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SMSPP Phase 0 Federal Aviation Administration 1 Phase 0 of the Safety Management Systems (SMS) Pilot Project Federal Aviation Administration The The Beginning! Beginning!

SMSPP Phase 0 Federal Aviation Administration 1 Phase 0 of the Safety Management Systems (SMS) Pilot Project Federal Aviation Administration The Beginning!

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SMSPP Phase 0 Federal AviationAdministration 1

Phase 0of the Safety Management

Systems (SMS)Pilot Project

Federal AviationAdministration

The Beginning!The Beginning!

SMSPP Phase 0 Federal AviationAdministration 2

AGENDAAGENDA

1.1. IntroductionsIntroductions 5 min 5 min

2.2. Overview of SMSOverview of SMS 45 min45 min

3.3. BreakBreak 15 min15 min

4.4. Use of the SMS GuidebooksUse of the SMS Guidebooks 10 min10 min

5.5. Summary SMS Audit/Gap Analysis ToolSummary SMS Audit/Gap Analysis Tool 10 min10 min

6.6. Detailed SMS Audit/Gap AnalysisDetailed SMS Audit/Gap Analysis ToolsTools 10 min10 min

7.7. Pilot Project Implementation PlanPilot Project Implementation Plan 15 min15 min

8.8. Open DiscussionOpen Discussion 40 min40 min

SMSPP Phase 0 Federal AviationAdministration 3

INTRODUCTIONSINTRODUCTIONS

SMSPP Phase 0 Federal AviationAdministration 4

Overview of Safety Management Systems

(SMS)

Federal AviationAdministration

SMSPP Phase 0 Federal AviationAdministration 5

At this airline, safety is our first priority

Really?

SMSPP Phase 0 Federal AviationAdministration 6

What is the primary objectiveWhat is the primary objectiveof a business organization?of a business organization?

SMSPP Phase 0 Federal AviationAdministration 7

Safety Management – RationaleSafety Management – Rationale

• In order to achieve its production objectives, the In order to achieve its production objectives, the management of any aviation organization requires the management of any aviation organization requires the management of many business processes.management of many business processes.

• Managing safety is one such business process.Managing safety is one such business process.

• Safety management is a core business function just Safety management is a core business function just as financial management, HR management, etc.as financial management, HR management, etc.

• This brings about a This brings about a potentialpotential dilemma for management. dilemma for management.

SMSPP Phase 0 Federal AviationAdministration 8

The management dilemma

ProductionProtectionProtection

ResourcesResourcesManagement levels

SMSPP Phase 0 Federal AviationAdministration 9

The management dilemma

Management levels

Production

ProtectionProtection

Resources

Resources

Catastrophe

SMSPP Phase 0 Federal AviationAdministration 10

The management dilemma

Management levels

Production

ProtectionProtection

Bankruptcy

Resources

Resources

SMSPP Phase 0 Federal AviationAdministration 11

Safety SpaceSafety Space

ProductionProduction

Prot

ectio

nPr

otec

tion

BankruptcyBankruptcy

CatastropheCatastrophe

Source: James Reason

SMSPP Phase 0 Federal AviationAdministration 12

Safety Management –Safety Management – The response to the dilemmaThe response to the dilemma

• Safety issues are a byproduct of activities related to Safety issues are a byproduct of activities related to production/services deliveryproduction/services delivery. .

• An analysis of an organization's resources and goals An analysis of an organization's resources and goals allows for a balanced and realistic allocation of allows for a balanced and realistic allocation of resources between resources between protection and production goalsprotection and production goals, , which supports the needs of the organization.which supports the needs of the organization.

• The product/service provided by any aviation The product/service provided by any aviation organization must be delivered safely (i.e. protecting organization must be delivered safely (i.e. protecting users and stakeholders). users and stakeholders).

SMSPP Phase 0 Federal AviationAdministration 13

What is safety?What is safety?

• Safety is not equivalent to risk free (U.S. Supreme Safety is not equivalent to risk free (U.S. Supreme Court, 1980)Court, 1980)

• Carelessness and overconfidence are more dangerous Carelessness and overconfidence are more dangerous than deliberately accepted risk (Wilbur Wright, 1901)than deliberately accepted risk (Wilbur Wright, 1901)

• Practical safety is Practical safety is risk managementrisk management

SMSPP Phase 0 Federal AviationAdministration 14

Mitigating to “Acceptable Risk”Mitigating to “Acceptable Risk”

““Safety in a system may be defined as a quality of a Safety in a system may be defined as a quality of a system that allows the system to function under system that allows the system to function under predetermined conditions with predetermined conditions with an acceptable an acceptable minimum of accidental lossminimum of accidental loss.”.”

System Safety Engineering & Management, 2nd Edition, John Wiley & Sons 1990 ISBN 0471618160

SMSPP Phase 0 Federal AviationAdministration 15

Why SMS? An imperfect systemWhy SMS? An imperfect system

Operational performance

Operational performance

OperationalOperationaldeploymentdeployment

System System designdesign

Baseline performanceBaseline performance

“Practicaldrift”

SMSPP Phase 0 Federal AviationAdministration 16

Risk Management Risk Management is….is….

Risk Management Risk Management is….is….

….a continuous process….a closed loop process….cross discipline

….a continuous process….a closed loop process….cross discipline

IdentifyHazards

AnalyzeHazard(s)

AssessRisk

ManageRisk

EvaluateHazardControls

ModifyProcess

New Info?

Tracking

SMSPP Phase 0 Federal AviationAdministration 17

A Risk Assessment Matrix ExampleA Risk Assessment Matrix ExampleA Risk Assessment Matrix ExampleA Risk Assessment Matrix Example

Risk severityRisk

probability Catastrophic

AMajor

CMinor

DNegligible

EHazardous

BB

Frequent 5

Occasional 4

Remote 3

Improbable 2

Extremelyimprobable 1

5A5A 5B5B 5C5C 5D5D 5E5E

4A4A 4B4B 4C4C 4D4D 4E4E

3A3A 3B3B 3C3C 3D3D 3E3E

2A2A 2B2B 2C2C 2D2D 2E2E

1A1A 1B1B 1C1C 1D1D 1E1E

SMSPP Phase 0 Federal AviationAdministration 18

Risk AcceptanceRisk Acceptance• Risk is inherentRisk is inherent in aviation operations in aviation operations

• Risk results from aspects of the Risk results from aspects of the environmentenvironment and and byproducts of byproducts of operational activitiesoperational activities

• Operator is responsible for risk managementOperator is responsible for risk management (Title 49 – (Title 49 – FA Act)FA Act)

• A fundamental concept of risk management is A fundamental concept of risk management is acceptance of riskacceptance of risk

• Risk management is fundamental to the SMSRisk management is fundamental to the SMS

SMSPP Phase 0 Federal AviationAdministration 19

Risk

Mgmt.

