交 通 民 部 民 航 用 航 通 空 局 告 主旨:安全管理系統 發行日期:2011.01.25 編號:AC 120-032C 發行單位:飛航標準組 一、目的: 本通告之目的係介紹安全管理系統(SMS Safety Management System) 之概念,並提供航空業者建構安全管理系統之指引。安全管理系統為 我國 07-02A「航空器飛航管理規則」第 9 條及 06-02A「維修廠設立 檢定管理規則」第 27 條之需求,航空器使用人依據本通告建構之安 全管理系統及據此規範所實施之安全管理作為,可滿足前揭法規之需 求。 二、修正說明: (一)為配合第一次修訂,本局參考 ICAO Doc 9422 及 UK CAA CAP 712 (Safety Management System for Commercial Air Transport Operations)作文字修訂,取消 AC120-32 版。並取代民國 93 年 9 月 16 日訂定之 AC 120-032。 (二)為配合第二次修訂,本通告係參考美國 FAA AC120-92 訂定。 並取代民國 95 年 9 月 27 日訂定之 AC 120-032A。 (三)為配合第三次修訂,本通告係參考 ICAO Doc 9859 Safety Management Manual (SMM) 訂定,並取代民國 96 年 3 月 12 日 訂定之 AC 120-32B。 三、背景說明: 1 現代之航空事業為富有更具多變性及複雜商業網路之特殊管理機 構,在快速變遷之航空營運環境中,此等機構仍必須持續適應以保持 生存。雖極少數之商業個體、市場、供應網及其作業仍僅限於本國內, 惟航空事業更趨向於全球化已是無法避免之事實,亦因此該等複雜、 多元及改變之特性更突顯了良好的安全管理之重要性。截至目前為 止,致力於航空安全方面之努力還算相當成功,然在航空市場營運量 及種類快速增加之趨勢下,現有之安全策略及作為仍有必要繼續提 升。在此趨勢下,業者及政府機構可使用之資源將顯不足,因此尋求 未來之安全策略至為重要。在增加航空活動及減少資源問題中最佳的 解決方法是,將安全管理融入飛航作業之正常管理架構中,以達到應 有之安全成效。政府及業者必須將其作有效之管理,以完成其使命並 達成事業永續經營之目標。 『安全管理系統』為創新之名詞,為政府 及業者在監理與事業管理上最佳溝通語言,亦為提升安全最有效之方 法。 (一)安全管理系統之安全效益:安全管理系統為高品質及控制風險 管理之必要措施,其組織架構得以提供支援良好之安全文化, 可為公司安全管理之主軸,亦為與民航局之有效溝通介面,同 時提供公司管理階層監控安全相關流程之詳細路徑。 (二)安全管理系統之商業效益:建構及實施安全管理系統使航空業 者符合法規需求之安全管理架構;藉由安全管理系統融合內部 評鑑及品質保證理念,形成更佳之管理結構及持續改善作業流 程,可獲得明顯之商業效益。本通告所提出之理念已將各種安 全努力融合於航空業者之商業模式中,且融合現行航空業者已 具備或正在建立之品管、職場安全及環境控制系統中。 四、需求說明: ICAO Annex 6, Part I 3.2.5 07-02A「航空器飛航作業管理規則」第 9 條『航空器使用人應建立安 全管理系統並經報請民航局備查後,於中華民國 98 年 1 月 1 日前實 施』 。 06-02A「維修廠設立檢定管理規則」第 27 條『維修廠應建立安全管 2 理系統並經報請民航局備查後,於中華民國 98 年 1 月 1 日前實施』 。 五、執行要點說明: 有關安全管理系統之建構及施行說明,詳如附錄。 六、相關規定及參考文件: (一)FAA AC 120-66「Aviation Safety Action Programs(ASAP)」及 後續更新版本。 (二)FAA AC 120-79「Developing and Implementation a Continuing Analysis and Surveillance System(CASS)」及後續更新版本。 (三)FAA AC 120-82「Flight Operation Quality Assurance」及後續更 新版本。 (四)ICAO Doc 9859「Safety Management Manual (SMM)」及後續更 新版本。 (五)UK CAA「Safety Management Systems-Guidance to Organizations」及後續更新版本。 簽署:________________ 飛航標準組組長張羚悌 3 附錄 安全管理系統之建構及施行說明 AC 120-32C Safety Management System 25 January, 2011 1 Table of Contents 1. GENERAL 1.1 Purpose…………………………………………………………………….. 2 1.2 Requirements and References…………………………………………… 2 1.3 Definitions…………………………………………………………………... 2 1.4 Introduction………………………………………………………………… 3 - 2. - Management Systems………………………………………………… Quality Management System………………………………………… 3 3 - Safety Management System…………………………………………. 4 - Gap analysis…………………………………………………………… 4 - Safety Management System Implementation……………………… 5 SAFETY POLICY AND OBJECTIVES 2.1 Management commitment and responsibility………………………….. 7 2.2 Safety accountabilities……………………………………………………. 9 2.3 Appointment of key safety personnel……………………………………. 10 2.4 Coordination of emergency response planning………………………… 13 2.5 SMS documentation………………………………………………………. 13 3. 4. 5. SAFETY RISK MANAGEMENT 3.1 Hazard identification……………………………………………………….. 16 3.2 Safety risk assessment and mitigation…………………………………… 19 SAFETY ASSURANCE 4.1 Safety performance monitoring and measurement…………………….. 26 4.2 The management of change………………………………………………. 27 4.3 Continuous improvement of the SMS…………………………………….. 28 SAFETY PROMOTION 5.1 Training and education……………………………………………………… 29 2 5.2 Safety communication………………………………………………………. 30 ATTACHMENT 1 SMS IMPLEMENTATION PLAN……………………………….. 32 ATTACHMENT 2 SMS GAP ANALYSIS CHECK LIST…………………………... 42 ATTACHMENT 3 GLOSSARY………………………………………………………….. 51 3 1. GENERAL 1.1 Purpose This AC has been developed to give sufficient understanding on SMS concepts and the development of management policies and processes to implement and maintain an SMS that meets ICAO and CAA requirements. This AC presents an acceptable means, but not the only means, to show compliance with Article 9 of “Aircraft Flight Operation Regulations” or Article 27 of “Regulations for Repair Station Certification and Management” for establishing and implementing a safety management system. This AC applies to all Civil air transport enterprise certificate holders (Operator) and repair station certificate holders of CAA, Taiwan. 1.2 Requirements and References - 01-01A Civil Aviation Act - 06-02A Regulations for Repair Station Certification and Management - 07-02A Aircraft Flight Operation Regulations - CAA State Safety Program, SSP - CAA AC 00-001A - ICAO Safety Management Manual (Doc 9859 2nd edition) - ICAO Annex 1 - ICAO Annex 6 - ICAO Annex 8 1.3 Definitions The following definitions are used in this document: Safety The state in which the possibility of harm to persons or of property damage is reduced to, and maintained at or below, an acceptable level through a continuing process of hazard identification and safety risk management. Hazard is defined as a condition or an object with the potential to cause injuries to personnel, damage to equipment or structures, loss of material, or reduction of ability to perform a prescribed function. Safety risk is defined as the assessment, expressed in terms of predicted probability and severity, of the consequences of a hazard, taking as reference the worst foreseeable situation Safety risk management is a generic term that encompasses the assessment and mitigation of the safety risks of the consequences of hazards that threaten the capabilities of an organization, to a level as low as reasonably practicable (ALARP). Level of safety is the degree of safety of a system. It represents the quality of the system, safety-wise. It is expressed through safety indicators; 4 Safety indicators are the parameters that characterize and/or typify the level of safety of a system; Safety targets are the concrete objectives of the level of safety; Acceptable level of safety is the minimum degree of safety that must be assured by a system in actual practice; Safety measurement refers to the quantification of the outcomes of selected high-level, high-consequence events, such as accident and serious incident rates. Safety performance measurement refers to the quantification of the outcomes of selected low-level, low consequence processes. It is a non-stop activity, involving continuous monitoring and measurement, by an organization. Safety Assurance means a process of examining an organization’s SMS and evaluating its effectiveness, based on the SMS components and elements. This extends from an evaluation for regulatory compliance; Organization when used alone means all functions of service provision of the aircraft operators and repair station certificate holders. Safety Management System (SMS) means documented processes for managing risk that integrates operations and technical systems with the management of financial and human resources as well as infrastructure and technology, to ensure aviation safety or the safety of the public. 1.4 Introduction Management Systems Aviation organizations are required to develop, implement and operate a number of different management systems to achieve their production goals through the delivery of services. Typical management systems an aviation organization might need to operate include quality management system (QMS), environment management system (EMS), occupational health and safety management system (OHSMS), safety management system (SMS), and security management system (SEMS). Since it is beneficial for the aviation organizations to integrate all these different management systems, there is a developing tendency in civil aviation to such integration. Aviation organizations should be encouraged to integrate their quality, safety, security, occupational health and safety, and environmental protection management systems. Quality Management System Quality management has been established in many segments of the aviation system for a long time. Many aviation organizations have implemented and operated quality control (QC) and/or quality assurance (QA) for a number of years. A few aviation organizations have integrated their QC and QA programs into quality management systems (QMS). SMS and QMS share many commonalities. They both: 5 (a) have to be planned and managed; (b) (c) depend upon measurement and monitoring; involve every function, process and person in the organization; and (d) strive for continuous improvement. SMS differs from QMS in that: (a) SMS focuses on the safety, human and organizational aspects of an organization (i.e. safety satisfaction); while (b) QMS focuses on the products and services of an organization (i.e. customer satisfaction). Once commonalities and differences between SMS and QMS have been established, it is possible to establish a synergistic relationship between both systems. To summarize: (a) SMS builds partly upon QMS principles; (b) SMS should include both safety and quality policies and practices; and (c) The integration of quality principles, policies and practices should be focused towards the support of the management of safety. Safety Management System A Safety Management System (SMS) is a systematic, explicit and proactive process for managing safety that integrates operations and technical systems with financial and human resource management to achieve safe operations with as low as reasonably practicable risk. SMS is a proactive and integrated approach to Safety. It should be integrated into the management system of an organization. It should describe the structure and scope of the organization, available resources, staff accountabilities, authorities and responsibilities and how decisions are taken and managed throughout the organization. By identifying, assessing and eliminating or controlling safety-related hazards and risks, acceptable levels of safety will be achieved. Gap analysis It is apparent that organizations would need to conduct a gap analysis of their system(s) to determine which components and elements of a safety management system are currently in place and which components or elements must be added or modified to meet SMS as well as regulatory requirements. The review may include comparison of the SMS elements found in this AC against the existing systems in your organization. A checklist may be used to account for each of this AC and their respective sub- elements or an example of a gap analysis checklist in Attachment 2. Remarks for partial compliance or deviations should be made as well as actions required in order to meet the criteria. There should be a column for 6 annotating existing company documentation where the requirement is addressed. Once the gap analysis is complete and fully documented, the items you have identified as missing or deficient will form the basis of your SMS project plan. The first target of the plan should be compilation of the organization’s SMS manual. Safety Management System Implementation An aviation organization should, as part of the SMS documentation, develop, adhere to and maintain an SMS implementation plan. This SMS implementation plan shall be endorsed by senior management of the organization. The SMS implementation plan shall be the definition of the approach the organization will adopt for managing safety in a manner that will meet the organization’s safety objectives. The SMS implementation plan shall explicitly address the coordination between the SMS of the aviation organization and the SMS of other organizations the aviation organization must interface with during the provision of services. The first step in the development of any successful SMS is to identify what elements currently exist within an organization, this can be achieved by carrying out a thorough gap analysis of the current business, from which an implementation plan can be developed and delivered. Attachment 1 of this AC presents a phased-in approach to develop an SMS implementation. Phases I &II should be completed by June 30, 2011. Phase III should be completed by June 30, 2012. Phase IV should be completed by December 31, 2012. The contents of the implementation plan should include: (a) Safety policy and objectives; (b) System description; (c) Gap analysis; (d) SMS components; (e) Safety roles and responsibilities; (f) Safety reporting policy; (g) Means of employee involvement; (h) Safety performance measurement; (i) Safety communication; (j) Safety training and (k) Management review of safety performance The framework for the implementation and maintenance of a safety management system must include, as a minimum, the following 4 components and twelve elements: 7 Safety Policy and Objectives - Management commitment and responsibility Safety accountabilities Appointment of key safety personnel Coordination of emergency response planning SMS documentation Safety Risk Management - Hazard Identification - Safety risk assessment and mitigation Safety Assurance - Safety performance monitoring and measurement - The management of change - Continuous improvement of the SMS Safety Promotion - Training and education - Safety Communication 8 2. 