3-1 CHAPTER 3. IMPLEMENTATION: BUILDING A SAFETY MANAGEMENT SYSTEM (SMS)
3.1 Process Overview. There are several steps to developing and implementing an SMS that is compliant with part 5 (ref §§ 5.11, 5.13, 5.15):
• Required: Develop an organizational system description.
• Recommended: Complete a gap analysis to identify the areas where your organization complies with part 5 and where changes are required.
• Required: Develop and submit an SMS implementation plan to the FAA for approval.
• Required: Develop the necessary policies, processes, procedures, and systems to comply with part 5 and your implementation plan.
• Required: Implement the SMS in accordance with part 5 and your implementation plan.
3.1.1 Develop an Organizational System Description. Follow the guidance in paragraph
2.2.10 of this AC (ref § 5.17) to develop your organizational system description.
3.1.2 Gap Analysis. A gap analysis involves analyzing and assessing your existing programs, systems, processes, and activities with respect to SMS requirements found in part 5.
Most certificate holders have many of the elements of part 5 in their current processes, although those processes may not entirely fulfill the part 5 requirements. For example, the current processes may be limited in scope (i.e., do not cover the entire organization) and/or interoperability (i.e., do not interface sufficiently to form a “system”). If you determine that a process in your organization satisfies one or more part 5 requirements, your analysis should document how that process meets the requirements. You may document how you meet certain part 5 requirements by referencing the processes or procedures where the requirements are discussed. Your gap analysis should identify the additional policies, processes, and procedures you need to develop to fully comply with part 5.
3.1.3 Develop and Submit an Implementation Plan. Follow the guidance in paragraph 2.2.11 of this AC (ref § 5.19) to develop your implementation plan, and in paragraphs 2.2.7,
2.2.8, or 2.2.9 of this AC (ref §§ 5.11, 5.13, or 5.15) to submit your implementation plan for FAA approval.
3.1.4 Develop the Policies, Processes and Procedures to Comply with Part 5. Develop the necessary policies, processes, and procedures in accordance with the implementation plan (ref §§ 5.11, 5.13, or 5.15).
3.1.5 Implement the SMS. Follow the guidance in paragraphs 2.2.7, 2.2.8, or 2.2.9 of this AC (ref §§ 5.11, 5.13, or 5.15) to implement the SMS in accordance with your implementation plan.
1 APPENDIX A. GUIDANCE FOR DEVELOPING A SAFETY POLICY A.1 Safety Policy.
The safety policy must meet the requirements in § 5.21 and be signed by the accountable executive. References (i.e., “pointers” to other manuals which provide guidance how each requirement is to be met) could be embedded in the safety policy. It is important to remember the safety policy is unique to your organization and should be developed to meet the specific needs, activities, and structure of your organization. A safety policy is a document that states what your organization will do and how its employees are expected to act.
A.1.1 A sample safety policy is included in Paragraph A.2.
A.1.2 Reserved.
2 A.2 Sample Safety Policy.
Safety is one of our core functions and an effective safety management system (SMS) is vital to the success and longevity of [company name]. We are committed to implementing, maintaining, and continuously improving a fully functional SMS to ensure that the safety of our products and services are our highest priority.
All employees, starting with the [title of the Accountable Executive], are accountable for supporting our organization’s ultimate goal to achieve the highest level of safety performance of the products and services we provide.
At [company name], we are committed to:
• Supporting the management of safety through the provision of all necessary resources to establish and maintain a fully functional SMS.
• Establishing safety objectives that are available for all employees to review in the [location of objectives]. We will ensure that our safety objectives are monitored, measured, and tracked to ensure they are fulfilled.
• Regularly reviewing the safety performance of our organization and directing actions necessary to address substandard safety performance.
• Encouraging employees to disclose safety concerns without fear of reprisal and ensuring that no action will be taken against any employee who discloses a safety concern through the confidential employee reporting system.1 Specific reporting procedures are located [location of procedures].
• Communicating this safety policy to all employees to ensure each of us is aware of our SMS and safety-related duties and responsibilities.