Safety

Assurance

Policy:(Structure)

Safety Promotion:(Culture)

Four “Pillars” of SMSFour “Pillars” of SMS

SMSPP Phase 0 Federal AviationAdministration 20

SMSSMS is the toolbox for…is the toolbox for…SMSSMS is the toolbox for…is the toolbox for…

• Policies & management Policies & management practicespractices

• Risk Management Risk Management processesprocesses

• Safety Assurance processesSafety Assurance processes

• Confidential reporting Confidential reporting processes/employee processes/employee involvementinvolvement

SMSPP Phase 0 Federal AviationAdministration 21

What is the Regulator’s Duty?What is the Regulator’s Duty?What is the Regulator’s Duty?What is the Regulator’s Duty?

• It is It is NOTNOT safety safety achievement …or achievement …or “management”“management”

• It It ISIS safety “oversight” safety “oversight”

SMSPP Phase 0 Federal AviationAdministration 22

What is the Provider’s Duty?What is the Provider’s Duty?What is the Provider’s Duty?What is the Provider’s Duty?

• Safety achievementSafety achievement is is the responsibility of the the responsibility of the “provider”“provider”

• Safety achievementSafety achievement is is the responsibility of the the responsibility of the “provider”“provider”

The FAA’s resources are best applied in The FAA’s resources are best applied in assisting / enablingassisting / enabling safety management by the safety management by the business or operationbusiness or operation

The FAA’s resources are best applied in The FAA’s resources are best applied in assisting / enablingassisting / enabling safety management by the safety management by the business or operationbusiness or operation

SMSPP Phase 0 Federal AviationAdministration 23

Is ATOS the same as SMS?Is ATOS the same as SMS?

• ATATOSOS: An : An Oversight SystemOversight System used to fulfill FAA safety used to fulfill FAA safety responsibilitiesresponsibilities

• SSMSMS: A : A Management SystemManagement System used to fulfill operator used to fulfill operator safety responsibilitiessafety responsibilities

SMSPP Phase 0 Federal AviationAdministration 24

Process

Operator’s Safety Management

System(SMS-P)

FAA’s Safety Management

System(SMS-O)

ATOS and SMSATOS and SMS

DA PA

FAA (ATOS)Oversight Program

Management(8 Modules)

Air Carrier’sSRM/SA

Outputs areProducts /Services

Inputs

Objective: Serve customer requirements

Objective: Manage safety actions as part of “business”

processes

Objective: Public Safety

Direct sampling(e.g. surveillance)

Protection Production

SRM

SA

SMSPP Phase 0 Federal AviationAdministration 25

SMS for “Providers”SMS for “Providers” isis……SMS for “Providers”SMS for “Providers” isis……

… … a top-down program a top-down program startingstarting with “Top Management”with “Top Management”

SMSPP Phase 0 Federal AviationAdministration 26

A A SMSSMS Organization Organization……A A SMSSMS Organization Organization……

Develops a “Just Culture” or Develops a “Just Culture” or “Safety Culture” to:“Safety Culture” to:

Develops a “Just Culture” or Develops a “Just Culture” or “Safety Culture” to:“Safety Culture” to:

Capture the operational knowledge and experience of the employees

Involve the employees in the safety achievement process

SMSPP Phase 0 Federal AviationAdministration 27

A Positive “Safety” Culture is…A Positive “Safety” Culture is…

……An An informedinformed culture where People understand hazards and culture where People understand hazards and risks.risks.

• Staff work continuously to identify and overcome Staff work continuously to identify and overcome threatsthreats

……A A reportingreporting culture where culture where

• People are encouraged to voice safety concernsPeople are encouraged to voice safety concerns• Those concerns are analyzed and appropriate action Those concerns are analyzed and appropriate action

is takenis taken• The workforce knows and agrees on what is The workforce knows and agrees on what is

acceptable and unacceptable (shared values)acceptable and unacceptable (shared values)

Dr. James Reason

SMSPP Phase 0 Federal AviationAdministration 28

……A A learninglearning culture where: culture where:• People are encouraged to develop and apply their skills People are encouraged to develop and apply their skills

and knowledge to enhance organizational safetyand knowledge to enhance organizational safety

• Management updates staff on safety issuesManagement updates staff on safety issues

• Safety reports are fed back to staff so everyone learnsSafety reports are fed back to staff so everyone learns

……A A justjust culture where: culture where:• The workforce knows and agrees on what isThe workforce knows and agrees on what is

acceptable and unacceptable (shared values)acceptable and unacceptable (shared values)

• Errors are understoodErrors are understood but willful violationsbut willful violationsare not toleratedare not tolerated

A Positive “Safety” Culture is…A Positive “Safety” Culture is…

SMSPP Phase 0 Federal AviationAdministration 29

What’s in a “Just Culture?”What’s in a “Just Culture?”What’s in a “Just Culture?”What’s in a “Just Culture?”

• The immediate response is to find The immediate response is to find “what happened and why,” “what happened and why,” not “who to blame and punish”not “who to blame and punish”

• Acceptance that more can be Acceptance that more can be learned through full reporting and learned through full reporting and detailed investigation than by blame detailed investigation than by blame and punishmentand punishment

• Partnership in identifying hazards Partnership in identifying hazards and root causesand root causes

SMSPP Phase 0 Federal AviationAdministration 30

SMSSMS…emphasizes Risk …emphasizes Risk ManagementManagementSMSSMS…emphasizes Risk …emphasizes Risk ManagementManagement

……It integrates safety It integrates safety with with Line Line ManagementManagement

SMSPP Phase 0 Federal AviationAdministration 31

The International PictureThe International PictureThe International PictureThe International Picture

Annex 11 - Air Traffic Annex 11 - Air Traffic Services Services

Annex 14 - AerodromesAnnex 14 - Aerodromes Annex 6 - Operation of Annex 6 - Operation of

AircraftAircraft Annex 6 - Maintenance of Annex 6 - Maintenance of

AircraftAircraft

ICAO safety management requirementsICAO safety management requirements

SMSPP Phase 0 Federal AviationAdministration 32

ICAO Annex 6 RequirementsICAO Annex 6 Requirements• “…“…a safety management system acceptable to the State a safety management system acceptable to the State

of the Operator that, as a minimum:of the Operator that, as a minimum:• identifiesidentifies safety safety hazardshazards;;

• ensures that ensures that remedial actionremedial action necessary to maintain an necessary to maintain an acceptable level of safety is implemented; andacceptable level of safety is implemented; and

• provides for provides for continuous monitoringcontinuous monitoring and and regular assessmentregular assessment of the safety level achieved.”of the safety level achieved.”