2.1 SAFETY POLICY AND OBJECTIVES Management commitment and responsibility Safety Policy An aviation organization shall identify an Accountable Executive to be responsible and accountable on behalf of the aviation organization for meeting the requirements of this regulation. The Accountable Executive should have full responsibility and accountability for the SMS and should have: (a) Full authority for human resources issues; (b) Authority for major financial issues; (c) Direct responsibility for the conduct of the organization’s affairs; (d) Final authority over operations under certificate; and (e) Final responsibility for all safety issues. An aviation organization shall define the organization’s safety policy which shall be in accordance with international and national requirements, and which shall be signed by the Accountable Executive of the organization. The safety policy shall reflect organizational commitments regarding safety; shall include a clear statement about the provision of the necessary resources for the implementation of the safety policy; and shall be communicated, with visible endorsement, throughout the organization. The safety policy shall include the safety reporting procedures; shall clearly indicate which types of operational behaviors are unacceptable; and shall include the conditions under which disciplinary action would not apply. The safety policy shall be periodically reviewed to ensure it remains relevant and appropriate to the organization. In preparing a safety policy, senior management should consult widely with key staff members in charge of safety-critical areas. Consultation ensures that the document is relevant to staff and encourages buy-in to the safety policy. An example of a safety policy is included in Figure 2-1. The safety policy must include a commitment to: (a) achieve the highest safety standards; (b) observe all applicable legal requirements and international standards, and best effective practices; (c) provide all appropriate resources; (d) enforce safety as a primary responsibility of all managers; and (e) ensure that the policy is understood, implemented and maintained at all levels. 9 SAFETY POLICY STATEMENT Safety is one of our core business functions. We are committed to developing, implementing, maintaining and constantly improving strategies and processes to ensure that all our aviation activities take place under a balanced allocation of organizational resources, aimed at achieving the highest level of safety performance and meeting national and international standards, while delivering our services. All levels of management and all employees are accountable for the delivery of this highest level of safety performance, starting with the [chief executive officer (CEO)/managing director/or as appropriate to the organization]. Our commitment is to: - Support the management of safety through the provision of all appropriate resources, that will result in an organizational culture that fosters safe practices, encourages effective safety reporting and communication, and actively manages safety with the same attention to results as the attention to the results of the other management systems of the organization; - Enforce the management of safety as a primary responsibility of all managers and employees; - Clearly define for all staff, managers and employees alike, their accountabilities and responsibilities for the delivery of the organization’s safety performance and the performance of our safety management system; - Establish and operate hazard identification and risk management processes, including a hazard reporting system, in order to eliminate or mitigate the safety risks of the consequences of hazards resulting from our operations or activities to a point which is as low as reasonably practicable (ALARP); - Ensure that no action will be taken against any employee who discloses a safety concern through the hazard reporting system, unless such disclosure indicates, beyond any reasonable doubt, an illegal act, gross negligence, or a deliberate or willful disregard of regulations or procedures; - Comply with and, wherever possible, exceed, legislative and regulatory requirements and standards; - Ensure that sufficient skilled and trained human resources are available to implement safety strategies and processes; - Ensure that all staff are provided with adequate and appropriate aviation safety information and training, are competent in safety matters, and are allocated only tasks commensurate with their skills; - Establish and measure our safety performance against realistic safety performance indicators and safety performance targets; - Continually improve our safety performance through management processes that ensure that relevant safety action is taken and is effective; and - Ensure externally supplied systems and services to support our operations are delivered meeting our safety performance standards. (Signed) ___________________________________ CEO/Managing Director/or as appropriate Figure 2-1 An example of a safety policy 10 Safety Objectives: In conjunction with an organization’s overall safety policy statement, there should be a set of underlying tangible safety objectives. Senior management of the aviation organization must establish safety objectives, as well as the standards of safety performance for the SMS. The safety objectives must identify what the organization wants to achieve, in terms of the management of safety, and lay out the steps the organization needs to take to achieve the objectives. The standards of safety performance allow organizational behavior to be measured in comparison with safety performance and therefore with reference to the management of safety. Both safety objectives and the standards of safety performance must be linked to the safety performance indicators, safety performance targets and action plans of the SMS. Examples of such safety objectives are listed below: - To identify and eliminate hazardous conditions within our aviation related processes and operations - To perform hazard and risk assessment for all proposed new equipment acquisitions, facilities, operations and procedures - To promulgate an ongoing systematic hazard and risk assessment plan. - To provide relevant SMS training/ education to all personnel. - To provide a safe, healthy work environment for all personnel - To minimize accidents/incidents that is attributable to organizational factors - To prevent damage and injury to property and people resulting from our operations - To improve the effectiveness of the safety management system through a yearly safety audit that reviews all aspects of the SMS 2.2 Safety accountabilities The organization should clearly define the lines of safety accountability throughout the organization. This should include the direct accountability for safety on the part of the Accountable Executive and senior management. Safety is everyone’s responsibility and all staff should be aware of their safety roles and responsibilities. The safety accountabilities and responsibilities of all relevant departmental and/or unit managers, and in particular line managers, should be described in the organization’s Safety Management System Manual. It should include an accountability chart in terms of the delivery of safety as a core business process. It must be emphasized that the primary responsibility for safety outcomes rests with those who ‘own’ the production processes. It is here where hazards are directly encountered, where deficiencies in processes contribute to safety risks, and where direct supervisory control and resource allocation can mitigate the safety risks to acceptable levels. The line managers are responsible for the management of an identified safety concern, its mitigation activities and subsequent performance. 11 2.3 Appointment of key safety personnel The successful management of safety is a cooperative responsibility that requires the participation of all relevant management and operational/ support personnel of the organization. The safety roles and accountabilities between the organization’s key SMS personnel and the various functional departments should be established and defined. Whilst the organizational structure of the SMS should reflect the size, nature and complexity of the organization, consideration should be given to the: (a) Appointment of a Safety Manager; (b) Creation of safety committees. The Safety Manager It is important to note that accountability for the SMS lies with the Accountable Executive not the Safety Manager. Specific safety activities and the functional or operational safety performance and outcomes are the responsibility of the relevant operational or functional managers, The Safety Manager is responsible for, and is the focal point for, the development, administration and maintenance of the SMS. The safety manager also must ensure safety promotion throughout the organization. In order to avoid possible conflict of interest, the safety manager should not have conflicting responsibility for any of the operational areas. In principle, integration of aviation safety, occupational safety, quality, environmental control and security is possible. The safety manager should be at a sufficiently high level in the management hierarchy to ensure that he or she can have direct communication with other members of the senior management team. The Safety Manager should be a full-time employee although in a smaller less complex organization it may be a part time role shared with other duties. The Safety Manager should possess: (a) Operational management experience; (b) Technical background to understand the systems that support operations; (c) People skills; (d) Analytical and problem-solving skills; (e) Project management skills; and (f) Oral and written communications skills. The safety manager’s functions include, but are not necessarily limited to: (a) Managing the SMS implementation plan on behalf of the Accountable Executive; (b) Performing/facilitating hazard identification and safety risk analysis; (c) Monitoring corrective actions and evaluating their results; (d) Providing periodic reports on the organization’s safety performance; 12 (e) Maintaining records and safety documentation; (f) Planning and organizing staff safety training; (g) Providing independent advice on safety matters; (h) Monitoring safety concerns in the aviation industry and their perceived impact on the organization’s operations aimed at service delivery; (i) Coordinating and communicating (on behalf of the Accountable Executive) with the State’s oversight authority and other State agencies as necessary on issues relating to safety; and (j) Coordinating and communicating (on behalf of the Accountable Executive) with international agencies on issues relating to safety. Safety Review Board (Safety Committees) The Safety Review Board (SRB) is a high level committee which considers strategic safety functions. The Board should be chaired by the Accountable Manager and should normally include the senior management of the organization. Membership of the Board and frequency of meetings should be defined. Directors of the organization may be included in the SRB. The SRB: (a) Monitors the effectiveness of the SMS implementation plan; (b) Defining safety performance indicators and set safety performance targets for the organization (c) Monitors that any necessary corrective action is taken in a timely manner; (d) Monitors safety performance against the organization’s safety policy and objectives; (e) Monitors the effectiveness of the organization’s safety management processes which support the declared corporate priority of safety management as another core business process; (f) Monitors the effectiveness of the safety supervision of subcontracted operations; (g) Ensures that appropriate resources are allocated to achieve safety performance beyond that required by regulatory compliance; and (h) Gives strategic direction to the SAG. Figure 2-2 is an example of a functional chart showing the interfaces and interrelationships of the SRB among the various sectors of the organization. 