SMS Voluntary Program

1. SMS Voluntary Program Initial Workshop Briefing

2. The SMS Voluntary Program Transition • Applying the same requirements • Applying the same validation process • Calibrate Roles, Responsibilities and Relationships • Promote new tools & guidance

3. SMS Voluntary Program (SMSVP) • The SMS Voluntary Program Guidance is located in the FAA Inspector’s Order 8900.1, Volume 17, Chapter 4, Sections 1, 2, & 3 • WEB URL: www.fsims.faa.gov • References to the SMSVP guidance are shown in GOLD where appropriate on the applicable slides

4. Fundamental “Differences” • Realignment of roles, responsibilities and relationships • Design & Performance assessments vs “Levels” of Implementation • Referencing SMSVP Standard vs SMS Framework, AC 120-92A Appendix 1

5. Roles, Responsibilities & Relationships • The Certificate Holder will develop and implement SMS • The Certificate Management Team, is the primary authority as to the disposition of their Certificate Holder’s SMS • The SMS Program Office, is the Owner of the SMS Voluntary Programand will support technical aspects relating to the SMS Voluntary Program Standard • Regional Point of Contacts may provide assistance

6. Acknowledgment of the SMS Implementation Plan: CH Implementation Plan CMT Validation Project Plan “SMSVP ACTIVE PARTICIPANT” Acknowledgmentof the fully functional SMS. After demonstrating the Plan has worked properly “SMS ACTIVE CONFORMANCE” Two types of SMS recognition The Certificate Holder may use the “Level / Phase” development structure described in the SMS Pilot Project, or any other implementation method, with the concurrence of the CMT

7. Primary Validation Guidance Safety Management Systems (SMS) Voluntary Program – Implementation Plan Validation, SMS Evaluation, and Continued Oversight • Vol 17 Ch 4 Sec 1 – General • General – Overview of the SMSVP process, Roles, Responsibilities & Relationships • Vol 17 Ch 4 Sec 2 – SMSVP Implementation Process • 17-4-2-1– Preparation Phase • 17-4-2-3– CMT Validation Phase • 17-4-2-5– Documentation Validation Phase • 17-4-2-7– Design Demonstration Phase • 17-4-2-9– Administration Process Phase • Vol 17 Ch 4 Sec 3 – Continued Operational Safety • SMS Voluntary Program Standard, Design Validation Job Aids, Design Demonstration Job Aids, Bridging Documents, Definitions

8. Primary Validation Guidance (continued)Safety Management Systems (SMS) Voluntary Program – Implementation Plan Validation, SMS Evaluation, and Continued Oversight • Figure 17-4-3 ASMS Voluntary Program “Standard” • Figures 17-4-3 B – E SMSVP Design Validation Job Aids • Figures 17-4-3 F – R SMSVP Design Demonstration Job Aids • Figure 17-4-3 S Transitioning from SMS Pilot Project to the SMS Voluntary Program • Figure 17-4-3 T Bridging Document, Differences between the SMS Pilot Project and The SMSVP Standard

9. SMSVP Standard – Figure 17-4-3 A • Subpart A - General • Subpart B - Safety Policy • Subpart C - Safety Risk Management • Subpart D - Safety Assurance • Subpart E - Safety Promotion • Subpart F - SMS Documentation and Recordkeeping Refer to Vol 17, Ch 4, Sec 3 Fig 17-4-3A

10. Safety Policy (5.21) Safety Policy must include at least: • Safety objectives of the Certificate Holder • Commitment to the safety objectives • Provisions of resources to implement SMS • Safety reporting policy & requirements • Unacceptable behavior policy • Emergency response planning

11. Responsibility for Safety Line Organizations Business Tier Technical Tier Safety Dept.? Admin Support Tech Support Operating Line

12. Accountable Executive Designation 5.25(a) Irrespective of other functions, satisfies the following: • The final authority over operations authorized to be conducted... • Controls the financial resources… • Controls the human resources... • Retains ultimate responsibility for the safety performance...

13. Accountable Executive Duties 5.25(b) • Ensure SMS is properly implemented and performing in all areas • Develop and sign safety policy • Communicate safety policy throughout the organization • Regularly review safety policy • Regularly review safety performance of the organization and direct actions for substandard safety performance

14. Accountability Framework: Responsibility • “Person who is accountable for the quality of a process” (may not be specifically identified on Certificate Holder’s org chart) • What managers (“process owners”) are responsible for: • § 5.23 (a)(2): • (i) Hazard identification and safety risk assessment. • (ii) Assuring the effectiveness of safety risk controls. • (iii) Promoting safety as required in subpart E of this part. • (iv) Advising the accountable executive on the performance of the SMS and on any need for improvement.