• ……and, aims to make and, aims to make continuous improvementcontinuous improvement to the overall level to the overall level of safety (proposed amendment)of safety (proposed amendment)

SMSPP Phase 0 Federal AviationAdministration 33

Annex 6 requirements (cont.)Annex 6 requirements (cont.)• ““An accepted safety management system shall clearly An accepted safety management system shall clearly

define lines of safetydefine lines of safety accountabilityaccountability throughout the throughout the operator’s organization, including a direct accountability operator’s organization, including a direct accountability for safety on the part of senior management.”for safety on the part of senior management.”

SMSPP Phase 0 Federal AviationAdministration 34

An Industry Answer?An Industry Answer?An Industry Answer?An Industry Answer?

ICAO, FAA, overseas Regulators, Air Carriers, ALPA, IATA, IBACICAO, FAA, overseas Regulators, Air Carriers, ALPA, IATA, IBAC

Launching a commoncommon idea and a new approach:

Launching a commoncommon idea and a new approach:

SMSSMSSMSSMS

SMSPP Phase 0 Federal AviationAdministration 35

FAA Support of the SMS ConceptFAA Support of the SMS Concept

• U.S. Response to the Annex 6 proposal endorsed the U.S. Response to the Annex 6 proposal endorsed the SMS conceptSMS concept

• Prior U.S. implementation of system safety-based Prior U.S. implementation of system safety-based oversight systemsoversight systems

• ATOSATOS

• SASOSASO

• FAA (AVS) will also apply safety management concepts FAA (AVS) will also apply safety management concepts to oversight activitiesto oversight activities

SMSPP Phase 0 Federal AviationAdministration 36

The SMS StandardThe SMS Standard

• First FAA SMS standard was delivered onFirst FAA SMS standard was delivered onJune 22, 2006 in Advisory Circular AC 120-92.June 22, 2006 in Advisory Circular AC 120-92.

• SMSs are currently voluntary in the United StatesSMSs are currently voluntary in the United States

• The standard is organized around the “four pillars”The standard is organized around the “four pillars”

• The standard is based on an extensive review of existing The standard is based on an extensive review of existing SMSs around the worldSMSs around the world

• The format of the SMS standard is similar to that of the The format of the SMS standard is similar to that of the ISO standardsISO standards

SMSPP Phase 0 Federal AviationAdministration 37

Rulemaking EffortRulemaking Effort

• Part 121 Rulemaking Project Record (RPR) opened Part 121 Rulemaking Project Record (RPR) opened Nov. 2006Nov. 2006

• Project cancelled Jan. 2008Project cancelled Jan. 2008

• Project team commissioned to create integrated SMS Project team commissioned to create integrated SMS Rule for all CFR partsRule for all CFR parts

• Objective: harmonization of requirementsObjective: harmonization of requirements

• Strategy is being formulatedStrategy is being formulated

• ARC is a possibilityARC is a possibility

SMSPP Phase 0 Federal AviationAdministration 38

TestimonialsTestimonials – –

• ““Why didn’t TC do this years ago?” Why didn’t TC do this years ago?” (705 Operator) (705 Operator)

• ““We are now much more aware of our safety We are now much more aware of our safety responsibilities and liabilities.” responsibilities and liabilities.” (AMO)(AMO)

• ““My employees are involved in developing the SMS My employees are involved in developing the SMS processes. They tell me they feel safer at work.” processes. They tell me they feel safer at work.” (small AMO)(small AMO)

• ““It is too early to realize all the benefits of SMS, but It is too early to realize all the benefits of SMS, but already employees and customers have an increased already employees and customers have an increased confidence in the company. confidence in the company. (AMO)(AMO)

• ““Already we are seeing the benefits of recording and Already we are seeing the benefits of recording and tracking incidents and hazards” tracking incidents and hazards” (FTU)(FTU)

• ““The idea of SMS is much scarier than the actuality.” The idea of SMS is much scarier than the actuality.” (702,703 Helicopter Operator).(702,703 Helicopter Operator).

SMSPP Phase 0 Federal AviationAdministration 39

OthersOthers

Air Transat initially saved over $1 million per monthAir Transat initially saved over $1 million per month

Skyservice saved $5 million in first year of SMS Skyservice saved $5 million in first year of SMS operationoperation

SMSPP Phase 0 Federal AviationAdministration 40

BREAKBREAK

SMSPP Phase 0 Federal AviationAdministration 41

SMS Implementationand Tools

Federal AviationAdministration

SMSPP Phase 0 Federal AviationAdministration 42

The purpose of the Guidebooks is to provide a framework The purpose of the Guidebooks is to provide a framework and offer developmental guidance to aid organizations in and offer developmental guidance to aid organizations in defining their organizational safety structure. defining their organizational safety structure.

SMS SMS GuidebooksGuidebooks

SMSPP Phase 0 Federal AviationAdministration 43

Format of the GuidebookFormat of the Guidebook

• ((OBJ) are objectives.OBJ) are objectives. This information describes or outlines what This information describes or outlines what you will be expected to develop in this specific area of your Safety you will be expected to develop in this specific area of your Safety Management System documentation, in order to meet an SMS Management System documentation, in order to meet an SMS standard.standard.

• (STD) are standards.(STD) are standards. This is the specific language of the standard This is the specific language of the standard that the organization will be held to in order to meet the statement of that the organization will be held to in order to meet the statement of requirements conveyed in the policy/procedure section.requirements conveyed in the policy/procedure section.

• (DG) is developmental guidance(DG) is developmental guidance This provides instruction This provides instruction regarding how you can develop your policy, procedures, and regarding how you can develop your policy, procedures, and controls to address each specific requirement of the Safety controls to address each specific requirement of the Safety Management System. Management System.