• Periodically reviewing this safety policy to ensure it remains relevant and appropriate to our organization.
[Signed], Accountable executive [Additional management personnel optional]
1 Activities involving intentional disregard for FAA regulations, company policies and procedures, illegal activities, and/or drugs or alcohol may be subject to disciplinary action.
Appendix B B-1 APPENDIX B. IDENTIFYING THE ACCOUNTABLE EXECUTIVE B.1 Identifying the Accountable Executive Flowcharts. The following flowcharts provide a series of questions to assist you with the selection of your organization’s accountable executive:
• Figure B-1, Accountable Executive Decision Process
• Figure B-2, Verifying the Accountable Executive B.1.1 Figure B-1 identifies different organizational structures and how those structures may determine the accountable executive. These flowcharts cannot address all possible organizational structures.
B.1.2 Once you have identified the accountable executive, the questions in Figure B-2 will assist you in verifying that the person in the selected position is the correct choice. All questions must receive a “yes” answer as they are validating the requirements of part 5 and § 5.25(a). Should any of the questions result in a “no” answer, you should start the selection process again with a new candidate.
Appendix B Figure B-1. Accountable Executive Decision Process Accountable Executive Decision Process Confirm selection Is the organization a sole proprietor ship? Yes Proprietor is Accountable Executive by answering the questions on Figure B-2 Accountable Executive Proprietor is No Accountable Executive Is the Nominate a Confirm selection organization a partnership partner as by answering the between Accountable questions on individuals? Yes Executive Figure B-2 No Nominated partner is Accountable Executive controlled by a organization Is the appointed a CEO or Has the Board Confirm selection by answering the Directors? Board of equivalent to manage the organization? questions on Figure B-2 No CEO is Accountable Executive Chairman of Board is Accountable Executive Who in the What is the most organization senior position in holds this the company? position?
If a clear selection cannot be made, No Confirm Yes organization and re-evaluate by answering selection Accountable Executive Identified person is begin process the questions again on Figure B-2 B-2
Appendix B Figure B-1. Verifying the Accountable Executive Start Identify person by name Select another candidate Does the person have final $5.25 (a) (1) authority over the service provider's operations?
No Yes Does the person control the financial resources required for §5.25 (a) (2) → the service provider's operation?
No Yes Does the person control the human resources required to §5.25 (a) (3) → conduct the service provider's operations? No Yes Does the person retain the ultimate responsibility for the safety §5.25 (a) (4) performance of the service provider's operations? No Yes This person is the Accountable Executive B-3
Appendix C C-1 APPENDIX C. References and Additional Information C.1 Safety Management System (SMS) -Related Websites.
For additional information regarding SMSs, please see the following websites:
• FAA public SMS website at FAA SMS.
• International Civil Aviation Organization (ICAO) Safety Management at website at ICAO Safety Management.
o Annex 19 to the Convention on International Civil Aviation, Safety Management.
o ICAO Document 9859, Safety Management Manual.
C.2 FAA Resources.
Refer to the current version of the following documents at FAA Regulations & Policies or FAA DRS.
• AC 120-92, Safety Management Systems for Aviation Service Providers.
• FAA Order VS 8000.367, Aviation Safety (AVS) Safety Management System Requirements.
• FAA Order 8000.369, Safety Management System.
C.3 Related 14 C FR Regulations.
• You can also obtain a copy of 14 CFR part 5, Safety Management Systems, and other current regulations online from the Federal Register website at Electronic CFR, jointly administered by the Office of the Federal Register (OFR) of the National Archives and Records Administration (NARA) and the U.S. Government Publishing Office (GPO). You can order a paper copy from the U.S. Superintendent of Documents, U.S. Government Publishing Office, Washington, D.C. 20401; at www.gpo.gov, by calling telephone number (202) 512-1800; or by sending a fax to
(202) 512 2250.
• You can also obtain a copy of current regulations, Title 14 CFR Part 5, Safety Management Systems, online at Electronic CFR.
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