Par 3-1 Page 9 CHAPTER 3. SAFETY MANAGEMENT SYSTEM (SMS) COMPONENTS EXPLAINED
3-1. OVERVIEW OF THE STRUCTURE OF CHAPTER 3. SMS requirements are organized around building blocks of safety management. These processes are essential for an SMS. This chapter contains short descriptions of each SMS component and the processes contained therein. After the title of each process are the following.
a. Specific Regulatory Requirement (SRR). The SRR for the process (where it may be found in Title 14 of the Code of Federal Regulations (14 CFR) part 5).
b. Related Regulatory Requirements. Where applicable, to help put part 5 in context of existing regulations and provide reference for interrelated requirements within part 5, e.g., requirements for management accountability related to a process.
c. Tracking Tags.3 A reference to International Civil Aviation Organization (ICAO)/former Safety Management System Pilot Project (SMSPP) - Component/Element tags.
These do not denote legal requirements; they are provided solely as reference to facilitate cross-referencing and gap analysis on the part of SMSPP participants to assist them in revising their plans and systems to comply with part 5. The Federal Aviation Administration (FAA) emphasizes that fully complying with part 5 satisfies almost all4 of the pertinent ICAO SMS requirements.
d. A Summary. A brief plain language overview of the process.
e. An Objective. A brief explanation of the goal of the process.
f. A Regulatory Text Box. A copy of part 5 regulatory text, for reference, which should facilitate readers’ ability to relate regulatory requirements with explanations without the need to cross-reference additional documents.
g. A Discussion. A more detailed plain language explanation of the process as it relates to the SMS. It includes some examples, when appropriate, and offers optional Recommended Design Characteristics.
h. Scalability. A short discussion, where applicable, of scalability, providing examples of how different-sized carriers can meet the pertinent SMS requirements. Information on scalability is broken down into small, medium, and large carriers. Small carriers are generally defined as those carriers operating fewer than 10 airplanes; medium carriers are those with fewer than 48 airplanes; and large carriers are those with more than 48 airplanes.
3 These tags are included to assist carriers who originally developed their documentation in accordance with AC 120-92A, Appendix 2, and for alignment with international standards. The items referenced as “components” or “elements” are also consistent with ICAO Annex 19, Appendix 2, SMS Framework.
4 ICAO Safety Management standards require operators of airplanes over 27,000 kg to have include a Flight Data Analysis (FDA) program as part of their SMS. Part 5 will not require these programs.
Par 3-1 Page 10 NOTE: The scalability discussions are for illustration only and impose neither requirements nor resource allocation by a service provider.
3-2. SUBPART A: GENERAL.
a. Applicability: Requirements for Implementation.
(1) SRR. Part 5, § 5.1.
(2) Related Regulatory Requirements. None.
(3) ICAO/SMSPP. N/A.
(4) Part 5 Requirements.
(5) Discussion. The SMS required by this regulation is intended to cover only the aviation operational processes of the carrier. For example, the aviation operational processes in a typical carrier may include:
• Flight operations,
• Operational control (dispatch/flight following),
• Maintenance and inspection,
• Cabin safety,
• Ground handling and servicing,
• Cargo handling, and
• Training.
NOTE: Information concerning implementation planning for 14 CFR part 121 certificate holders and applicants for part 121 certificates is outlined in greater detail in Chapter 4, Implementation: Building a Safety Management System (SMS).
b. General Requirements: Components of an SMS.
(1) SRR. Section 5.3(a).
(2) Related Regulatory Requirements. None.
§ 5.1 Applicability.
(a) A certificate holder under part 119 of this chapter authorized to conduct operations in accordance with the requirements of part 121 of this chapter must have a Safety Management System that meets the requirements of this part and is acceptable to the Administrator by March 9, 2018.
(b) A certificate holder must submit an implementation plan to the FAA Administrator for review no later than September 9, 2015. The implementation plan must be approved no later than March 9, 2016.
(c) The implementation plan may include any of the certificate holder ’s existing programs, policies, or procedures that it intends to use to meet the requirements of this part, including components of an existing SMS.
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(3) ICAO/SMSPP. N/A.
(4) Part 5 Requirements.
(5) Discussion. For a discussion on size, scope and complexity with regard to SMS scalability, see paragraph 1-3 and the scalability examples in this chapter.
c. Recordkeeping Requirements.
(1) SRR. Section 5.3(b).
(2) Related Regulatory Requirements. Section 5.95.
(3) ICAO/SMSPP. N/A.
(4) Part 5 Requirements.