SMSPP Phase 0 Federal AviationAdministration 44

Example Section of the GuidebookExample Section of the Guidebook

• 4.4 Safety Planning4.4 Safety Planning

(OBJ) The expectation of this section is that you describe your safety management plan to meet the (OBJ) The expectation of this section is that you describe your safety management plan to meet the objectives described by your above stated safety policy.objectives described by your above stated safety policy.

(DG) Management has historically been defined as planning, organizing, directing, and controlling. Therefore a Safety Management System will start with a plan to meet the Safety Objectives. A plan should be set by Top Management that will direct and sequence the implementation of the Safety Management System. Planning at one level becomes direction at the next level. The first thing to plan is how much and on what time table the various portions of the Safety Management System will be created, who will be responsible for the overall system and the various portions of it.

(STD) - FAA Advisory Circular AC 120-92 Appendix 1

4.4. Safety Planning

The organization shall establish and maintain a safety management plan to meet the

safety objectives described in its safety policy.

SMSPP Phase 0 Federal AviationAdministration 45

• High level assessment toolHigh level assessment tool

• To be utilized for initial screening or audit To be utilized for initial screening or audit summarysummary

• Questions at the objective level Questions at the objective level

• Evaluates the organization’s existing systems Evaluates the organization’s existing systems to determine conformance to the SMS to determine conformance to the SMS standardsstandards

Summary Audit/Gap Analysis ToolSummary Audit/Gap Analysis Tool

SMSPP Phase 0 Federal AviationAdministration 46

Summary Audit/Gap Analysis Tool Summary Audit/Gap Analysis Tool

•Evaluate Objectives utilizing assessment scales

•Measure the level of development for each objective

0 – No action 1 – Action initiated2 – Implemented3 – Integrated4 – Evaluated and Sustained5 – State of Art

SMSPP Phase 0 Federal AviationAdministration 47

Summary Audit/Gap Analysis Tool Summary Audit/Gap Analysis Tool

No action = 0 Action

initiated=1

Implemented=2

Integrated=3Evaluated and Sustained=4

State of Art=5

SMSPP Phase 0 Federal AviationAdministration 48

Audit/Gap Analysis ToolsAudit/Gap Analysis Tools

• Detailed assessment of the organization’s existing Detailed assessment of the organization’s existing systems to determine conformance to the SMS systems to determine conformance to the SMS standards standards

• Used to determine what needs to be developedUsed to determine what needs to be developed

• After implementation, to assess continued performance After implementation, to assess continued performance of the systemof the system

• Final gap analysis prior to implementation planning Final gap analysis prior to implementation planning must must be based on the be based on the full full set of tools to ensure that all of the set of tools to ensure that all of the standard's requirements are included in the system standard's requirements are included in the system designdesign

SMSPP Phase 0 Federal AviationAdministration 49

Audit/Gap Analysis Tools Audit/Gap Analysis Tools

System 8.0 of the Air Transportation Oversight System System 8.0 of the Air Transportation Oversight System (ATOS):(ATOS):

• Includes the SMS pillars as subsystemsIncludes the SMS pillars as subsystems

8.1 Policy8.1 Policy

8.2 Safety Risk Management8.2 Safety Risk Management

8.3 Safety Risk Assessment8.3 Safety Risk Assessment

8.4 Safety8.4 Safety

• 13 Design Assessment Tools based on major13 Design Assessment Tools based on majorsub-clauses of the Standardsub-clauses of the Standard

SMSPP Phase 0 Federal AviationAdministration 50

Audit/Gap Analysis ToolsAudit/Gap Analysis Tools

8.1.1 Organizational Management8.1.1 Organizational Management8.1.2 Documentation and Records Management8.1.2 Documentation and Records Management8.1.3 Emergency Preparedness and Response8.1.3 Emergency Preparedness and Response8.2.1 System and Task Analysis8.2.1 System and Task Analysis8.2.2 Hazard Identification8.2.2 Hazard Identification8.2.3 Safety Risk Analysis and Assessment8.2.3 Safety Risk Analysis and Assessment8.2.4 Safety Risk Controls8.2.4 Safety Risk Controls8.3.1 Data Acquisition8.3.1 Data Acquisition8.3.2 Data Analysis and System Assessment8.3.2 Data Analysis and System Assessment8.3.3 Corrective and Preventive Action8.3.3 Corrective and Preventive Action8.4.1 Communication and Awareness8.4.1 Communication and Awareness8.4.2 Personnel Qualifications and Training8.4.2 Personnel Qualifications and Training

SMSPP Phase 0 Federal AviationAdministration 51

Detailed Audit/Gap Analysis Tools Detailed Audit/Gap Analysis Tools

• Utilizes ATOS SAI format

• Has a stated functional objective - expectations and outcomes

• Questions in the procedures section of each element are based on specific requirements in the standard

• Requirements evaluated utilizing assessment scales and scales measure the level of conformance with each requirement

0 – No action 1 – Action initiated2 – Implemented3 – Integrated4 – Evaluated and Sustained5 – State of Art