13 Figure 2-2 Safety accountabilities: interfaces and interrelationships among the various sectors of the organization Safety Action Group Large organizations that have relatively complex operations could set up Safety Action Groups (or equivalent sub-committees) accountable to the Safety Committee. Managers and supervisors from a given functional area would be members of the SAG for that area and would take strategic directions from the Safety Committee. A safety action group should be established as a standing group or as an ad-hoc group to assist or act on behalf of the SRB. The Safety Action Group (SAG) reports to and takes strategic direction from the SRB. It is comprised of managers, supervisors and staff from operational areas. Membership of the Group and frequency of meetings should be defined. The Safety Manager may also participate in the SAG. The SAG: (a) Oversees operational safety performance within the functional areas and ensures that hazard identification and safety risk management are carried out as appropriate, with staff involvement as necessary to build up safety awareness; (b) Coordinates the resolution of mitigation strategies for the identified consequences of hazards and ensures that satisfactory arrangements exist for safety data capture and employee feedback; (c) Assesses the impact of operational changes on safety; (d) Maintenance and review of relevant performance indicators 14 (e) Coordinates the implementation of corrective action plans and convenes meetings or briefings as necessary to ensure that ample opportunities are available for all employees to participate fully in management for safety; (f) Ensures that corrective action is taken in a timely manner; (g) Reviews the effectiveness of previous safety recommendations; and (h) Oversees safety promotion and ensures that appropriate safety, emergency and technical training of personnel is carried out that meets or exceeds minimum regulatory requirements. 2.4 Coordination of emergency response planning An Emergency Response Plan (ERP) should be established that provides the actions to be taken by the organization or individuals in an emergency. The emergency response plan should be integrated into the SMS and reflect the size, nature and complexity of the activities performed by the organization. The ERP should ensure: (a) An orderly and efficient transition from normal to emergency operations; (b) Designation of emergency authority; (c) Assignment of emergency responsibilities; (d) Authorization by key personnel for actions contained in the plan; (e) Coordination of efforts to resolve the emergency; (f) Safe continuation of operations or return to normal operations as soon as practicable. (g) Compatibility with other emergency response plans of other organizations. The ERP should set out the responsibilities, roles and actions for the various agencies and personnel involved in dealing with emergencies. It may include checklists and contact details and the ERP should be regularly reviewed and tested. Key personnel should have easy access to the ERP at all times. For an AOC holder, a comprehensive ERP would include other aspects of aircraft accident response such as, crisis management centre, management of an accident site, news media, coordination with state investigations, family assistance, post critical incident stress counseling, etc. It should also include arrangements for emergencies at line stations. 2.5 SMS documentation SMS documentation must include and make reference to, as appropriate, all relevant and applicable national and international regulations. It must also include SMS-specific records and documentation, such as system descriptions, gap analysis, hazard reporting forms, lines of accountability, responsibility and authority regarding the management of operational safety, and the structure of the safety management organization. It must furthermore document explicit guidelines for records management, including handling, storage, retrieval and preservation. 15 SMS Manual The SMS Manual (SMSM) is a key instrument for communicating the organization’s approach to safety to the whole organization. It documents all aspects of the SMS, including the safety policy, objectives, procedures and individual safety accountabilities. Typical contents of an SMSM include: (a) Scope of the SMS; (b) Safety policy and objectives; (c) Safety accountabilities; (d) Key safety personnel; (e) Documentation control procedures; (f) Coordination of emergency response planning; (g) Hazard identification and risk management schemes; (h) Safety assurance; (i) Safety performance monitoring; (j) Safety auditing; (k) Management of change; (l) Safety promotion; and (m) Contracted activities. An SMS Manual should preferably be a manual by itself. For small organizations, it is possible for the SMS Manual to be incorporated within an existing organization’s manual. In either case, the various SMS components and their relevant integration should be adequately and systematically documented. Safety Library In a large organization, operating a SMS generates significant amount of data, documents and reports. Proper management and record keeping of such data is crucial for sustaining an effective SMS. Effective safety analysis is totally dependent upon the availability and competent use of the safety information management system. To facilitate easy retrieval and consolidation of safety data/information, it is necessary to ensure that there is relevant integration between the various sources of such data or reports. This is important where different departments within the organization have traditionally limited the scope of safety data distribution to within the department itself. Cross functional safety data integration becomes important in this case. It is necessary that the organization maintain a systematic record of all measures taken to fulfill the objectives and activities of the SMS. Such records would be required as evidence of ongoing SMS processes including hazard identification, risks mitigation and safety performance monitoring. These 16 records should be appropriately centralized and maintained in sufficient detail to ensure traceability of all safety related decisions. Examples of such records include: (a) Hazards Register (b) Incident/Accident reports (c) Accident/Accident investigation reports (d) (e) Safety/SMS audit reports Periodic analyses of safety trends/indicators (f) (g) Minutes of safety committee or safety action group meetings Hazard and Risk Analysis Reports, etc. Quality safety data are the lifeblood of safety management. Sound management of the organization’s databases is fundamental to effective safety management functions (such as trend monitoring, risk assessment, cost-benefit analyses and occurrence investigations). 17 3. SAFETY RISK MANAGEMENT Safety risk management is a generic term that encompasses the assessment and mitigation of the safety risks of the consequences of hazards that threaten the capabilities of an organization, to a level as low as reasonably practicable (ALARP). The objective of safety risk management is to provide the foundation for a balanced allocation of resources among all assessed safety risks and those safety risks the control and mitigation of which are viable. Safety risk management is therefore a key component of the safety management process. Its added value, however, lies in the fact that it is a data driven approach to resource allocation, thus defensible and easier to explain. The safety risk management of an SMS encompasses two distinct activities: hazard identification and safety risk assessment and mitigation. 3.1 Hazard identification A hazard is defined as a condition or an object with the potential to cause injuries to personnel, damage to equipment or structures, loss of material, or reduction of ability to perform a prescribed function. Hazard identification is a process where organizational hazards are identified and managed so that safety is not compromised. Sources of hazard identification There are a variety of sources of hazard identification. Some sources are internal to the organization while other sources are external to the organization. Examples of the internal sources of hazard identification available to an organization include: (a) flight data analysis (b) company voluntary reporting system; (c) safety surveys; (d) safety audits; (e) normal operations monitoring schemes; (f) trend analysis; (g) feedback from training; and (h) investigation and follow-up of incidents. Examples of external sources of hazard identification available to an organization include: (a) accident reports; (b) State mandatory occurrence reporting system; (c) State voluntary reporting system; (d) State oversight audits; and (e) information exchange systems. Note: Confidential reporting systems should be based on established human factors principles including an effective feedback process. All personnel in aviation organizations should receive the appropriate safety 18 management training, at a level commensurate with their responsibilities, so that everybody in the organization is prepared and able to identify and report hazards. From this perspective, hazard identification and reporting are everybody’s responsibility. However, organizations must have designated personnel with the exclusive charge of hazard identification and analysis. This would normally be the personnel assigned to the safety services office. Therefore, broadening the previous perspective, in aviation organizations, hazard identification is everybody’s responsibility, but accountability for hazard identification lies with dedicated safety personnel. Under mature safety management practices, hazard identification is a continuous, ongoing, daily activity. It never stops or rests. It is an integral part of the organizational processes aimed at delivering the services that the organization is in business to deliver. Nevertheless, there are three specific conditions under which special attention to hazard identification is warranted. These three conditions should trigger more in-depth and far-reaching hazard identification activities and include: (a) any time the organization experiences an unexplained increase in safety-related events or regulatory infractions; (b) any time major operational changes are foreseen, including changes to key personnel or other major equipment or systems; and (c) before and during periods of significant organizational change, including rapid growth or contraction, corporate mergers, acquisitions or downsizing. The scope of hazard identification is across the operational activities of the organization with data derived from reactive, proactive and predictive schemes. Reactive schemes include data from accidents, incidents and mandatory reports. Proactive schemes include voluntary incident reporting, confidential reporting schemes, safety surveys, operational safety audits and safety assessments. Predictive schemes include flight data analysis, direct observation systems. Managed group sessions can also be used to identify hazards. Hazard identification process The hazard identification process shall include the following steps: (a) reporting of hazards, events or safety concerns; (b) analysis of the safety data, develop control and mitigation strategies; (c) implementation and re-evaluate strategies (d) collection and storage of safety data (safety library); (e) distribution of the safety information distilled from the safety data. Hazard analysis Hazard analysis is, in essence, a three-step process: (a) First step. Identify the generic hazard (also known as top level hazard(TLH)). — airport construction 19 (b) Second step. Break down the generic hazard into specific hazards. — construction equipment — closed taxiways, etc. (c) Third step. Link specific hazards to potentially specific consequences. — aircraft colliding with construction equipment (construction equipment) — aircraft taking off into the wrong taxiway (closed taxiways), etc. Documentation of Hazards Appropriate documentation management regarding hazard identification is important as a formal procedure to translate raw operational safety information into hazard-related knowledge. Continuous compilation and formal management of this hazard-related knowledge becomes the “safety library” of an organization. In order to develop knowledge on hazards and thus build the “safety