(5) Discussion. Documentation and recordkeeping requirements are in part 5, subpart F.
d. Compliance with Code of Federal Regulations (CFR).
(1) SRR. Section 5.3(c).
(2) Related Regulatory Requirements. None.
(3) ICAO/SMSPP. N/A.
(4) Part 5 Requirements.
§ 5.3 General requirements.
(a) Any certificate holder required to have an SMS under this part must submit the Safety Management System to the Administrator for acceptance. The SMS must be appropriate to the size, scope, and complexity of the certificate holder’s operation and include at least the following components:
(1) Safety policy in accordance with the requirements of subpart B of this part;
(2) Safety risk management in accordance with the requirements of subpart C of this part;
(3) Safety assurance in accordance with the requirements of subpart D of this part; and
(4) Safety promotion in accordance with the requirements of subpart E of this part.
§ 5.3 General requirements.
(b) The Safety Management System must be maintained in accordance with the recordkeeping requirements in subpart F of this part.
§ 5.3 General requirements.
(c) The Safety Management System must ensure compliance with the relevant regulatory standards in chapter I of Title 14 of the Code of Federal Regulations.
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3-3. SUBPART B: SAFETY POLICY.
a. Introduction.
(1) SRR. Part 5, subpart B.
(2) Related Regulatory Requirements. None.
(3) ICAO/SMSPP. N/A.
(4) Summary. This section of the advisory circular (AC) provides guidance about how the accountable executive, in coordination with other senior managers, might define safety performance objectives, assign accountability, and allocate resources. The safety policy should be appropriate to the size, scope, and complexity of the operation. Additionally, the safety policy component is where your management defines their commitment to managing safety throughout the organization.
b. Safety Policy.
(1) SRR. Section 5.21.
(2) Related Regulatory Requirements. None.
(3) ICAO/SMSPP. Element 1.1.
(4) Part 5 Requirements.
(5) Discussion. The safety policy statement is a concise document from the accountable executive that conveys the organization’s basic commitments to safety management. It provides a basis for more detailed setting of objectives for planning and performance measurement, assignment of responsibility, and reporting, including clear statements regarding behavioral and performance expectations. The safety policy may be supported by additional documents that expand in specific areas, and, where applicable, it may also set out procedures. An example of a § 5.21 Safety policy.
(a) The certificate holder must have a safety policy that includes at least the following:
(1) The safety objectives of the certificate holder.
(2) A commitment of the certificate holder to fulfill the organization's safety objectives.
(3) A clear statement about the provision of the necessary resources for the implementation of the SMS.
(4) A safety reporting policy that defines requirements for employee reporting of safety hazards or issues.
(5) A policy that defines unacceptable behavior and conditions for disciplinary action.
(6) An emergency response plan that provides for the safe transition from normal to emergency operations in accordance with the requirements of § 5.27.
(b) The safety policy must be signed by the accountable executive described in § 5.25.
(c) The safety policy must be documented and communicated throughout the certificate holder organization.
(d) The safety policy must be regularly reviewed by the accountable executive to ensure it remains relevant and appropriate to the certificate holder.
Par 3-3 Page 13 safety policy statement can be found in Appendix 3, Sample Safety Policy Statement.
Section 5.21(a)(1) requires carriers to develop safety objectives as part of their safety policy. The assessment process required by § 5.73 is where decisions are made regarding attainment of these objectives. In setting these objectives, this is a case where “starting with the end in sight” is sound advice. Objectives can fall into a number of categories, including:
• Compliance with regulations. Compliance with all regulations is an expectation for all carriers and assurance of such compliance is an explicit requirement of the SMS (refer to § 5.3(b)).
• Milestones for implementation of safety-related programs or initiatives.
• Reduction of error or incident rates.
• Tracking of safety events. Certain events such as ground damage, pilot deviations, weight and balance errors, or maintenance errors may be targets for safety objectives and associated tracking and action. One caution with these types of measures is not to lose focus on risk factors that may be associated with potentially more serious events.
(6) Scalability. Safety policies would not be expected to vary between small, medium, and large organizations; however, the levels of management involved in preparation and implementation of the policy may vary.
(a) Small. The owner or most senior manager (the accountable executive) may personally perform this process. The policy can be a simple, often single-page, written document, signed by the accountable executive. Small organizations typically operate in smaller networks of employees, so the policy may be posted in company work areas or included in company briefings or in training.
(b) Medium. The accountable executive, with the involvement of other senior managers, is likely to develop, publish, and communicate the safety policy. The policy may be disseminated via company newsletters, company Web sites, employee briefings, or existing indoctrination and recurrent training.
