how communications were compromised at low altitude in certain flight route segments, etc. This data could be reviewed on a regular basis (perhaps monthly or quarterly). Hazards could be analyzed using SRM, and mitigating actions could be recorded as changes to procedures, minimum performance requirements, etc. are identified.
In a single-individual organization, the accountable executive will perform this function. In a small organization, this could be accomplished by another member of management.
§ 5.73, Safety performance assessment.
The results of assessments can be recorded in a paper or electronic medium (e.g., in a common logbook-style binder, electronic file folder, common desktop software, specialized system, or third-party software program, such as WBAT).
In a small or lower complexity aviation organization, safety performance and assessment could be a documented activity performed by the accountable executive or a coordinated activity between the accountable executive and other operational managers, supported and coordinated by the DOS if the organization has this position. Risk acceptance would also normally fall to managers within this group.
In small organizations, the reactive data gathered may not be statistically significant due to small sample sizes. This can be managed by looking beyond the data within your own organization.
Where available, the organization could include data from industry organizations and associations, related industries, regulatory bodies, and safety boards.
For single-individual organizations, an internal review (a self-assessment) may be as effective as a formal audit. Networking
Appendix G G-11 Section Implementation Strategies Considerations for Small and Single Individual Organizations with other similar organizations and sharing safety information may provide insights into vulnerabilities that may exist in the organization’s processes and procedures.
§ 5.75, Continuous improvement.
Continuous improvement decision making is an output of the Safety Performance Assessment (SPA) process. Therefore, corrective actions discussed during the assessment apply to continuous improvement activities. The managers, committees, or working groups that make assessment decisions for the aviation organization would also determine the appropriate corrective actions based on the situation.
There would be no difference in how this section is addressed by any aviation organization based on size, complexity, or scope of operations.
Subpart E – Safety Promotion.
§ 5.91, Competencies and training.
Aviation organizations may choose to either train their employees in house or contract the training to outside vendors.
Whichever option is taken, the training must be specific to the SMS and aviation activities conducted. Training can be in person or virtual based on organizational needs. Training should be modular so only the material pertinent to the position within the organization is presented.
A small or low-complexity organization with only a few employees would likely complete online training to meet this requirement.
Aviation organizations on the higher end of the size or complexity spectrum could have a training department that develops and conducts the training.
The knowledge and experience gained by a single individual developing the organization’s SMS is likely sufficient to meet training requirements for the organization. In a small organization, consider whether the safety manager or the individual assigned the associated duties (if there is one in a small organization) has received SMS training.
§ 5.93, Safety communication.
In smaller or lower complexity aviation organizations, communicating safety considerations to employees may be simple and direct. For example, the accountable executive could conduct regular all-hands/employee meetings, such as “hangar talk sessions.” Additionally, communication could include regular and periodic briefings to the employees, posting the status of safety issues on bulletin boards, emails to employees, and face-to-face meetings with division management teams.
Aviation organizations with only a few employees could utilize a required reading list consisting of material from industry or other sources. The selected material would be applicable to the Small organizations should consider the methods they will utilize when sharing information with other aviation service providers they interface with. Methods used can be as simple or as complex as the organization chooses, but they should be consistent. Maintaining a “Journey Log” or “Unusual Occurrences” log may be useful for regular review and reinforcement of safety concerns identified when performing the aviation service. This will facilitate entering the occurrences into the safety assurance component (§ 5.71) for tracking and resolution.
Appendix G G-12 Section Implementation Strategies Considerations for Small and Single Individual Organizations operations conducted. Documentation of what was reviewed would meet the requirements of § 5.97(d).
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: § 5.93.
Subpart F – SMS Documentation and Recordkeeping.
§ 5.95, SMS documentation.
Smaller organizations might use a compliance statement or spreadsheet listing the part 5 requirements and how the organization meets the requirements. SMS documentation may be maintained either as hard copies or electronically. It may be contained in a General Operations Manual (GOM) or Repair Station Manual (RSM) or any other combination of documentation and manuals that is appropriate for the organization. However, the documentation is maintained, the organization should ensure it remains up to date.
In a small or lower complexity aviation organization, the owner/manager (accountable executive) or designee may be responsible for maintaining and distributing current versions of guidance documents. Single-pilot organizations, while not required to maintain a manual system per 14 CFR part 135, § 135.21, are still required to document their SMS safety policy and SMS processes and procedures.
Documentation may consist of a set of typewritten documents, spreadsheets, and forms that are kept in file cabinets or binders. They may also use WBAT or other third-party providers. Managers of medium-complexity organizations need the same type of information to make decisions; however, the volume is typically larger than that of a low-complexity organization and smaller than that of a high-complexity organization.