library”, it must be remembered that tracking and analysis of hazards are facilitated by standardizing: a) definitions of terms used; b) understanding of terms used; c) validation of safety information collected; d) reporting (i.e. what the organization expects); e) measurement of safety information collected; and f) management of safety information collected. The following flowchart illustrates the process of hazard management and documentation. Figure 3-1 The safety risk management process 20 3.2 Safety risk assessment and mitigation Following the identification of a hazard a form of analysis and mitigation of risks is required to assess its potential for harm or damage. Risk assessment uses conventional breakdown of risk in its two components. This involves two considerations: (a) Probability: The consequences. probability of the hazard causing adverse (b) Severity: The severity of the potential adverse consequences. Risk assessment and mitigation processes analyze and eliminate or mitigate to an acceptable level risks that could threaten the capabilities of an organization. A system should be developed for assessing and analyzing the data collected or derived from the actions outlined above. Information provided by analysis should be distributed to those with a responsibility for operational safety in the organization. Safety Risk Probability The process of bringing the safety risks of the consequences of hazards under organizational control starts by assessing the probability that the consequences of hazards materialize during operations aimed at delivery of services. This is known as assessing the safety risk probability. Safety risk probability is defined as the likelihood that an unsafe event or condition might occur. The definition of the likelihood of a probability can be aided by questions such as: (a) Is there a history of similar occurrences to the one under consideration, or is this an isolated occurrence? (b) What other equipment or components of the same type might have similar defects? (c) How many personnel are following, or are subject to, the procedures in question? (d) What percentage of the time is the suspect equipment or the questionable procedure in use? (e) To what extent are there organizational, management or regulatory implications that might reflect larger threats to public safety? 21 Figure 3-2 presents a typical safety risk probability table. The table includes five categories to denote the probability of occurrence of an unsafe event or condition, the meaning of each category, and an assignment of a value to each category. Probability of occurrence Meaning Value Frequent Likely to occur many times (has occurred frequently) 5 Occasional Likely to occur sometimes (has occurred infrequently) 4 Remote Unlikely to occur, but possible (has occurred rarely) 3 Improbable Very unlikely to occur (not known to have occurred) 2 Extremely improbable Almost inconceivable that the event will occur 1 Figure 3-2 Safety risk probability table Safety Risk Severity Once the safety risk of an unsafe event or condition has been assessed in terms of probability, the second step in the process of bringing the safety risks of the consequences of hazards under organizational control is the assessment of the severity of the consequences of the hazard if its damaging potential materializes during operations aimed at delivery of services. This is known as assessing the safety risk severity. Safety risk severity is defined as the possible consequences of an unsafe event or condition, taking as reference the worst foreseeable situation. The assessment of the severity of the consequences of the hazard if its damaging potential materializes during operations aimed at delivery of services can be assisted by questions such as: (a) How many lives may be lost (employees, passengers, bystanders and the general public)? (b) What is the likely extent of property or financial damage (direct property loss to the operator, damage to aviation infrastructure, third-party collateral damage, financial and economic impact for the State)? (c) What is the likelihood of environmental impact (spillage of fuel or other hazardous product, and physical disruption of the natural habitat)? (d) What are the likely political implications and/or media interest? 22 Figure 3-3 presents a typical safety risk severity table. The table includes five categories to denote the probability of occurrence of an unsafe event or condition, the meaning of each category, and an assignment of a value to each category. Severity of occurrence Catastrophic Hazardous Major Minor Negligible Meaning - Equipment destroyed - Multiple deaths - A large reduction in safety margins, physical distress or a workload such that the operators cannot be relied upon to perform their tasks accurately or completely. - Serious injury - Major equipment damage - A significant reduction in safety margins, a reduction in the ability of the operators to cope with adverse operating conditions as a result of increase in workload, or as a result of conditions impairing their efficiency. - Serious incident - Injury to persons - Nuisance - Operating limitations - Use of emergency procedures - Minor incident - Little consequences Value A B C D E Figure 3-3 Safety risk severity table Safety Risk Tolerability Once the safety risk of the consequences of an unsafe event or condition has been assessed in terms of probability and severity, the third step in the process of bringing the safety risks of the consequences of the unsafe event or condition under organizational control is the assessment of the tolerability of the consequences of the hazard if its damaging potential materializes during operations aimed at delivery of services. This is known as assessing safety risk tolerability. This is a two-step process. First, it is necessary to obtain an overall assessment of the safety risk. This is achieved by combining the safety risk probability and safety risk severity tables into a safety risk assessment matrix, an example of which is presented in Figure 3-4. Each composite of probability and severity is the safety risk of the consequences of the hazard under consideration. The color coding in the matrix in Figure 3-4 reflects three tolerability regions: red for Intolerable region, yellow for tolerable region, and green for acceptable region, respectively. 23 Risk severity Risk probability Catastrophic Hazardous Major Minor Negligible A B C D E 5C Frequent 5 5A 5B Occasional 4 4A 4B Remote 3 3A Improbable 2 Extremely improbable 1 1A 3E 1B 1C 2D 2E 1D 1E Figure 3-4 Safety risk assessment matrix Second, the safety risk index obtained from the safety risk assessment matrix must then be exported to a safety risk tolerability matrix in Figure 3-5, which describes the tolerability criteria. Risk Level Intolerable region Risk index Suggested criteria 5A, 5B, 5C,4A 4B, 3A Unacceptable under the existing circumstances Do not permit any operation until sufficient control measures have been implemented to reduce risk to an acceptable level. Acceptable based on risk mitigation. It may require management decision. Acceptable region 3E, 2D, 2E, 1A 1B, 1C, 1D, 1E Acceptable Figure 3-5 Safety risk tolerability matrix If the safety risk falls in the intolerable region, the safety risk of the consequences of the hazard is unacceptable. The organization must: (a) allocate resources to reduce the exposure to the consequences of the hazards; (b) allocate resources to reduce the magnitude or the damaging potential of the consequences of the hazards; or (c) cancel the operation if mitigation is not possible. Safety risks assessed as initially falling in the intolerable region are unacceptable under any circumstances. The probability and/or severity of the consequences of the hazards are of such a magnitude, and the damaging potential of the hazard poses such a threat to the viability of the organization, that immediate mitigation action is required. Safety risks assessed as initially falling in the tolerable region are acceptable, provided mitigation strategies already in place guarantee that, to the 24 foreseeable extent, the probability and/or severity of the consequences of hazards are kept under organizational control. The same control criteria apply to safety risks initially falling in the intolerable region and mitigated to the tolerable region. A safety risk initially assessed as intolerable that is mitigated and slides down to the tolerable region must remain “protected” by mitigation strategies that guarantee its control. Risk Control/Mitigation In the final step of the process of bringing the safety risks of the consequences of an unsafe event or condition under organizational control, control/mitigation strategies must be deployed. Generally speaking, control and mitigation are terms that can be used interchangeably. Both are meant to designate measures to address the hazard and bring under organizational control the safety risk probability and severity of the consequences of the hazard. For example If the safety risk of the consequences of the hazard under analysis has been assessed as 4B (“unacceptable under the existing circumstances”). Resources must then be allocated to slide it down the triangle, into the tolerable region, where safety risks are ALARP. If this cannot be achieved, then the operation aimed at the delivery of services which exposes the organization to the consequences of the hazards in question must be cancelled. Figure 3-6 presents the process of safety risk management in graphic format. Equipment, procedures, organization, etc. Hazard identification Analyze the likelihood of the consequence occurring Risk analysis probability Evaluate the seriousness of the consequence if it does occur Risk analysis severity Is the assessed risk acceptable and within the organization’s safety performance criteria? Risk assessment and tolerability Yes, accept the risk Risk control/ mitigation No, take action to reduce the risk to an acceptable level Figure 3-6 The process of safety risk management There are three generic strategies for safety risk control/mitigation: (a) Avoidance. The operation or activity is cancelled because safety risks exceed the benefits of continuing the operation or activity. Examples of avoidance strategies include: 25 (1) operations into an aerodrome surrounded by complex geography and without the necessary aids are cancelled; (2) operations in RVSM airspace by non-RVSM equipped aircraft are cancelled. (b) Reduction. The frequency of the operation or activity is reduced, or action is taken to reduce the magnitude of the consequences of the accepted risks. Examples of reduction strategies include: (1) operations into an aerodrome surrounded by complex geography and without the necessary aids are limited to daytime, visual conditions; (2) operations by non-RVSM equipped aircraft are conducted above or below RVSM airspace. (c) Segregation of exposure. Action is taken to isolate the effects of the consequences of the hazard or build in redundancy to protect against them. Examples of strategies based on segregation of exposure include: (1) operations into an aerodrome surrounded by complex geography and without the necessary aids are limited to aircraft with specific performance navigation capabilities; (2) non-RVSM equipped aircraft are not allowed to operate into RVSM airspace. The following shows a sample flowchart of the risk mitigation process and a sample risk mitigation worksheet. Figure 3-7 The safety risk mitigation process 26 Type of operation or activity Generic hazard Specific components of the hazard Hazard-related consequences Existing defenses to control safety risks, and safety risk index Further action to reduce safety risks, and resulting safety risk index Airport operation Airport construction Construction vehicles crossing primary runway a) Construction vehicles may deviate from prescribed procedures and cross the primary runway without an escort. a) The SAG assessment leads to the conclusion that there is a remote probability that a construction vehicle will deviate from prescribed procedures and cross the primary runway without an escort. a) The SAG decides to control the safety risk by using an existing aerodrome perimeter road to gain access to the construction site. All construction vehicles will be escorted on the perimeter road. b) Aircraft could conflict with a crossing vehicle. b) There are night air