SMSPP Phase 0 Federal AviationAdministration 52

Example: Design Assessment ToolExample: Design Assessment Tool

SMSPP Phase 0 Federal AviationAdministration 53

Example: Design Assessment Tool: DetailExample: Design Assessment Tool: Detail

SMSPP Phase 0 Federal AviationAdministration 54

Standard and Audit/Gap Analysis ToolsStandard and Audit/Gap Analysis Tools

1 2 3 4

Safety Management System 8.0 Safety Management System4. Policy 8.1 SMS Management4.1. General Requirements 8.1.1 Organizational Management √ √4.2. Safety Policy 8.1.1 Organizational Management √ √4.3. Quality Policy 8.1.1 Organizational Management √ √4.4. Safety Planning 8.1.1 Organizational Management √ √4.5. Organizational Structure and Responsibilities 8.1.1 Organizational Management √ √4.6. Compliance with Legal and Other Requirements 8.1.1 Organizational Management √ √4.7. Procedures and Controls All √ √ √ √4.8. Emergency preparedness and Response 8.1.3 Emergency Response √4.9. Documentation and Records Management 8.1.2 Document and Records Management √ √ √ √5. Safety Risk Management 8.2 Safety Risk Management5.1. System and Task Analysis 8.2.1 System and Task Analysis √5.2. Identify Hazards 8.2.2 Hazard Identification √ √5.3. Analyze Safety Risk 8.2.3 Risk Analysis and Assessment √ √5.4. Assess Safety Risk 8.2.3 Risk Analysis and Assessment √ √5.5. Control Safety Risk 8.2.4 Risk Control √ √5.6. Operational Risk Management (Proposed) 8.2.5 Operational Risk Management (Proposed)5.7 Management of Change (Proposed)6. Safety Assurance and Internal Evaluation 8.3 Safety Assurance6.1. General Requirements 8.3.2 Data Analysis/System Assessment √ √6.2. System Description 8.2.1 System and Task Analysis √6.3. Information Acquisition 8.3.1 Data Acquisition √ √ √6.4. Analysis of Data 8.3.2 Data Analysis/System Assessment √ √6.5. System Assessment 8.3.2 Data Analysis/System Assessment √ √6.6. Preventive/Corrective Action 8.3.3 Preventive/Corrective Action √ √6.7. Management Reviews 8.3.2 Data Analysis/System Assessment √ √6.8. Continual Improvement 8.1.1 Organizational Management √7. Safety Promotion 8.4 Safety Promotion7.1. Safety Culture All √ √ √ √7.2. Communication and Awareness 8.4.1 Communication and Awareness √7.3. Personnel Requirements (Competence) 8.4.2 Personnel Qualification and Training √ √ √ √7.4. Training 8.4.2 Personnel Qualification and Training √ √ √ √

7.5. Safety Lessons Learned

8.3.2 Data Analysis/System Assessment 8.4.1 Communication and Awareness √ √ √

PhaseStandard Audit Tool*

SMSPP Phase 0 Federal AviationAdministration 55

SMS Pilot ProjectSMS Pilot Project

• A set of confirmatory trials that consist of voluntary A set of confirmatory trials that consist of voluntary SMS development and interface with oversight systemsSMS development and interface with oversight systems

• The purpose is to gather data to be used in further The purpose is to gather data to be used in further development of guidance material, implementation development of guidance material, implementation strategies, and oversight systemsstrategies, and oversight systems

SMSPP Phase 0 Federal AviationAdministration 56

Industry & FAA Industry & FAA SMSSMS Implementation ImplementationIndustry & FAA Industry & FAA SMSSMS Implementation Implementation

• Should follow a Should follow a phased approachphased approach

• The processes underlying the four The processes underlying the four pillars will be modularizedpillars will be modularized

• ““Growth” or “increasing maturity” will Growth” or “increasing maturity” will then be emphasized for each then be emphasized for each process and the system as a wholeprocess and the system as a whole

• Should follow a Should follow a phased approachphased approach

• The processes underlying the four The processes underlying the four pillars will be modularizedpillars will be modularized

• ““Growth” or “increasing maturity” will Growth” or “increasing maturity” will then be emphasized for each then be emphasized for each process and the system as a wholeprocess and the system as a whole

SMSPP Phase 0 Federal AviationAdministration 57

SMSSMS Implementation ProcessImplementation Process

0Orientation &Commitment

2ReactiveProcesses

3ProactiveProcesses

4ContinuousImprovement

1Planning &Organization

SMSPP Phase 0 Federal AviationAdministration 58

Purpose and Methodology of SMSPurpose and Methodology of SMS

• Phased implementation: Phased implementation: a logical process for building a logical process for building the SMSthe SMS

• Management capability: Management capability: Each step in the model will Each step in the model will increase and strengthen management capabilityincrease and strengthen management capability

• Process based uponProcess based upon• ICAO recommendations and ICAO recommendations and • Capability Maturity Model (CMM) conceptsCapability Maturity Model (CMM) concepts

SMSPP Phase 0 Federal AviationAdministration 59

Who’s Involved in Implementation?Who’s Involved in Implementation?

• The OperatorThe Operator

• The Certificate Management Organization (CMO, The Certificate Management Organization (CMO, FSDO, CHDO)FSDO, CHDO)

• The Standardization and Assistance Team (SAT)The Standardization and Assistance Team (SAT)

SMSPP Phase 0 Federal AviationAdministration 60

Level Zero: Orientation and CommitmentLevel Zero: Orientation and Commitment

• Outreach presentationsOutreach presentations

• Understanding what’s aheadUnderstanding what’s ahead

• Establishing the relationshipEstablishing the relationship

• Securing the commitment from top managementSecuring the commitment from top management

SMSPP Phase 0 Federal AviationAdministration 61

Level 1: Planning & OrganizationLevel 1: Planning & Organization Charting the Course Charting the Course

• The Gap Analysis: Evaluating existing processes, The Gap Analysis: Evaluating existing processes, programs, and practices for safety managementprograms, and practices for safety management

• The Implementation PlanThe Implementation Plan

• Organizing for ImplementationOrganizing for Implementation

SMSPP Phase 0 Federal AviationAdministration 62

Level 1 - MeetingsLevel 1 - Meetings

Session 1 (Today)Session 1 (Today)• SAT to Brief: SAT to Brief:

• SMS Process Map SMS Process Map • SMS ObjectivesSMS Objectives• Summary Audit/Gap Analysis ToolSummary Audit/Gap Analysis Tool• Detailed Audit/Gap Analysis Tools Detailed Audit/Gap Analysis Tools

• Jointly Perform Summary Gap Analysis Jointly Perform Summary Gap Analysis • Schedule Operator’s Gap Analysis Out BriefSchedule Operator’s Gap Analysis Out Brief

• The operator may require 4 to 6 months to complete the The operator may require 4 to 6 months to complete the detailed gap analysis. SAT and CMT will be available detailed gap analysis. SAT and CMT will be available on call while the operator is performing this task.on call while the operator is performing this task.

SMSPP Phase 0 Federal AviationAdministration 63

Level 1 - MeetingsLevel 1 - MeetingsSession 2Session 2

• Operator to Brief:Operator to Brief:• Overview of their Gap AnalysisOverview of their Gap Analysis• Gaps found and how they may develop processes to close the gaps.Gaps found and how they may develop processes to close the gaps.

• Operator to Discuss Documentation Operator to Discuss Documentation • Operator to present objective evidence of conformityOperator to present objective evidence of conformity

• Operator to Identify Resource and Training Needs Operator to Identify Resource and Training Needs • SAT may provide additional training if necessary as a result of this SAT may provide additional training if necessary as a result of this

discussion.discussion.