§ 5.97, SMS records. The process developed for record retention should be appropriate for the aviation organization. As an example, digital photographs of safety-related posters or signs in a maintenance hangar could be retained as a record of the communication.
Read-and-initial documents would also provide a record.
Hangar talks and flight crew alerts are also types of communications that would be retained. These communications can be retained electronically or in paper format. The method utilized should be appropriate to the size and complexity of the aviation organization.
In smaller or lower complexity aviation organizations, the owner/manager (accountable executive) or designee may be responsible for maintaining auditable records. Documentation may consist of handwritten records, spreadsheets, phone and email logs, and completed forms that are kept in file cabinets or binders.
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: § 5.97(d).
Appendix G G-13 G.3 Sample Scenarios. In the paragraphs below, we will use fictional aviation service provider Flyslow Aviation as an example of how a typical organization could integrate part 5 requirements into their operations and how different safety issues they encounter are addressed.
G.3.1 G eneral Applicability Example.
G.3.1.1 To meet the requirement to implement an SMS, Flyslow Aviation starts by reviewing their organization to consider the operating environment, personnel needed, any interfaces with other organizations and facilities, and materials needed to provide their aviation service or product. They may identify flight operations, maintenance, dispatch, and training departments as areas that support the aviation product or service. They might also identify external organizations that support the aviation product or service, such as fuel service providers, third-party maintenance, and catering. All this information would be documented in an organizational description that can be used to ensure all aviation-related areas are considered in the SMS development.
G.3.1.2 To ensure part 5 is fully integrated into the organization, Flyslow Aviation may develop a compliance statement for their internal tracking to document how they already meet the requirements of part 5. While not required for existing operators, a compliance statement makes identifying existing processes and procedures as well as existing methods and voluntary programs easier to verify when documenting how an organization meets the regulatory requirements. This is accomplished for all departments and areas identified in the organizational description.
G.3.2 D esignation of Management Personnel Example. Flyslow Aviation has chosen to use an existing required management individual required under 14 CFR part 119, §§ 119.65 and 119.69 or part 145, §§ 145.151 and 145.153 to fulfill these responsibilities. As Flyslow Aviation grows and expands, they could establish a safety department with designated personnel assigned this requirement.
G.3.3 Safety Policy Example. Flyslow Aviation recognizes the key to a successful organization is open communication and strong leadership. They identify the accountable executive and management representatives (§ 5.23) and start working on the safety policy. While developing safety objectives (§ 5.21(a)(1)), management reviewed the organization’s performance indicators as well as reports from previous audits. Management then determined a reduction in uncalibrated tools being issued by the tool room would be an appropriate objective for the coming year. Management communicates the organization’s goal of reducing uncalibrated tool issuance by 20 percent by publishing an updated safety policy (§ 5.21(c) and (d)) and through employee meetings (§ 5.23). Management also develops processes and procedures describing how employees are expected to accomplish their duties and responsibilities under the SMS.
Appendix G G-14 G.3.4 S ystem Analysis Example . Flyslow Aviation is considering the addition of a new aircraft (or a fleet of aircraft) for operations to meet organizational or corporate goals. Several organizational systems would be affected (e.g., flight operations, maintenance, station, ground, etc.). As part of the examination of the flight operations system, Flyslow Aviation needs to consider changes to pilot qualifications, pilot and mechanic training, scheduling, crew rest, employee representation participation, and several other areas. This is a process normally done as part of business activities.
G.3.4.1 T he system analysis should identify and consider activities and resources necessary for the system to function. For example, in the scenario of adding aircraft to the fleet, Flyslow Aviation identifies the pilot training system as one of the affected systems and the need for additional activities and resources necessary for pilot training to operate the additional aircraft. These resources may include simulators, training curriculum, training aids, and instructors. A repair station might be adding a rating or changing from paper to digital manual systems and need to update their revision tracking process and training for employees.
G.3.4.2 Although Flyslow Aviation has to consider many systems and procedures when considering larger, systemic changes, simpler changes, such as a change in a single procedure (e.g., arming cabin doors prior to pushback), would only have to consider the elements of the system that would be affected by the change. The system analysis process frequently includes representatives from management, safety staff, subject matter experts (SME), employees, and representation groups (e.g., pilots and mechanics) in workgroups, such as safety committees, safety roundtables, safety action groups, or similar titles.
Since many, if not most, system changes involve allocation of resources, the accountable executive or other managers with the authority to commit resources should be included in the process.
G.3.4.3 Flyslow Aviation records 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. One example is the Web-Based Application Tool (WBAT) (see Appendix H, References and Additional Information).