carrier operations at the airport, so there is a remote probability that an aircraft could conflict with a crossing vehicle. c) While the probability of an aircraft/ construction vehicle conflict is remote, the SAG assesses that, should such conflict occur, the severity of the occurrence could be catastrophic. d) The SAG assesses existing defenses (driver training program, use of escorts for construction vehicles, signs, markings and lighting) e) Using the safety risk assessment matrix (Chapter 3, Figure 3-4) and the safety risk tolerability matrix (Chapter 3, Figure 3-5), the SAG assesses: Safety risk index: 3A Safety risk tolerability: Unacceptable under the existing circumstances. b) With this mitigation, the SAG reassesses the probability of construction vehicles crossing the primary runway without an escort, or that aircraft could conflict with a crossing vehicle, as being extremely improbable. Nevertheless, should an aircraft/construction vehicle conflict occur, the severity of such an occurrence could still be catastrophic. c) Use of the perimeter road as mitigation may delay construction vehicles due to the added driving distance, but in the assessment of the SAG: while it does not entirely remove the possibility of the consequences of the hazard from occurring (construction vehicles may still cross the primary runway due to a number or combination of circumstances), it nevertheless brings the safety risks of the consequences (construction vehicle deviating from prescribed procedures and crossing the primary runway without an escort; and aircraft in conflict with a crossing vehicle) to an acceptable level. d) Using the safety risk assessment matrix (Chapter 3, Figure 3-4) and the safety risk tolerability matrix (Chapter 3, Figure 3-5), the SAG reassesses: Safety risk index: 1A Safety risk tolerability: Acceptable. e) The SAG documents this decision process for future follow-up with the Any city International Airport safety manager. Table 3-1 Hazard identification and safety risk management 27 4 SAFETY ASSURANCE Safety assurance can be defined as activities designed to gain confidence that risk controls established during safety risk management continue to be effective. The safety assurance function applies the activities of safety assurance and internal evaluation to ensure that risk controls, once designed, continue to conform to their expectations and that they continue to be effective in maintaining risk within acceptable levels. These assurance and evaluation functions also provide a basis for continuous improvement. The safety assurance activities should include procedures that ensure that corrective actions are developed in response to findings of reports, studies, surveys, audits, evaluations and so forth, and to verify their timely and effective implementation. Organizational responsibility for the development and implementation of corrective actions should reside with the operational departments cited in the findings. If new hazards are discovered, the safety risk management process should be employed to determine if new safety risk controls should be developed. Safety assurance, utilizes auditing, analysis, review and similar techniques, in line with those utilized by quality management systems. 4.1 Safety performance monitoring and measurement Safety Performance Indicators and Safety Performance Targets provide a measurable way of ensuring and demonstrating the effectiveness of an SMS beyond regulatory compliance. Such safety performance measurements should express or link to the safety objectives of the aviation organization. Safety performance measurements have to be agreed between CAA and the aviation organization. Safety performance monitoring is the process by which safety performance indicators of the organization are reviewed in relation to safety policies and objectives. Such monitoring would normally be done at the safety committee and where applicable safety action group level. Any significant abnormal trend would warrant appropriate investigation into potential hazards or risks associated with such deviation. The following provides a list of generic aspects or areas to be considered to “assure safety” through safety performance monitoring and measurement: (a) Responsibility. Who is accountable for management of the operational activities (planning, organizing, directing, controlling) and its ultimate accomplishment. (b) Authority. Who can direct, control or change the procedures and who cannot as well as who can make key decisions such as safety risk acceptance decisions. (c) Procedures. Specified ways to carry out operational activities and that translate the “what” (objectives) into “how” (practical activities). (d) Controls. Elements of the system, including, hardware, software, special procedures or procedural steps, and supervisory practices designed to keep operational activities on track. (e) Interfaces. An examination of such things as lines of authority between departments, lines of communication between employees, consistency of procedures, and clear delineation of responsibility between organizations, work units and employees. 28 (f) Process measures. Means of providing feedback to responsible parties that required actions are taking place, required outputs are being produced and expected outcomes are being achieved. Safety Performance Indicators Safety performance indicators (parameters) are generally data based expressions of the frequency of occurrence of some safety/ quality related events, incidents or reports. These occurrence data may be reactive, proactive or predictive in nature. There is no single safety performance indicator that is appropriate to all organizations. The indicator(s) chosen should correspond to the organization’s relevant safety objectives. Safety Performance Targets Safety performance targets are quantifiable and have time components. They should be achievable and realistic. These safety performance targets should be measured and monitored with the use of safety performance indicators where applicable. Safety Reporting Systems Confidential reporting systems should be based on a just culture providing appropriate protection for the reporter including an effective feedback process. This approach should encourage staff at all levels to proactively report near misses and hazards. More guidance on safety reporting systems may be found in CAA AC 00-001A. 4.2 The management of change Aviation organizations experience constant change due to expansion and introduction of new equipment or procedures. Changes can introduce new hazards or risks which can impact the appropriateness or effectiveness of previous risk mitigation. External changes would include change of regulatory requirements, security status/level or re-arrangement of air traffic control/provisions, etc. Internal changes can involve management/organizational changes, major new equipment introduction or new procedures, etc. A formal management of change process should identify changes within or from outside the organization which may affect established processes and services from a safety viewpoint. Prior to implementing such changes, the new arrangements should be assessed using the SMS hazard and risk analysis protocol or in relation to previously completed risk mitigation as applicable. Activities with safety risks should be scheduled for a baseline hazard analysis in accordance with the organization’s safety risk management process. Periodically, such activities should be reviewed for any changes to the operational environment which may affect the continued validity of the previous baseline analysis. The procedure for routine review of completed safety assessments should be established as appropriate. The interval for such scheduled review may be on a case by case basis or as a standard interval, for example annually. Such scheduled review may take into consideration previously unidentified hazard/ risks based on operational or industry incident/ accident investigation findings. Likewise, any modification or change subsequent to the initial safety 29 assessment done should be evaluated for any possible effect on the existing safety assessment. 4.3 Continuous improvement of the SMS Internal SMS Audit Internal safety (SMS) audits are used to ensure that the structure of an SMS is sound. It is also a formal process to ensure continuous improvement and effectiveness of the SMS. The protocol for conducting a SMS audit (from planning to final corrective action closure) should be no different from any other system audit. Audits should involve the use of appropriate checklists. The overall scope of an SMS audit should include: - Regulatory SMS requirements Structure of safety accountabilities Organizational safety policies and standards Documentation, including SMS manual and SMS records Compliance with SMS hazard/ risk evaluation procedures Adequacy of staff training for their SMS roles Safety Performance indicators Compliance with safety assessment plan or schedule Effective SMS integration with other control systems SMS integration with contractors where applicable Continuing assessments and management of change Review completed safety assessments for any that may be obviously sub-standard or inadequate Safety Reviews Over and above SMS audits, safety reviews or surveys may be employed as a proactive procedure for examining particular elements, processes or a specific operation for any safety concerns or sub-standard performance. Such targeted safety surveys may be initiated as a follow up to informal feedback or voluntary/confidential reports to identify issues that may contribute to generation of hazard/risks or their escalation factors, such as: - Problem areas or bottlenecks in daily operations - Perceptions and opinions about personnel’s competency with possible safety implications - Poor Teamwork and cooperation between employee groups or departments (especially involving safety/operational/technical functions) - Areas of dissent or perceived confusion (especially involving safety/operational/technical functions) - Unsafe working procedures or conditions - Prolonged working hours or long-term manpower shortfall, etc 30 5. SAFETY PROMOTION An organizational safety effort cannot succeed by mandate or strictly though mechanistic implementation of policies. Safety promotion sets the tone that predisposes both individual and organizational behavior and fills in the blank spaces in the organization’s policies, procedures and processes, providing a sense of purpose to safety efforts. Many of the processes and procedures specified in the safety policy and objectives and safety risk management and safety assurance components of the SMS provide the structural building blocks of an SMS. However, the organization must also set in place processes and procedures that allow for communication among operational personnel and with the organization’s management. Organizations must make every effort to communicate their objectives, as well as the current status of the organization’s activities and significant events. Likewise, organizations must supply a means of upward communication in an environment of openness. Safety promotion includes: (a) training and education, including safety competency; and (b) safety communication. 