(c) Large. A large organization may require the accountable executive or other senior managers and technical staff to perform this process. While the regulations only require the accountable executive to sign the safety policy, members of senior management may also sign the safety policy. Large carriers may disseminate their policy using a variety of resources such as company Web sites, intranets, email, or existing indoctrination and recurrent training.
c. Safety, Accountability, and Authority.
(1) SRR. Section 5.23.
(2) Related Regulatory Requirements. Section 5.25 and 14 CFR part 119, § 119.65.
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(3) ICAO/SMSPP. Element 1.2.
(4) Part 5 Requirements.
(5) Discussion. This SMS process requires defined accountability for achieving safety performance objectives within the organization’s safety policy for the following individuals:
NOTE: “Accountability” as used here, refers to active management and line employee involvement and action in managing and maintaining safety performance. A certificate holder defines accountability by ensuring that each of its management and line employees is aware of his or her specific role within SMS and actively participates in carrying out his or her SMS-related duties. Once the accountabilities for these employees have been defined, Subpart D (Safety Promotion) requires that these accountabilities be communicated throughout the organization.
(a) Accountable Executive. The accountable executive has the ultimate responsibility for safety management within the organization. The specific duties of the accountable executive are discussed in more detail in the discussion of § 5.25 below.
(b) All Members of Management. Managers are the individuals who are responsible for identifying hazards, conducting risk assessments, and developing risk controls for their areas of responsibility. They have the technical expertise and are the ones responsible for implementation and operation of risk controls (often in the form of operational procedures, specified tools, training, communication, etc.). A key element in your SRM process is to identify the levels of management with the authority to make risk decisions related to aviation safety.
Thus, managers that have the authority to implement changes in systems and procedures must use the SMS processes in managing their area of operational responsibility. They are also responsible for assuring the continuing operational safety of risk controls. Through data collection methods and analytical processes in the SA component, managers are able to determine that risk controls are effective and that their safety performance is acceptable. For example, the Director of Maintenance (DOM) is one of the managers accountable for SMS within his or her area of responsibility.
§ 5.23 Safety accountability and authority.
(a) The certificate holder must define accountability for safety within the organization’s safety policy for the following individuals:
(1) Accountable executive, as described in § 5.25.
(2) All members of management in regard to developing, implementing, and maintaining SMS processes within their area of responsibility, including, but not limited to:
(i) Hazard identification and safety risk assessment.
(ii) Assuring the effectiveness of safety risk controls.
(iii) Promoting safety as required in subpart E of this part.
(iv) Advising the accountable executive on the performance of the SMS and on any need for improvement.
(3) Employees relative to the certificate holder’s safety performance.
(b) The certificate holder must identify the levels of management with the authority to make decisions regarding safety risk acceptance.
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(c) Employees. All employees should be aware of the company’s safety policies, as well as the processes, procedures, and tools relevant to their responsibilities. They need to know how the confidential employee reporting system works. Employees have a duty and responsibility to follow an organization’s processes and procedures.
(6) Scalability. The method for meeting these requirements is not expected to vary greatly between different organizations. Rather, the numbers and relationships of personnel will be unique to each organization.
d. Designation and Responsibilities of Required Safety Management Personnel. This section of the regulation addresses two processes: (1) Designation and Responsibilities of the Accountable Executive, and (2) Designation and Responsibilities of Safety Management Personnel.
(1) Designation and Responsibilities of the Accountable Executive.
(a) SRR. Sections 5.25(a) and (b).
(b) Related Regulatory Requirements. None.
(c) ICAO/SMSPP. Element 1.3.
(d) Part 5 Requirements.
(e) Discussion.
1. Designation. Section 5.25(a) requires the organization to identify an alreadyexisting person in the organization who holds the ultimate decisionmaking authority over the § 5.25 Designation and responsibilities of required safety management personnel.
(a) Designation of the accountable executive. The certificate holder must identify an accountable executive who, irrespective of other functions, satisfies the following:
(1) Is the final authority over operations authorized to be conducted under the certificate holder’s certificate(s).
(2) Controls the financial resources required for the operations to be conducted under the certificate holder’s certificate(s).
(3) Controls the human resources required for the operations authorized to be conducted under the certificate holder’s certificate(s).
(4) Retains ultimate responsibility for the safety performance of the operations conducted under the certificate holder’s certificate.
(b) Responsibilities of the accountable executive. The accountable executive must accomplish the following:
(1) Ensure that the SMS is properly implemented and performing in all areas of the certificate holder’s organization.
(2) Develop and sign the safety policy of the certificate holder.