G.3.5 SRM Example. F lyslow Aviation initiates the SRM processes due to an employee report identifying a hazard: an uncalibrated tool issued to a technician. This was in response to a report sent through the safety assurance employee safety reporting system (§ 5.71(a)(7)).
G.3.5.1 T he tool room process owner starts by conducting a system analysis (§ 5.53(b)) on the calibrated tool control process by identifying the various interfaces with the procedure. The process owner also looks for areas where a hazard might exist (§ 5.53(c)). Once potential areas where mistakes (hazards) could occur, the process owner conducts a risk assessment (§ 5.55(b)) using Flyslow Aviation’s risk matrix. By identifying the likelihood of uncalibrated tools being issued and the severity of a potential failure where uncalibrated
Appendix G G-15 tools were used, the process owner determines the risk is moderate due to the criticality of the tasks the technicians using the tools are completing. The process owner, remembering their training, uses a risk matrix to determine the potential risk of the uncalibrated tool being used. As risk is a composite of likelihood and severity and since uncalibrated tools have been issued to technicians previously, the process owner considers this a likely occurrence.
G.3.5.2 Flyslow Aviation’s management, process owners, and employee representatives work together to develop risk controls (§ 5.55(c)) to prevent future issuance of uncalibrated tools to employees. Brainstorming identifies several methods they can use to enhance existing processes. These include a complete audit and verification of the online tool tracking software to ensure all information is entered correctly. A review of calibrated tool expiration dates will be accomplished at the start of each shift to ensure any tools that may have expired are removed from use. Signs will be designed and posted in the tool room reminding the technicians to double check the calibration dates on tools prior to use, and management will be provided with talking points to use during routine employee meetings to ensure everyone is aware of the need to verify the calibrated tool dates.
G.3.5.3 The aviation organization reviews the proposed risk controls and determines the revised procedure is acceptable before implementation (§ 5.55(d)).
G.3.6 H azard Notification Example . The following example demonstrates how hazard notification in accordance with § 5.57 should occur for a small operator. This issue is not related to the calibrated tool example described in other paragraphs.
G.3.6.1 F lyslow Aviation received an employee report from a pilot stating that the aircraft flight management system (FMS) deviated from the expected approach at a particular airport. The flight crew noticed the deviation and corrected the flight path for a safe landing. Flyslow Aviation’s SMS classified this employee report as a hazard because the airport is surrounded by high-elevation terrain. Although this incident occurred during the daytime and in visual meteorological conditions (VMC), management determined that if the same issue occurred during a night landing or instrument meteorological conditions (IMC), the aircraft could be turned toward terrain without detection by the flight crew, foreseeably resulting in an accident.
G.3.6.2 Flyslow Aviation followed its hazard notification process and decided that the aircraft manufacturer was the best organization to mitigate the risk (step 1).
Flyslow Aviation also decided that the aircraft manufacturer contributed to the safety of the services provided by Flyslow Aviation (step 2). Flyslow Aviation provided the following hazard notification to the aircraft manufacturer (step 3): “Aircraft model Alpha-1 (serial number 225) performed a wrong turn at waypoint YAYGO on XYXYX TWO ARRIVAL (RNAV) approach to airport KXYZ.”
Appendix G G-16 G.3.6.3 No further action under § 5.57 is required by Flyslow Aviation. The organization has met the § 5.57 hazard notification requirements in this example.
G.3.7 S afety Assurance Example. Flyslow Aviation becomes aware of an uncalibrated tool being issued to a technician through their confidential employee reporting program (§ 5.71(a)(7)). During a review of the tool control program, the process owner recognized this could be a potential noncompliance with regulatory standards (§ 5.71(a)(6)) and uses the Voluntary Disclosure Reporting Program (VDRP) to notify Flyslow Aviation’s FAA Certificate Management Team (CMT) of the incident.
G.3.7.1 A n investigation of the calibrated tool program is initiated as required by § 5.71(a)(3). Records of previous audits (§ 5.97(b)) were reviewed for any previous calibrated tool findings. It was noted during the records review and interviews with employees that the tool room changed from a manual calibrated tool tracking system to a computer-based tracking system since the previous audit occurred.
G.3.7.2 Uncalibrated tools being issued to employees is identified as a new hazard (§ 5.73(c)). Flyslow Aviation initiates their SRM process as required by § 5.51(d).
G.3.7.3 Once acceptable risk controls are developed and implemented using their SRM processes, Flyslow Aviation establishes a new objective to reduce the issuance of uncalibrated tools and adds a requirement to track calibrated tool control under § 5.73(a)(3) to ensure the developed risk controls are functioning as designed. The process owner regularly reviews the data acquired through their safety assurance monitoring processes and evaluates the effectiveness of the changes to the calibrated tool program.