• SAT to Brief on Planning Process SAT to Brief on Planning Process • Schedule for Operator’s SMS Implementation Plan Out BriefSchedule for Operator’s SMS Implementation Plan Out Brief

• The operator may require 2 to 4 months to complete the detailed The operator may require 2 to 4 months to complete the detailed implementation plan development.implementation plan development.

• Estimated time for this session is one day of presentation of gap Estimated time for this session is one day of presentation of gap analysis by the operator. Half to one day of SAT presentation and analysis by the operator. Half to one day of SAT presentation and discussions of the planning processes.discussions of the planning processes.

SMSPP Phase 0 Federal AviationAdministration 64

Level 1 - MeetingsLevel 1 - Meetings

Session 3Session 3

• Operator’s Presentation of Implementation Plan Operator’s Presentation of Implementation Plan

• Detailed presentation and discussion of their SMS implementation Detailed presentation and discussion of their SMS implementation plan involving the operator, CMT and SATplan involving the operator, CMT and SAT

• Consensus on Plan Consensus on Plan

• Agreement on the implementation plan among operator, CMT and Agreement on the implementation plan among operator, CMT and SATSAT

• Exit Level 1Exit Level 1

• Agreement among operator, CMT and SAT that the participant is Agreement among operator, CMT and SAT that the participant is ready to move the next phase of the pilot project.ready to move the next phase of the pilot project.

• Estimated time for this session is one day of presentation by Estimated time for this session is one day of presentation by the operator.the operator.

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Level 1 – Completion CriteriaLevel 1 – Completion Criteria• Identify and assign safety responsibilities to managers.Identify and assign safety responsibilities to managers.

1.1 Management commitment and responsibility (4.2B, 4.5A, 4.5B)1.1 Management commitment and responsibility (4.2B, 4.5A, 4.5B)1.2 Safety responsibilities of managers (4.5D, 4.1)1.2 Safety responsibilities of managers (4.5D, 4.1)

• Identify the person responsible for implementing the SMS.Identify the person responsible for implementing the SMS.1.3 Appointment of key safety personnel (4.5C)1.3 Appointment of key safety personnel (4.5C)

• Describe the system.Describe the system.1.4 SMS implementation plan (4.4, 4.1)1.4 SMS implementation plan (4.4, 4.1)

• Conduct a gap analysis of existing resources compared to SMS requirements.Conduct a gap analysis of existing resources compared to SMS requirements.1.4 SMS implementation plan (4.4)1.4 SMS implementation plan (4.4)

• Develop an SMS implementation plan.Develop an SMS implementation plan.1.4 SMS implementation plan (4.4)1.4 SMS implementation plan (4.4)

• Develop documentation relevant to safety policy and objectives.Develop documentation relevant to safety policy and objectives.1.6 Documentation (4.9)1.6 Documentation (4.9)

• Develop and establish means for safety communication.Develop and establish means for safety communication.4.2 Safety communication (7.2)4.2 Safety communication (7.2)

• Communicate the SMS implementation to all employees.Communicate the SMS implementation to all employees.4.2 Safety communication (7.2)4.2 Safety communication (7.2)

• Develop an initial training plan for all employees.Develop an initial training plan for all employees.4.1 Training and education (7.4) 4.1 Training and education (7.4)

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Level 1 Assessment CriteriaLevel 1 Assessment CriteriaThe assessment will be accomplished using the Audit/Gap The assessment will be accomplished using the Audit/Gap

Analysis Tools below:Analysis Tools below:• 8.1.1. Organizational Management 8.1.1. Organizational Management • 8.1.2. Document and Records Management8.1.2. Document and Records Management• 8.4.1. Communication and Awareness8.4.1. Communication and Awareness• 8.4.2. Personnel Qualification and Training8.4.2. Personnel Qualification and Training

All questions on these tools should achieve a score of at All questions on these tools should achieve a score of at least 1, as defined on the next slide. All individual least 1, as defined on the next slide. All individual questions receiving less than a score of 1 will be questions receiving less than a score of 1 will be reviewed by the Participant, the CMO and the SAT for reviewed by the Participant, the CMO and the SAT for creation of a mutually agreeable solution. creation of a mutually agreeable solution.

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Level 1 Assessment ScaleLevel 1 Assessment ScaleSAI Assessment Scale

Score Assessment Word Picture

0 No Action No action has been taken on this requirement of the standard.

1 Action Initiated Identifiable actions have been taken to satisfy this requirement of the standard. All responsibilities, processes and procedures are documented. However, the implementation of those defined actions is not complete. Example: 8.1.1 Section 2, Question 1. Does the operator have a control or controls in place to ensure that all SMS processes are documented, monitored, measured, and analyzed? To achieve a score of 1, the Participant must have policies and procedures defined and written on how the process will be monitored, measured and analyzed, but does not have to have taken any actions to actually do the monitoring, measuring or analysis.

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Level 1 - DocumentsLevel 1 - Documents

• Management Commitment LetterManagement Commitment Letter• Management responsibilities definedManagement responsibilities defined• Safety Policy and Objectives Safety Policy and Objectives • Safety responsibilities for managers definedSafety responsibilities for managers defined• Results of Gap Analysis for the department/area under Results of Gap Analysis for the department/area under

the Pilot Programthe Pilot Program• SMS Implementation Plan for the entire organizationSMS Implementation Plan for the entire organization• All Employee Letter or equivalent advising employees of All Employee Letter or equivalent advising employees of

the SMS implementationthe SMS implementation• SMS Training Plan for all employees SMS Training Plan for all employees

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Level 1 - Expectations Level 1 - Expectations

• Development Partner– Sessions 1

• Complete summary gap analysis

– Session 2• Completed detailed gap analysis utilizing the detailed audit/gap analysis

tools for Level 1

• Brief gap analysis results

• Brief gaps and how they will be addressed

• Provide evidence of conformity

– Session 3• Present implementation plan

• Complete the required documents

• Meet the requirements of the exit criteria for this phase

• Provide process inputs to the SAT

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Level 1 - Expectations Level 1 - Expectations

• Oversight Organization– Review and utilize (if desired) audit/gap analysis tools

– Attend audit/gap analysis meetings with the operator

– Participate in meetings with the SAT and operator

– Review the operators implementation plan and other documents

– Discuss the requirements of the exit criteria for this phase with the operator and SAT

– Provide input to the SAT regarding the SMS implementation, documents and audit tools

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Level 1 - Expectations Level 1 - Expectations

• SAT – All Levels

– Provide assistance, as requested, to the Development Partner and its Oversight Organization throughout the Pilot Project period.

