(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.
§ 5.21 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.
(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 Par 3-3 Page 12
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.
§ 5.23 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.
(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.
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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.
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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.
§ 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.
(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.
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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.
§ 5.27 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.
(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:
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• 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 System Analysis (Design) Hazard Ident Risk Control Risk Assmt Risk Analysis Start Inputs: 5.51
•New System
•System Change
•New Operational Procedure Outputs: To SA Subpart D Inputs From SA: 5.71(b)
5.53(a)&(b)
5.53(c)
5.55(b)
5.55(c)
5.55(a) Evaluate Controls
5.55(c)(1)
5.53 System Analysis & Hazard Identification
5.55 Risk Assessment & Control SRM (Subpart 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.
§ 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 controls through the safety assurance processes in subpart D of this part.
(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.
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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.
§ 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.
(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.
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3. The above example of adding aircraft to your fleet would entail consideration of several systems and a variety of procedures due to the number of processes that would be affected. However, in a simpler case, such as a change in the procedure for arming cabin doors prior to pushback, only those elements of the systems that would be affected by the change would need to be considered. The carrier would not be expected to perform a comprehensive analysis of the entire cabin safety system.
4. The system description and analysis process frequently includes representatives from management, safety staff, subject matter experts (SME), employees, and representation groups (e.g., unions) formed into 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.
5. The outputs could be recorded in a simple recording medium such as a worksheet or a notebook, common desktop software, or a Web-Based Application Tool (WBAT), (see Appendix 6). Appendix 2 provides an example of a set of worksheets that could be used as paper records or converted to a variety of software applications, including desktop spreadsheets or WBATs.
(g) Scalability.
1. Small. System description and 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.
2. Medium. System description and analysis could be performed by a member of management or one of the designated SMS management representatives with a small workgroup of company SMEs and stakeholders.
3. Large. System description and analysis might be performed at multiple organizational levels (e.g., corporate, division, or department) and facilitated by the Safety Department/division or its equivalent. The organization might have standing committees of SMEs and stakeholders participating at various levels.
(2) Hazard Identification.
(a) SRRs. Section 5.53(c).
(b) Related Regulatory Requirements.
• Section 5.23(a)(2)(i), Accountabilities of Members of Management.
• Section 5.25(c)(2), Responsibilities of Safety Management Personnel.
(c) ICAO/SMSPP. Element 2.1/Process 2.1.2.
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(d) Objective. To examine operational systems, operations, processes, and the operational environment in order to identify conditions that could result in an aircraft accident.
(e) Part 5 Requirements.
§ 5.53 System analysis and hazard identification.
(c) The certificate holder must develop and maintain processes to identify hazards within the context of the system analysis.
(f) Discussion. The hazard identification process flows from the system analysis. In hazard identification, you would ask: What could go wrong with your processes, under typical or abnormal operational conditions, that could cause an accident?
1. Most often the same individuals or groups conducting the system analysis process (safety committees, safety roundtables, etc.) would conduct hazard identification. You use your experience, FAA requirements, manufacturers’ technical data, and knowledge of your operations to identify hazards to your operation. For example, a newly modified component of an aircraft cabin door might require new arming and disarming procedures by flight attendants and new signaling procedures for station personnel upon aircraft arrival at a passenger gate.
Hazards could include the effectiveness of new procedure training, employees missing training, failing to read or understand newly published procedures, supervisors failing to monitor the new procedures, etc. While identification of every conceivable hazard is unlikely, you are expected to exercise due diligence in identifying hazards that could foreseeably lead to an aircraft accident.
2. The output of hazard identification could be recorded in a simple recording medium such as a spreadsheet or paper files, or software such as a WBAT.
(g) Scalability.
1. Small. Hazard identification could be performed by the owner/manager and/or another employee(s), often as part of the system analysis.
2. Medium. As in the system analysis, hazard identification could be performed by a member of management or a designated SMS management representative with a small workgroup of company SMEs and stakeholders.
3. Large. Hazard identification might be performed at multiple organizational levels (e.g., corporate, division, or department levels) and facilitated by a Safety Department/division or its equivalent. The organization might have standing committees of SMEs and stakeholders participating at various levels.
d. Safety Risk Analysis and Control. This section of the regulation addresses the following three processes: (1) Safety Risk Analysis, (2) Safety Risk Assessment, and (3) Safety Risk Control.
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