(3) Communicate the safety policy throughout the certificate holder’s organization.
(4) Regularly review the certificate holder's safety policy to ensure it remains relevant and appropriate to the certificate holder.
(5) Regularly review the safety performance of the certificate holder’s organization and direct actions necessary to address substandard safety performance in accordance with § 5.75.
Par 3-3 Page 16 certificate holder’s operations. This person is responsible for planning, organizing, directing, and controlling the personnel, organizational structure, financial, and other resources necessary for safe flight operations. A flowchart outlining a process for designating an accountable executive is available in Appendix 4, Identifying the Accountable Executive.
2. Responsibilities. As the ultimate authority in the organization, the accountable executive is responsible for the proper functioning of the SMS. This entails, among other things, keeping an open line of communication with the designated management personnel, providing sufficient resources for the SMS to function properly, and being actively involved in the SA component of SMS, discussed below.
3. Scalability. In smaller organizations, the accountable executive may personally participate in or directly supervise operational processes. This individual may serve in multiple positions within the company. In larger organizations, the accountable executive is responsible for ensuring that management personnel are clearly designated for ensuring the safety of operational and safety management processes.
(2) Designation and Responsibilities of Required Safety Management Personnel.
(a) SRR. Section 5.25(c).
(b) Related Regulatory Requirements. None.
(c) ICAO/SMSPP. Element 1.3.
(d) Part 5 Requirements.
(e) Discussion. This section of the regulation requires the company to ensure that sufficient personnel are available to provide support for essential SMS functions, such as analysis, assistance to operational managers in meeting their safety management responsibilities, and acting as a safety advisor to the accountable executive. These responsibilities may be carried out as collateral duties by managers referred to in § 5.23(a)(2), or the carrier could assign the tasks of supporting SMS functions to other personnel. For example some organizations may choose to use their existing required management personnel under § 119.65 to fulfill these responsibilities. Other organizations may organize a Safety Department with a number of persons or use existing personnel within each operational division.
§ 5.25 Designation and responsibilities of required safety management personnel.
(c) Designation of management personnel. The accountable executive must designate sufficient management personnel who, on behalf of the accountable executive, must be responsible for the following:
(1) Coordinate implementation, maintenance, and integration of the SMS throughout the certificate holder’s organization.
(2) Facilitate hazard identification and safety risk analysis.
(3) Monitor the effectiveness of safety risk controls.
(4) Ensure safety promotion throughout your organization as required in subpart E of this part.
(5) Regularly report to the accountable executive on the performance of the SMS and on any need for improvement.
Par 3-3 Page 17 NOTE: The final rule preamble states: “Personnel designated to perform this function must be in positions in the organization of sufficient independence to have direct access to the accountable executive to report on the safety performance of the operation and recommend and necessary improvements.”
e. Coordination of Emergency Response Planning.
(1) SRR. Section 5.27.
(2) Related Regulatory Requirements. None.
(3) ICAO/SMSPP. Element 1.4.
(4) Part 5 Requirements.
(5) Discussion. The plan should provide procedures for management decisionmaking and action in an emergency. This should include a line of succession of management authority sufficient to respond to emergencies. Coordination of your emergency response plans with the emergency response plans of other organizations might include first responders to accidents or incidents, airport authorities, and hazardous materials (hazmat) authorities. The plan might also address how you return or transition to normal operations after the emergency condition subsides. Many organizations already have emergency response plans that may be used to fulfill this requirement.
3-4. SUBPART C: SAFETY RISK MANAGEMENT.
a. Introduction.
(1) SRR. Part 5, subpart C.
(2) Related Regulatory Requirements. Section 5.23(a)(2).
(3) ICAO/SMSPP. Component 2.0.
(4) Summary. SRM is a formal system for identifying and mitigating risk. There are five processes necessary to control and mitigate risk. These processes are featured in Figure 3-1, Safety Risk Management Processes and Regulatory Requirements, and are discussed in more detail below. These are:
§ 5.27 Coordination of emergency response planning.
Where emergency response procedures are necessary, the certificate holder must develop and the accountable executive must approve as part of the safety policy, an emergency response plan that addresses at least the following:
(a) Delegation of emergency authority throughout the certificate holder’s organization;
(b) Assignment of employee responsibilities during the emergency; and
(c) Coordination of the certificate holder’s emergency response plans with the emergency response plans of other organizations it must interface with during the provision of its services.
• System description and analysis.
• Hazard identification.
Safety risk analysis.
Safety risk assessment.
• Safety risk controls.