– Participate in meetings with the CMT and operator, if requested

– Review the operators implementation plan and other documents

– Discuss the requirements of the exit criteria for this phase with the operator and CMT

– Receive Pilot Project inputs from the Development Partner and Oversight Organization

– Report on summarized data gathered from the Pilot Project

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Level 2: Reactive ProcessesLevel 2: Reactive Processes Basic Risk Management Basic Risk Management

• Setting up the Setting up the information infrastructureinformation infrastructure and processes and processes

• Going after known problems: Reactive Going after known problems: Reactive Hazard IdentificationHazard Identification

• Designing and implementing Designing and implementing risk controlsrisk controls

• DocumentationDocumentation

• TrainingTraining• General initial trainingGeneral initial training• Specialist trainingSpecialist training

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Level 2 – Completion CriteriaLevel 2 – Completion Criteria• Implement safety risk management (SRM) for reactive processes.Implement safety risk management (SRM) for reactive processes.

2.1 Hazard identification process (5.2)2.1 Hazard identification process (5.2)

2.2 Risk assessment and mitigation processes (5.3, 5.4, 5.5)2.2 Risk assessment and mitigation processes (5.3, 5.4, 5.5)

2.3 Internal safety investigations (6.3.5)2.3 Internal safety investigations (6.3.5)

• Perform training relevant to SMS implementation plan and SRM Perform training relevant to SMS implementation plan and SRM components.components.

4.1 Training and education (7.4)4.1 Training and education (7.4)

• Develop documentation relevant to SMS implementation plan and Develop documentation relevant to SMS implementation plan and SRM components (reactive processes).SRM components (reactive processes).

1.4 SMS implementation plan (4.4)1.4 SMS implementation plan (4.4)

1.6 Documentation (4.9)1.6 Documentation (4.9)

• Initiate a non-punitive voluntary employee reporting system. (6.3.6, Initiate a non-punitive voluntary employee reporting system. (6.3.6, 4.2B5)4.2B5)

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Level 2 - DocumentsLevel 2 - Documents

• Processes and procedures for operating Processes and procedures for operating the SMS to the level of assessment and the SMS to the level of assessment and actions reactively actions reactively

• Voluntary employee reporting programVoluntary employee reporting program

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Level 2 – Audit/Gap Analysis ToolsLevel 2 – Audit/Gap Analysis Tools

• 8.1.2 Document and Records Management 8.1.2 Document and Records Management • 8.1.3 Emergency Response8.1.3 Emergency Response• 8.2.2 Hazard Identification8.2.2 Hazard Identification• 8.2.3 Risk Analysis and Assessment8.2.3 Risk Analysis and Assessment• 8.2.4 Risk Control8.2.4 Risk Control• 8.3.1 Data Acquisition8.3.1 Data Acquisition• 8.3.2 Data Analysis/System Assessment8.3.2 Data Analysis/System Assessment• 8.3.3 Preventive/Corrective Action8.3.3 Preventive/Corrective Action• 8.4.1 Communication and Awareness8.4.1 Communication and Awareness• 8.4.2 Personnel Qualification and Training8.4.2 Personnel Qualification and Training

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Level 3: Proactive ProcessesLevel 3: Proactive Processes Looking Ahead Looking Ahead

• System and task analysisSystem and task analysis of the operational of the operational (production) systems(production) systems

• Proactive Hazard identificationProactive Hazard identification

• Updating:Updating:• the risk controlsthe risk controls• Updating the documentationUpdating the documentation• Additional specialist trainingAdditional specialist training

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Level 3 – Completion CriteriaLevel 3 – Completion Criteria

• Implement safety risk management for proactive and predictive processes.Implement safety risk management for proactive and predictive processes.

2.1 Hazard identification process (5.2)2.1 Hazard identification process (5.2)

2.2 Risk assessment and mitigation processes (5.3, 5.4, 5.5)2.2 Risk assessment and mitigation processes (5.3, 5.4, 5.5)2.3 Internal safety investigations (6.3.5)2.3 Internal safety investigations (6.3.5)

• Perform training relevant to proactive and predictive processes.Perform training relevant to proactive and predictive processes.

4.1 Training and education (7.4)4.1 Training and education (7.4)

• Develop documentation relevant to proactive and predictive processes.Develop documentation relevant to proactive and predictive processes.

1.4 SMS implementation plan (4.4)1.4 SMS implementation plan (4.4)

1.6 Documentation (4.9)1.6 Documentation (4.9)

• Perform a system and task analysis for one department (5.1)Perform a system and task analysis for one department (5.1)• Incorporate hazards from system and task analysis into SRM (5.1 – 5.5)Incorporate hazards from system and task analysis into SRM (5.1 – 5.5)• Develop policies and procedures for safety assurance (6.2)Develop policies and procedures for safety assurance (6.2)

• Information acquisition (6.3)Information acquisition (6.3)• Analysis of data (6.4)Analysis of data (6.4)• System assessment (6.5)System assessment (6.5)• Preventive and corrective actions (6.6)Preventive and corrective actions (6.6)• Management reviews (6.7)Management reviews (6.7)

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Level 3 - DocumentsLevel 3 - Documents

• All processes and procedures for All processes and procedures for operating the SMS. operating the SMS.

• Safety assurance policy and procedures Safety assurance policy and procedures must be documented.must be documented.