5.1 Training and Education The safety manager provides current information and training related to safety issues relevant to the specific operations and operational units of the organization. The provision of appropriate training to all staff, regardless of their level in the organization, is an indication of management’s commitment to an effective SMS. Safety training and education should consist of the following: (a) a documented process to identify training requirements; (b) a validation process that measures the effectiveness of training; (c) initial (general safety) job-specific training; (d) indoctrination/initial training incorporating SMS, including Human Factors and organizational factors; and (e) recurrent safety training. Training requirements and activities should be documented for each area of activity within the organization. A training file should be developed for each employee, including management, to assist in identifying and tracking employee training requirements and verifying that personnel have received the planned training. Training programs should be adapted to fit the needs and complexity of the organization. Safety training within an organization must ensure that personnel are trained and competent to perform their safety management duties. The SMS Manual (SMSM) should specify initial and recurrent safety training standards for operational personnel, managers and supervisors, senior managers and the Accountable Executive. The amount of safety training should be appropriate to the individual’s responsibility and involvement in the SMS. The SMSM should also specify safety training responsibilities, including contents, frequency, validation and safety training records management. Safety training should follow a building-block approach. Safety training for operational personnel should address safety responsibilities, including following all operating and safety procedures, and recognizing and reporting hazards. The training objectives should include the organization’s safety policy 31 and SMS fundamentals and overview. The contents should include the definition of hazards, consequences and risks, the safety risk management process, including roles and responsibilities and, quite fundamentally, safety reporting and the organization’s safety reporting system(s). Safety training for managers and supervisors should address safety responsibilities, including promoting the SMS and engaging operational personnel in hazard reporting. In addition to the training objectives established for operational personnel, training objectives for managers and supervisors should include a detailed knowledge of the safety process, hazard identification and safety risk assessment and mitigation, and change management. In addition to the contents specified for operational personnel, the training contents for supervisors and managers should include safety data analysis. Safety training for senior managers should include safety responsibilities including compliance with national and organizational safety requirements, allocation of resources, ensuring effective inter-departmental safety communication and active promotion of the SMS. In addition to the objectives of the two previous employee groups, safety training for senior managers should include safety assurance and safety promotion, safety roles and responsibilities, and establishing acceptable levels of safety. Lastly, safety training should include special safety training for the Accountable Executive. This training session should be reasonably brief (it should not exceed one-half day), and it should provide the Accountable Executive with a general awareness of the organization’s SMS, including SMS roles and responsibilities, safety policy and objectives, safety risk management and safety assurance. 5.2 Safety Communication The organization should communicate SMS objectives and procedures to all operational personnel, and the SMS should be visible in all aspects of the organization’s operations supporting the delivery of services. The safety manager should communicate the performance of the organization’s SMS program through bulletins and briefings. The safety manager should also ensure that lessons learned from investigations and case histories or experiences, both internally and from other organizations, are distributed widely. Communication should flow between the safety manager and operational personnel throughout the organization. Safety performance will be more efficient if operational personnel are actively encouraged to identify and report hazards. Safety communication therefore aims to: (a) ensure that all staff are fully aware of the SMS; (b) convey safety-critical information; (c) explain why particular actions are taken; (d) explain why safety procedures are introduced or changed; and (e) convey “nice-to-know” information. Examples of organizational communication include: (a) safety management systems manual (SMSM); (b) safety processes and procedures; (c) safety newsletters, notices and bulletins; and 32 (d) websites or email. Confidential safety reporting systems should be established. These reporting systems should be based on a just culture providing appropriate protection for the reporter including an effective feedback process. This approach should encourage staff at all levels to proactively report near misses and hazards. More guidance on safety reporting systems may be found in CAA AC 00-001A. 33 ATTACHMENT 1 SMS IMPLEMENTATION PLAN Phases I &II should be completed by June 30, 2011. Phase III should be completed by June 30, 2012. Phase IV should be completed by December 31, 2012. 1. PHASE I — PLANNING SMS IMPLEMENTATION 1.1 The Accountable Executive Identify the Accountable Executive and the person or planning group to develop the SMS implementation plan. 1.2 System description and gap analysis. System description Perform the system description, which is the first prerequisite activity for the development of an SMS in an organization. It should include the interfaces within the system, as well as the interfaces with other systems in the air transportation system. Gap analysis (a) Perform a gap analysis, against the four components and twelve elements of the ICAO SMS framework, to identify existing safety arrangements within the organization and those that are missing. (b) Based upon the results of the gap analysis, the person or planning group should be able to develop the SMS implementation plan taking into consideration: — the identification of implementation; and potential gaps that may hinder SMS — the development of strategies to address such gaps. 1.3 Safety policy and objectives Safety policy - Develop a safety policy. - Have the Accountable Executive sign the safety policy. - Communicate the safety policy, with visible endorsement, throughout the organization. - Establish a review schedule for the safety policy to ensure it remains relevant and appropriate to the organization. Safety objectives 34 Establish safety objectives for the SMS, by developing safety performance standards in terms of: - safety performance indicators; - safety performance targets; and - action plans. Establish the SMS requirements for subcontractors: - establish a procedure to write SMS requirements into the contracting process; and - establish the SMS requirements in the bidding documentation. 1.4 Safety accountabilities and appointment of key safety personnel SMS organizational structure - Establish the safety services office. - Appoint a safety manager as the responsible individual and focal point for the development and maintenance of an effective SMS. - Assess and establish lines of communication between the safety services office and the Accountable Executive, the Safety Action Group (SAG) and the Safety Review Board (SRB). - Ensure that the functional lines of communication are commensurate with the size of the organization and complexity of the services provided. - Establish the Safety Review Board (SRB) chaired by the Accountable Executive. - Appoint senior managers, including line managers responsible for functional areas, to the SRB. - Assign appropriate strategic functions to the SRB. - Establish the Safety Action Group (SAG). - Appoint line managers and representatives of front-line personnel to the SAG. - Assign appropriate tactical functions to the SRB. - Document all safety responsibilities, accountabilities and authorities and communicate those throughout the organization, including a definition of the levels of management with authority to make decisions regarding safety risk tolerability. - Develop a schedule of meetings for the safety services office to meet with the SRB and SAG as needed. 1.5 Coordination of the emergency response plan (ERP) Internal coordination - Review the outline of the ERP related to the delegation of authority and 35 assignment of emergency responsibilities. - Establish coordination procedures for action by key personnel during the emergency and the return to normal operations. External coordination - Identify external entities that will interact with the organization during emergency situations. - Assess their respective ERPs. - Establish coordination between the different ERPs. - Incorporate the coordination among different ERPs in the organization’s safety management systems manual (SMSM). 1.6 SMS documentation - Establish the mechanism to collect and store the SMS-specific records and documentation. - Refer to all relevant and applicable national regulations and international standards. - Develop guidelines for records management that includes the SMS implementation plan and the SMSM. SMS implementation plan - Appoint the person, or establish the planning group, responsible for the development of the SMS implementation plan. - Collect all applicable documents that form the SMS implementation plan. - Conduct regular meetings with senior management to assess progress. - Allocate resources (including time for meetings) commensurate with the tasks at hand. - Include significant items of the SMS implementation plan in the business plan of the organization. - Identify the costs associated with the training and planning required for SMS implementation. - Allocate time for the development and deployment of the SMS implementation plan among the different management layers of the organization. - Draft a budget for SMS implementation. - Approve the initial budget for SMS implementation. - Submit the SMS implementation plan for endorsement by senior management. Safety management systems manual (SMSM) 36 - Draft the SMSM to communicate the organization’s approach to safety to the whole organization. - Expand, review and amend the contents of the SMSM (which is a living document) as the phased approach of the SMS evolves. 1.7 Safety promotion — Training Safety training - Develop a documented process to identify training requirements. - Develop a validation process that measures the effectiveness of training. - Develop safety training considering: >initial (general safety) job-specific training; > indoctrination/initial training incorporating SMS, including Human Factors and organizational factors; > recurrent training. - Identify the costs associated with training. - Organize and set up schedules for appropriate training for all staff according to their individual responsibilities and involvement in the SMS. - Develop training files for each employee, including management. 1.8 Safety promotion — Safety communication Establish a means to convey organizational information on Phase I, including: - safety newsletters, notices and bulletins; - websites; - email. 1.9 Time frame for implementation, and deliverables The estimated time frame for implementation of Phase I could take from 1 to 6 months, depending on the size of the organization and complexity of the services provided. Deliverables (1) Safety policy signed by the Accountable Executive. (2) Safety policy communicated to all staff. (3) System description completed. (4) Gap analysis completed. (5) SMS organizational structure in place. (6) SMS implementation plan approved. 37 (7) Training on SMS planning phase delivered. (8) Initial draft of SMSM published. (9) Means to communicate safety issues established. 2. PHASE II — REACTIVE SAFETY MANAGEMENT PROCESSES 2.1 Hazard identification and analysis based on reactive processes Hazard identification - Identify the internal and external sources to be used in collecting reactive information on hazards. - Implement a structured approach to the reactive identification of hazards. 2.2 Safety risk management based on reactive processes Safety risk assessment - Develop and adopt a safety risk matrix relevant to the organization’s operational environment. - Develop safety risk matrix instructions and include them in the training program. 2.3 Training Develop a safety training program for front-line personnel, managers and supervisors on: - the relevant SMS implementation plan components; - hazard identification and safety risk management based on reactive processes (front-line personnel are trained on identification and reporting of hazards from triggering events, and supervisors are trained on hazard and safety risk management); - the hazard reporting form/template. 2.4 Documentation on reactive processes - Establish a safety library. - Add information on reactive safety risk management processes to the SMSM. (Information on reactive safety risk management processes will be used at a later phase to establish safety performance indicators and targets.) - Write requirements for hazard identification and safety risk management based on reactive processes into the bid documentation for contractors, if necessary, and notify contractors and subcontractors in writing. 