FIGURE 3-1. SAFETY RISK MANAGEMENT PROCESSES AND REGULATORY
REQUIREMENTS Start Inputs: 5.51 5.53 System SRM •New System
•System Change Analysis & (Subpart c) Analysis System 5.53(a) &(b) •New Operational Procedure Hazard (Design) - Inputs From SA: 5.73(6) Identification Hazard
5.53(c) Ident Risk 5.55 Risk Analysis 5.55(a) Assessment & Control
5.55(b) Risk Outputs: To SA Subpart D Assmt Evaluate Controls
5.55(d) Risk Control 5.55(c)
b. Applicability: Requirements to Apply SRM.
(1) SRR. Section 5.51.
(2) Related Regulatory Requirements. None.
(3) ICAO/SMSPP. Component 2.0.
(4) Objective. To determine situations where the SRM process must be applied.
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(5) Part 5 Requirements.
(6) Discussion.
(a) To know when SRM process may be required, it is important to know what a system is. Systems could be people, hardware, software, information, procedures, facilities, services, and other support facets which are directly related to the organization’s aviation safety activities. Examples of broad-based systems could include:
• Flight operations,
• Operational control (dispatch/flight following),
• Maintenance and inspection,
• Cabin safety,
• Ground handling and servicing,
• Cargo handling, and
• Training.
(b) Within these systems there are subsystems. Some examples of subsystems include crew scheduling systems, training curricula, maintenance control, deicing, fueling, aircraft fleet, ground operations, and hazmat training.
(c) Under § 5.51, the SRM process is triggered when proposed new systems or changes to systems are being considered. For example, changes to your operation could include the addition of new routes, opening or closing of line stations, adding or changing contractual arrangements for services, additions of new fleets or major modifications of existing fleets, addition of different types of operations such as Extended Operations (ETOPS), or any one of many different types of operations. The SRM process is not triggered solely by major changes to a system; it is triggered by any revision of an existing system. However, the level of SRM documentation needed for smaller changes to a system may be significantly smaller than for major changes.
NOTE: It is not the intent of part 5 to require the application of SRM processes and procedures to activities that are not related to aviation operations.
c. System Analysis and Hazard Identification. This section of the regulation addresses the following two processes: (1) System Description and Analysis, and (2) Hazard Identification.
§ 5.51 Applicability A certificate holder must apply safety risk management to the following:
(a) Implementation of new systems.
(b) Revision of existing systems.
(c) Development of operational procedures.
(d) Identification of hazards or ineffective risk co ntrols through the safety assurance processes in subpart D of this part.
Par 3-4 Page 20 NOTE: Appendix 2, Safety Risk Management (SRM) Worksheets, contains a set of worksheets that may be useful for conducting SRM.
(1) System Description and Analysis.
(a) SRR. Section 5.53(a) and (b).
(b) Related Regulatory Requirements. None.
(c) ICAO/SMSPP. Element 2.1/Process 2.1.1.
(d) Objective. To gain an understanding of the components and elements of operational systems, processes, procedures and the operational environment.
(e) Part 5 Requirements.
(f) Discussion. Systems analysis is the primary means of proactively identifying and addressing potential problems before the new or revised systems or procedures are put into place. The system analysis should explain the functions and interactions among the hardware, software, people, and environment that make up the system in sufficient detail to identify hazards and perform risk analyses. The process is started by describing the system (this can be as simple as flowcharting the system or writing a short narrative).
1. An example of system description and analysis might involve the need in your operations for a new aircraft (or fleet of aircraft) to meet your company or corporate goals.
Several of your organizational “systems” would be affected: flight operations, maintenance, station, ground, etc. As part of your examination of the flight operations system, you would need to consider changes to pilot qualifications, pilot and mechanic training, scheduling, crew rest, union participation, and several other areas. This is a process normally done as part of your business activities.
2. Your system analysis should identify and consider activities and resources necessary for the system to function. For example, in the scenario of adding aircraft to your fleet, you would identify for the pilot training system, as one of the affected systems, the activities and resources necessary for pilot training to pilot the additional aircraft. These may include simulators, training curriculum, training aids, and instructors.
§ 5.53 System analysis and hazard identification.
(a) When applying safety risk management, the certificate holder must analyze the systems identified in § 5.51. Those safety analyses must be used to identify hazards under paragraph (c) of this section, and developing and implementing risk controls related to the system under § 5.55(c).
(b) In conducting the system analysis, the following information must be considered:
(1) Function and purpose of the system.
(2) The system’s operating environment.
(3) An outline of the system’s processes and procedures.
(4) The personnel, equipment, and facilities necessary for operation of the system.