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Level 3 – Audit/Gap Analysis ToolsLevel 3 – Audit/Gap Analysis Tools

• 8.1.2 Document and Records Management 8.1.2 Document and Records Management • 8.2.1 System and Task Analysis8.2.1 System and Task Analysis• 8.2.2 Hazard Identification8.2.2 Hazard Identification• 8.2.3 Risk Analysis and Assessment8.2.3 Risk Analysis and Assessment• 8.2.4 Risk Control8.2.4 Risk Control• 8.3.1 Data Acquisition8.3.1 Data Acquisition• 8.3.2 Data Analysis/System Assessment8.3.2 Data Analysis/System Assessment• 8.3.3 Preventive/Corrective Action8.3.3 Preventive/Corrective Action• 8.4.1 Communication and Awareness8.4.1 Communication and Awareness• 8.4.2 Personnel Qualification and Training8.4.2 Personnel Qualification and Training

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Level 4: Continuous ImprovementLevel 4: Continuous Improvement Continued Assurance Continued Assurance

• Mature safety assurance processMature safety assurance process• Analysis of dataAnalysis of data• System performance assessmentSystem performance assessment• Corrective/Preventive action: Maintaining the Corrective/Preventive action: Maintaining the

controlscontrols• Identifying new and emerging hazardsIdentifying new and emerging hazards

• Management Reviews: Formal involvementManagement Reviews: Formal involvement

• Documentation & Training as requiredDocumentation & Training as required

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Level 4: Continuous ImprovementLevel 4: Continuous Improvement

• This is the final stage of maturity of the SMSThis is the final stage of maturity of the SMS

• Continuous improvement is based on:Continuous improvement is based on:• ContinuousContinuous risk management risk management, and, and• Continuous Continuous safety assurancesafety assurance

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Level 4 – Completion CriteriaLevel 4 – Completion Criteria

• Implement an operational safety assurance program (6.x)Implement an operational safety assurance program (6.x)

3.1 Safety performance monitoring and measurement (6.3.1 - 6.3.3)3.1 Safety performance monitoring and measurement (6.3.1 - 6.3.3)

3.2 The management of change (5B4, 5E)3.2 The management of change (5B4, 5E)

3.3 Continuous improvement of the safety system (6.8, 4.2B2)3.3 Continuous improvement of the safety system (6.8, 4.2B2)

• Develop acceptable level(s) of safety (4.7)Develop acceptable level(s) of safety (4.7)

• Develop safety indicators and targets (4.7)Develop safety indicators and targets (4.7)

• Perform training relevant to operational safety assurance.Perform training relevant to operational safety assurance.

4.1 Training and education (7.4)4.1 Training and education (7.4)

• Develop documentation relevant to operational safety assurance.Develop documentation relevant to operational safety assurance.

1.6 Documentation (4.9)1.6 Documentation (4.9)

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Level 4 - DocumentsLevel 4 - Documents

All SMS program documents that have All SMS program documents that have been previously developed should be been previously developed should be reviewed to ensure that any changes, reviewed to ensure that any changes, amendments or maturity in the processes amendments or maturity in the processes or procedures have been appropriately or procedures have been appropriately documented.documented.

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Level 4 – Audit/Gap Analysis ToolsLevel 4 – Audit/Gap Analysis Tools

• 8.1.1 Organizational Management8.1.1 Organizational Management• 8.1.2 Document and Records Management 8.1.2 Document and Records Management • 8.3.1 Data Acquisition8.3.1 Data Acquisition• 8.3.2 Data Analysis/System Assessment8.3.2 Data Analysis/System Assessment• 8.4.2 Personnel Qualification and Training8.4.2 Personnel Qualification and Training

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Interfaces and IntegrationInterfaces and Integration• Regulatory OversightRegulatory Oversight

• ATOSATOS• Safety AssuranceSafety Assurance

• CASSCASS• IEPIEP

• Employee ReportingEmployee Reporting• ASRSASRS• ASAPASAP

• Compliance and Enforcement: InterfacesCompliance and Enforcement: Interfaces• VDRPVDRP• EDTEDT

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Voluntary Implementation of SMSVoluntary Implementation of SMS

• Advisory Circular has been DraftedAdvisory Circular has been Drafted

• Process Based on AC 120-92Process Based on AC 120-92

• Interim Solution while rulemaking is ongoingInterim Solution while rulemaking is ongoing

• Award SystemAward System• Bronze:Bronze: Maturity Level 2: Risk Management Program Maturity Level 2: Risk Management Program• Silver:Silver: Maturity level 3: SMS (provisional) Maturity level 3: SMS (provisional)• Gold:Gold: Maturity Level 4: SMS Maturity Level 4: SMS

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Draft AC 120-XX ContentsDraft AC 120-XX Contents

• Description of LevelsDescription of Levels

• Implementation ProcessImplementation Process

• Gap Analysis ToolGap Analysis Tool

• Functional ObjectivesFunctional Objectives

• Maturity RatingMaturity Rating

• Cross Reference to Detail Design Assessment Tools Cross Reference to Detail Design Assessment Tools

• Cross Reference to ICAO FrameworkCross Reference to ICAO Framework

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SMSSMS Pilot ProjectsPilot Projects

0Orientation &Commitment

2ReactiveProcesses

3ProactiveProcesses

4ContinuousImprovement

1Planning &Organization

Phase 1:

Readiness

Phase 2:

Experience

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SummarySummary

• Phased implementation of SMSPhased implementation of SMS

Four levels plus a “zero” levelFour levels plus a “zero” level

Approximate three-year estimated time to completeApproximate three-year estimated time to complete

• Integration of existing programs encouragedIntegration of existing programs encouraged

• SMS Pilot Projects underway to refine:SMS Pilot Projects underway to refine:

Oversight practices and interfacesOversight practices and interfaces

Implementation strategiesImplementation strategies

• SMS gap analysis and system assessment tools providedSMS gap analysis and system assessment tools provided

• Additional guidance and advisory material being Additional guidance and advisory material being developeddeveloped

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Are we done yet?Are we done yet?

• Aviation systems are open systems that operate in a Aviation systems are open systems that operate in a dynamic rapidly changing environmentdynamic rapidly changing environment

• Safety management is, therefore, Safety management is, therefore, nevernever “done” “done”

• Continuous improvement is based on continuous risk Continuous improvement is based on continuous risk management and assurancemanagement and assurance

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CONTACT INFORMATIONCONTACT INFORMATION

Dr. Donald N. Arendt, Manager Federal Aviation Administration AFS-940 Suite 131 45005 Aviation Drive Dulles, VA 20166-7537 (703) 661-0516 [email protected]

Bill JarrottLead System EngineerThe MITRE Corporation 7515 Colshire DriveMcLean, VA 22102-7539 (703) [email protected]

Keith D. DeBerryFAA, AFS-940 Suite 131 45005 Aviation Drive Dulles, VA 20166-7537 (571) 423-8720 [email protected]

http://www.mitrecaasd.org/SMS/documents.html

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OPEN DISCUSSIONOPEN DISCUSSION