38 2.5 Safety promotion — Safety communication Establish a means to convey organizational information on Phase II: - safety newsletters, notices and bulletins; - websites; - email. 2.6 Time frame for implementation, and deliverables The estimated time frame for implementation of Phase II could take from 9 to 12 months, depending on the size of the organization and complexity of the services provided. Deliverables (1) Safety library established. (2) Reactive safety management processes implemented. (3) Training relevant to SMS implementation plan components and safety risk management on reactive processes completed. (4) Safety-critical information based on safety data captured from reactive processes distributed to the organization. 3. PHASE III — PROACTIVE AND PREDICTIVE SAFETY MANAGEMENT PROCESSES 3.1 Hazard identification and analysis based on proactive and predictive processes Hazard identification - Identify the internal and external sources to be used in collecting proactive and predictive information on hazards. - Implement a structured approach to the proactive and predictive identification of hazards. 3.2 Safety risk management based on proactive and predictive processes Safety risk assessment - Develop and adopt a safety risk matrix relevant to the organization’s operational environment. - Develop safety risk matrix instructions and include them in the training program. 3.3 Training - Train staff of the safety services office on specific proactive and predictive means of collecting safety related data. 39 - Brief supervisors and front-line personnel on proactive and predictive processes. - Develop a safety training program for front-line personnel, managers and supervisors on: > the relevant SMS implementation plan components; > hazard identification and safety risk management based on proactive and predictive processes (frontline personnel are trained on identification and reporting of hazards from less serious triggering events or during real-time normal operations, and supervisors are trained on hazard and safety risk management based on proactive and predictive processes). 3.4 Documentation on proactive and predictive processes - Store information from safety risk management based on proactive and predictive processes in the safety library. - Add information on proactive and predictive safety risk management processes to the SMSM. - Develop safety performance indicators and safety performance targets. - Write requirements for hazard identification and safety risk management based on proactive and predictive processes into the bid documentation for contractors, if necessary, and notify contractors and subcontractors in writing. 3.5 Safety promotion — Safety communication Establish a means to convey organizational information on Phase III: - safety newsletters, notices and bulletins; - websites; - email. 3.6 Time frame for implementation, and deliverables The estimated time frame for implementation of Phase III could take from 12 to 16 months, depending on the size of the organization and complexity of the services provided. Deliverables (1) Initial testing period for proactive and predictive means to collect hazard identification established. (2) Proactive and predictive safety management processes implemented. (3) Training relevant to SMS implementation plan components and safety risk management based on proactive and predictive processes completed. (4) Safety performance indicators and safety performance targets developed. 40 (5) Critical safety information based on safety data captured by reactive, proactive and predictive processes distributed to the organization. 4. PHASE IV — OPERATIONAL SAFETY ASSURANCE 4.1 Safety performance of the SMS - Establish safety performance indicators. - Establish safety performance targets. - Establish action plans. - Define measures of reliability, availability and/or accuracy related to action plans, as required. - Agree on safety performance measurement with the State oversight authority. 4.2 Safety performance monitoring and measurement Define and develop information sources for safety performance and monitoring. 4.3 The management of change - Establish a formal process for the management of change that considers: > criticality of systems and activities; > stability of systems and operational environments; > past performance. - Identify changes that might affect established processes, procedures, products and services. - Prior to implementing changes, define arrangements to ensure safety performance. 4.4 Continuous improvement of the SMS - Develop forms for internal evaluations and ensure independence from technical processes being evaluated. - Define an internal audit process. - Define an external audit process. - Define a schedule for proactive evaluation of facilities, equipment, documentation and procedures, to be completed through audits and surveys. - Define a schedule for proactive evaluation of an individual’s performance. - Develop documentation relevant to operational safety assurance. 41 4.5 Training Develop training relevant to operational safety assurance for staff involved in the safety assurance phase. 4.6 Safety promotion — Safety communication Establish a means to convey organizational information on Phase IV: - safety newsletters, notices and bulletins; - websites; - email. 4.7 Time frame for implementation and deliverables The estimated time frame for implementation of Phase IV could take from 9 to 12 months, depending on the size of the organization and complexity of the services provided. Deliverables (1) Agreement reached with the State oversight authority on safety performance indicators and safety performance targets. (2) Training on safety assurance for operational personnel, managers and supervisors completed. (3) Documentation relevant to operational safety assurance placed in the safety library. 5. ADDITIONAL GUIDANCE 5.1 Non-Punitive Information) Reporting Policy (Protection of Sources of Safety Although not required in Phase 1, it is important to encourage safety reporting and to protect safety information sources. It is therefore recommended that in the early stages of deployment, the organization considers the development of a written policy to set the parameters for the circumstances in which safety reporting would be rewarded versus the circumstances in which safety reporting could lead to possible punitive action against individuals. An effective safety reporting system (and positive organizational safety culture) allows employees the freedom (and protection) to report safety concerns without apportioning blame or affect punishment to those involved. However, in instances where the safety reports filed indicate the existence of gross negligence or repeat violations in a certain area, a thorough investigation is required to establish the root cause of the behavior. Depending on the outcome of the investigation, based on the facts involved that explained the ‘why’ and ‘how’ questions behind the specific behavior, the organization might decide to take punitive action against the individuals involved. An error-tolerant SMS requires appropriate responsibility and accountability 42 from all involved to safe-guard the abuse of the system for personal gain. Even within a non-punitive reporting environment there are certain acts that should require disciplinary action (for example, willful gross negligence, criminal intent or use of illicit substances). 5.2 Human Error: All unsafe acts indicating human error will be logged into a database including the root cause (main reason) and other reasons that contributed to the errors being made. The following errors should not be punished: · Errors made as a result of deficiencies in procedures, requirements or standards; · Errors made as a result of poor or ineffective supervision; · Errors induced by the environment; · Errors induced by the organizational culture; and · 5.3 Violations: All unsafe acts indicating violations will be logged into a database including the root cause (main reason) and other reasons that contributed to the violations being made. 43 ATTACHMENT 2 SMS GAP ANALYSIS CHECK LIST The gap analysis checklist that follows can be used as a template to conduct a gap analysis. Each question is designed for a “Yes” or “No” response. A “Yes” answer indicates that the service provider already has the component or element of the SMS framework in question incorporated into its system and that it either matches or exceeds the requirement. A “No” answer indicates that a gap exists between the component/element of the SMS framework and the service provider’s system. Organization Name: Analyzed by: Date of Analysis: Reference: Items Aspect to be analyzed or question to be answered Answer Component 1 — SAFETY POLICY AND OBJECTIVES Element 1.1 — Management commitment and responsibility 1 � Yes Is there a safety policy in place? � No 2 3 4 Does the safety policy reflect organizational commitments regarding safety management? � Yes Does the safety policy include a clear statement about the provision of the necessary resources for the implementation of the safety policy? � Yes Does the safety policy include the safety reporting procedures? � Yes � No � No � No 5 6 7 Does the safety policy clearly indicate which types of operational behaviors are unacceptable? � Yes Does the safety policy include the conditions under which disciplinary action would not apply? � Yes Is the safety policy signed by the Accountable Executive? � Yes � No � No � No 8 9 10 11 Is the safety policy communicated, with visible endorsement, throughout the [organization]? � Yes Is the safety policy periodically reviewed to ensure it remains relevant and appropriate to the [organization]? � Yes Is there a formal process to develop a coherent set of safety objectives? � Yes Are the safety objectives linked to the safety performance indicators, safety performance targets and action plans? � Yes 44 � No � No � No Status of implementation Items Aspect to be analyzed or question to be answered Answer � No 12 Are the safety objectives publicized and distributed? � Yes � No Element 1.2 — Safety accountabilities 13 14 15 16 17 18 19 20 21 Has the [organization] identified an Accountable Executive who, irrespective of other functions, shall have ultimate responsibility and accountability, on behalf of the [organization], for the implementation and maintenance of the SMS? � Yes Does the Accountable Executive have responsibility for ensuring that the safety management system is properly implemented and performing to requirements in all areas of the [organization]? � Yes Does the Accountable Executive have full control of the financial resources required for the operations authorized to be conducted under the operations certificate? � Yes Does the Accountable Executive have full control of the human resources required for the operations authorized to be conducted under the operations certificate? � Yes Does the Accountable Executive have direct responsibility for the conduct of the organization’s affairs? � Yes Does the Accountable Executive have final authority over operations authorized to be conducted under the operations certificate? � Yes Has the organization identified the accountabilities of all members of management, irrespective of other functions, as well as of employees, with respect to the safety performance of the SMS? � Yes Are the safety responsibilities, accountabilities and authorities documented and communicated throughout the [organization]? � Yes Has the [organization] included a definition of the levels of management with authority to make decisions regarding safety risk tolerability? � Yes � No � No � No � No � No � No � No � No � No Element 1.3 — Appointment of key personnel 22 23 24 Has the organization appointed a qualified person to manage and oversee the day-to-day operation of the SMS? � Yes Does the person overseeing the operation of the SMS fulfill the required job functions and responsibilities? � Yes Are the safety authorities, responsibilities and accountabilities of personnel at all levels of the organization defined and documented? � Yes � No � No � No Element 1.4 — Coordination of emergency response planning 25 Does the [organization] have an emergency response/contingency plan appropriate to the size, nature and