G.3.7.4 After a defined period of monitoring the tool tracking process, Flyslow Aviation determines the risk controls are working as designed as there have been no further instances of uncalibrated tools being issued to technicians.
They close out the special audit and monitoring of this risk control for their calibrated tool program.
G.3.8 S afety Promotion and SMS Documentation and Recordkeeping Example. In an effort to raise awareness of the calibrated tool issue and employee reporting, Flyslow Aviation’s management included discussions on these areas as a monthly topic during employee meetings (§ 5.23(2)(iii) and § 5.93). In addition, management posted signs and posters in the breakroom and work areas. Rosters of meeting attendees were retained as well as a copy of the agenda topics (§ 5.97(d)).
Note 1: I n this example, § 5.91 would not be required as the training requirement addresses SMS processes and procedures. Calibrated tool usage, which is the subject of the training, is covered by other regulations and not the SMS.
Appendix G G-17 Note 2: Flyslow Aviation has control of the calibrated tool program and the associated hazards. If the hazard was under the control of an interfacing organization, then Flyslow Aviation would communicate the hazard under § 5.57.
Appendix H H-1 APPENDIX H. REFERENCES AND ADDITIONAL INFORMATION H.1 SMS-Related Resources. For additional information regarding SMSs, the following resources may prove helpful:
H.1.1 FAA public SMS website: https://www.faa.gov/about/initiatives/sms/specifics_by_aviati on_industry_type.
H.1.2 International Civil Aviation Organization (ICAO) Safety Management website:
https://www.icao.int/safety/SafetyManagement/Pages/default.aspx.
H.1.3 Transport Canada (TC) SMS website: https://tc.canada.ca/en/aviation/general- operatingflight-rules/aviation-safety-management/safety-management-systems-aviation.
H.1.4 Australian Government Civil Aviation Safety Authority SMS website:
https://www.casa.gov.au/operations-safety-and-travel/safety-management-systems.
H.1.5 Civil Aviation Authority (CAA) of New Zealand SMS website:
https://www.aviation.govt.nz/safety/sms-safety-management-systems/.
H.1.6 Web-Based Application Tool (WBAT). WBAT (maintained by Universal Technical Resource Services, Inc. (UTRS)) provides service providers with a secure, fully customizable system that promotes safety and accountability across five employee groups. UTRS developed WBAT with funding from the FAA and will deliver free onsite training and electronic support to certificate holders (CH). The UTRS point of contact (POC) can be reached at info@wbatsafety.com.
H.2 Code of Federal Regulations (CFR). Title 14 CFR Part 5, Safety Management Systems, and other current regulations are available online at https://www.ecfr.gov.
H.3 FAA Resources.
H.3.1 FAA Website. The FAA website is at https://www.faa.gov.
H.3.2 Dynamic Regulatory System (DRS). DRS is located at https://drs.faa.gov and contains:
• FAA Order 8900.1, Volume 10, Safety Assurance System Policy and Procedures.
• FAA Order 8900.1, Volume 17, Safety Management System.
H.4 Related Reading Material. Current editions of the following documents may be helpful in developing an SMS.
H.4.1 A dvisory Circulars (AC) . The following ACs are available on the FAA website and in DRS:
Appendix H H-2
• AC 00-58, Voluntary Disclosure Reporting Program.
• AC 21-58, Safety Management Systems for Part 21 Type and Production Certificate Holders.
• AC 120-48, Communication and Coordination Between Flightcrew Members and Flight Attendants.
• AC 120-49, Parts 121 and 135 Certification.
• AC 120-59, Internal Evaluation Programs.
• AC 120-66, Aviation Safety Action Program.
• AC 120-79, Developing and Implementing an Air Carrier Continuing Analysis and Surveillance System.
• AC 120-82, Flight Operational Quality Assurance.
• AC 120-115, Maintainer Fatigue Risk Management.
• AC 150/5200-37, Safety Management Systems for Airports .
H.4.2 FAA Orders. The following orders are available on the FAA website and in DRS:
• FAA Order VS 8000.367, AVS Safet y Management System (AVSSMS) Requirements.
• F AA Order 8000.369, Safety Management System.
• FAA Order 8000.377, Flight Standards Safety Management System (FSSMS) Requirements.
H.4.3 ICAO Resources. The following resources are available on the ICAO website at https://www.icao.int/publications/Pages/default.aspx:
• Annex 6, Operation of Aircraft, P art I, International Commercial Air Transport – Aeroplanes.
• A nnex 8, Airworthiness of Aircraft.
• Annex 19, Safety Management.
• Document 9859, Safety Management Manual.