complexity of the 45 � Yes Status of implementation Items 26 27 Aspect to be analyzed or question to be answered Answer organization? � No Does the [organization] coordinate its emergency response/contingency procedures with the emergency/response contingency procedures of other organizations it must interface with during the provision of services? � Yes Does the [organization] have a process to distribute and communicate the coordination procedures to the personnel involved in such interaction? � Yes � No � No Element 1.5 —SMS documentation 28 29 30 31 32 33 34 35 36 37 38 39 40 Has the [organization] developed and does it maintain a safety library for appropriate hazard documentation and documentation management? � Yes Has the [organization] developed and does it maintain SMS documentation in paper or electronic form? � Yes Is the SMS documentation developed in a manner that describes the SMS and the consolidated interrelationships between all the SMS components? � Yes Has the organization developed an SMS implementation plan that ensures that the SMS meets the organization’s safety objectives? � Yes Has the SMS implementation plan been developed by a person or a planning group which comprises an appropriate experience base? � Yes Has the person or planning group received enough resources (including time for meetings) for the development of the SMS implementation plan? � Yes Is the SMS implementation plan endorsed by the senior management of the [organization]? � Yes Is the SMS implementation plan regularly reviewed by the senior management of the [organization]? � Yes Does the SMS implementation plan propose implementation of the SMS in phases? � Yes Does the SMS implementation plan explicitly address the coordination between the organization’s SMS and the SMS of other organizations the [organization] must interface with during the provision of services? � Yes Has the organization developed a safety management systems manual (SMSM) as a key instrument for communicating the organization’s approach to safety to the whole [organization]? � Yes Does the SMSM document all aspects of the SMS including, among others, the safety policy, objectives, procedures and individual safety accountabilities? � Yes Does the SMSM clearly articulate the role of safety risk management � Yes 46 � No � No � No � No � No � No � No � No � No � No � No � No Status of implementation Items 41 42 43 44 Aspect to be analyzed or question to be answered Answer as an initial design activity and the role of safety assurance as a continuous activity? � No Are relevant portions of SMS-related documentation incorporated into approved documentation, such as company operations manual, maintenance control/policy manual and airport operations manual, as applicable? � Yes Does the organization have a records system that ensures the generation and retention of all records necessary to document and support operational requirements? � Yes Is the organization’s records system in accordance with applicable regulatory requirements and industry best practices? � Yes Does the records system provide the control processes necessary to ensure appropriate identification, legibility, storage, protection, archiving, retrieval, retention time, and disposition of records? � Yes � No � No � No � No Component 2 — SAFETY RISK MANAGEMENT Element 2.1 — Hazard identification 45 46 47 48 49 50 51 52 53 54 Does the organization have a formal safety data collection and processing system (SDCPS) for effectively collecting information about hazards in operations? � Yes Does the organization SDCPS include a combination of reactive, proactive and predictive methods of safety data collection? � Yes Does the organization have reactive processes that provide for the capture of information relevant to safety and risk management? � Yes Has the organization developed training relevant to reactive methods of safety data collection? � Yes Has the organization developed communication relevant to reactive methods of safety data collection? � Yes Is reactive reporting simple, accessible and commensurate with the size of the organization? � Yes Are reactive reports reviewed at the appropriate level of management? � Yes Is there a feedback process to notify contributors that their reports have been received and to share the results of the analysis? � Yes Does the organization have proactive processes that actively look for the identification of safety risks through the analysis of the organization’s activities? � Yes Is there training relevant to proactive methods of safety data collection? � Yes 47 � No � No � No � No � No � No � No � No � No � No Status of implementation Items Aspect to be analyzed or question to be answered 55 Has the organization developed communication relevant to proactive methods of safety data collection? � Yes Is proactive reporting simple, accessible and commensurate with the size of the organization? � Yes Does the organization have predictive processes that provide the capture of system performance as it happens in real-time normal operations? � Yes Is there training relevant to predictive methods of safety data collection? � Yes Has the organization developed communication relevant to predictive methods of safety data collection? � Yes Is the predictive safety data capture process commensurate with the size of the organization? � Yes 56 57 58 59 60 Answer � No � No � No � No � No � No Element 2. 2 — Safety risk assessment and mitigation 61 62 63 64 65 Has the [organization] developed and does it maintain a formal process that ensures analysis, assessment and control of the safety risks in the [organization] operations? � Yes Does the [organization] SMS documentation clearly articulate the relationship between hazards, consequences and safety risks? � Yes Is there a structured process for the analysis of the safety risks associated with the consequences of identified hazards, expressed in terms of probability and severity of occurrence? � Yes Are there criteria for assessing safety risks and establishing safety risk tolerability (i.e. the acceptable level of safety risk the organization is willing to accept? � Yes Does the organization have safety risk mitigation strategies that include corrective/preventive action plans to prevent recurrence of reported occurrences and deficiencies? � Yes � No � No � No � No � No Component 3 — SAFETY ASSURANCE Element 3.1 — Safety performance monitoring and measurement 66 67 Has the [organization] implemented an internal process to verify the safety performance of the organization and to validate the effectiveness of safety risks controls? Are the following tools included in those processes? Safety reporting systems � Yes � No Safety studies � Yes � No Safety reviews � Yes � No Safety audits � Yes � No 48 � Yes � No Status of implementation Items Aspect to be analyzed or question to be answered Safety surveys � Yes �No Internal safety investigations 68 69 Answer � Yes � No Is the safety performance of the [organization] verified in reference to the safety performance indicators and safety performance targets of the SMS? � Yes Are safety reports reviewed at the appropriate level of management? � Yes � No � No 70 71 72 73 74 75 76 77 78 79 80 81 82 Is there a feedback process to notify contributors that their reports have been received and to share the results of the analysis? � Yes Are corrective and preventive actions generated in response to hazard identification? � Yes Are there procedures in place for the conduct of internal investigations? � Yes Is there a process to ensure that occurrences and deficiencies reported are analyzed to identify all associated hazards? � Yes Does the organization have a process for evaluating the effectiveness of the corrective/preventive measures that have been developed? � Yes Does the organization have a system to monitor the internal reporting process and the associated corrective actions? � Yes Is there an audit function with the independence and authority required to carry out effective internal evaluations? � Yes Does the audit system cover all functions, activities and organizations within the organization? � Yes Are there selection/training processes to ensure the objectivity and competence of auditors as well as the impartiality of the audit process? � Yes Is there a procedure for reporting audit results and maintaining records? � Yes Is there a procedure outlining requirements for timely corrective and preventive action in response to audit results? � Yes Is there a procedure to record verification of action(s) taken and the reporting of verification results? � Yes Is there a process in place to monitor and analyse trends? � Yes � No � No � No � No � No � No � No � No � No � No � No � No � No Element 3.2 — The management of change 49 Status of implementation Items Aspect to be analyzed or question to be answered 83 Has the [organization] developed and does it maintain a formal process to identify changes within the organization which may affect established processes and services? � Yes Does the formal process for the management of change analyse changes to operations or key personnel for safety risks? � Yes Has the [organization] established arrangements to ensure safety performance prior to implementing changes? � Yes Has the [organization] established a process to eliminate or modify safety risk controls that are no longer needed due to changes in the operational environment? � Yes 84 85 86 Answer � No � No � No � No Element 3.3 — Continuous improvement of the SMS 87 88 89 90 91 Has the [organization] developed and does it maintain a formal process to identify the causes of substandard performance of the SMS? � Yes Has the [organization] established a mechanism(s) to determine the implications of substandard performance of the SMS on operations? � Yes Has the organization established a mechanism(s) to eliminate or mitigate the causes of substandard performance of the SMS? � Yes Does the organization have a process for the proactive evaluation of facilities, equipment, documentation and procedures (through audits and surveys, etc.)? � Yes Does the organization have a process for the proactive evaluation of an individual’s performance, to verify the fulfillment of that individual’s safety responsibilities? � Yes � No � No � No � No � No Component 4 — SAFETY PROMOTION Element 4.1 — Training and education 92 93 94 95 96 Is there a documented process to identify training requirements so that personnel are trained and competent to perform their SMS duties? � Yes Is the safety training appropriate to the individual’s involvement in the SMS? � Yes Is the safety training incorporated into indoctrination training upon employment? � Yes Is there emergency response/contingency training for affected personnel? � Yes Is there a process that measures the effectiveness of training? � Yes � No � No � No � No � No 50 Status of implementation Items Aspect to be analyzed or question to be answered Answer Element 4.2 — Safety communication 97 98 99 100 101 Are there communication processes in place within the [organization] that permit the safety management system to function effectively? � Yes Are there communication processes (written, meetings, electronic, etc.) commensurate with the size and scope of the organization? � Yes Is safety-critical information established and maintained in a suitable medium that provides direction regarding relevant SMS documents? � Yes Is safety-critical information disseminated throughout the [organization] and is the effectiveness of safety communication monitored? � Yes Is there a procedure that explains why particular safety actions are taken and why safety procedures are introduced or changed? � Yes 51 � No � No � No � No � No Status of implementation ATTACHMENT 3 GLOSSARY ALARP As low as reasonably practicable ALoS Acceptable level of safety AMO Approved maintenance organization AOC Air operator certificate EMS environment management system ERP Emergency response plan OHSMS occupational health and safety management system QA Quality assurance QC Quality control QMS Quality management system SA Safety assurance SAG Safety action group SARPs Standards and Recommended Practices (ICAO) SEMS Security Management System SMM Safety management manual SMS Safety management system(s) SMSM Safety management systems manual SOPs Standard operating procedures SRB Safety review board SRM Safety risk management SSP State safety program 52