15. Designated Management Personnel 5.25(c) Designation of Management Personnel: • Facilitate hazard identification and risk analysis • Monitor effectiveness of safety risk controls • Ensure safety promotion in accordance with Subpart E • Regularly report to Accountable Executive on SMS Performance & any need for improvement

16. Shared Safety Responsibility Accountable Executive: § 5.25(b)(5) Regularly review the safety performanceof the Certificate Holder's organization and direct actions necessary to address substandard safety performance... All Members of Management: § 5.23(a)(2)(iv), Advising the accountable executive on the performance of the SMS and on any need for improvement Designated Management Personnel: § 5.25(c)(5), Regularly report to the accountable executive on the performance of the SMS and on any need for improvement.

17. Emergency Response Planning -5.27 • The Certificate Holder will develop an Emergency Response Plan that addresses: • Delegation of emergency authority • Assignment of employee responsibilities • Interfacing with Emergency Response Plans of others the Certificate Holder is associated with

18. Subpart E - Competencies and Training Training is required for individuals identified in 5.23 to … perform their duties relevant to the operation and performance of the SMS • ensure those individuals attain • and maintain the competencies necessary

19. Overview of SRM to SA (SMSVP Standard) Design Performance 5.53(a)&(b) 5.71(a)(1) &(2) System Description (Analysis) SRM SA 5.51 5.51 Applicability System Monitoring 5.71 Safety performance monitoring & measurement Hazard Identification 5.71(a)(3-7) 5.53(c) 5.53 System analysis & hazard identification Data Acquisition Risk Analysis 5.55(a) 5.71(b) Analysis Of Data Risk Assessment 5.73 Safety performance assessment System Assessment 5.55 Safety risk assessment and control 5.55(b) 5.73(a) 5.73(b) 5.75 Continuous improvement Risk Control Corrective Action 5.55(c) 5.75 5.55(d)

20. Safety Risk Management 5.51 Applicability A Certificate Holder must apply safety risk management to the following: (a) Implementation of new systems. (b) Revision of existing systems. (c) Development of operational procedures. (d) Identification of hazards or ineffective controls.

21. Safety Risk Management • 5.53 System analysis and hazard identification • When applying safety risk management, the Certificate Holder must analyzethe systemsidentified in § 5.51. Those system analyses must be usedto identify hazards under paragraph (c) of this section, and in developing and implementing riskcontrols related to the system under § 5.55(c).

22. Safety Risk Management 5.53 System analysis and hazard identification (b) In conducting the system analysis, the following information must be considered: • Function and purpose of the system. • The system's operating environment. • An outline of the system's processes and procedures. • The personnel, equipment, and facilities necessary for operation of the system.

23. Safety Risk Management 5.53 System analysis and hazard identification (c) The Certificate Holder must develop and maintain processes to identify hazards within the context of the system analysis.

24. Safety Risk Management 5.55 Safety risk assessment and control • The Certificate Holder must develop and maintain processes to analyze safety risk associated with hazardsidentified in 5.53(c). (b) The Certificate Holder must define a process for conducting risk assessment that allows for the determination of acceptable safety risk.

25. Safety Risk Management 5.55 Safety risk assessment and control (c) The Certificate Holder must develop and maintain processes to develop safety risk controls that are necessary as a result of the safety risk assessment process under paragraph (b) of this section.

26. Safety Risk Management 5.55 Safety risk assessment and control (d) The Certificate Holder must evaluate whether the riskwill be acceptable with the proposed safety risk control applied, before the safety risk control is implemented.

27. Safety Assurance 5.71 Safety Performance Monitoring and Measurement: • The Certificate Holder must develop and maintain processes and systems to acquire data with respect to its operations, products, and services to monitor the safety performance of the organization. The minimum data acquisition processes must include: Monitoring, Auditing, Evaluating, Investigating, and Employee Reporting.

28. Safety Assurance 5.71 Safety performance monitoring and measurement. Minimum data acquisition must include: • Monitoring of operational processes. • Monitoring of the operational environment to detect changes. • Auditing of operational processes and systems. • Evaluating the SMS and operational processes and systems. (a)

29. Safety Assurance 5.71 (a) Safety performance monitoring and measurement. Minimum data acquisition must also include: • Investigations of incidents and accidents. • Investigations of reports regarding potential non-compliance with regulatory standards or other safety risk controls established by the Certificate Holder through theSRM process established in Subpart C of this part. • A confidential employee reporting system in which employees can report hazards, issues, concerns, occurrences, incidents, as well as propose solutions and safety improvements.

30. Safety Assurance 5.71 Safety performance monitoring and measurement (b) The Certificate Holder must develop and maintain processes that analyze the data acquired through processes … in Paragraph (a) … and any other relevant data with respect to its operations, products, and services.

31. Safety Assurance 5.73 Safety Performance Assessment: The Certificate Holder must conductassessmentsof its safety performance againstitssafety objectives, which include reviews by the Accountable Executive, to: (a) • Ensure compliance with the safety risk controls • Evaluate the performance of the SMS • Evaluate the effectiveness of the safety risk controls • Identify changes in the operational environment • Identify new & potential hazards, safety issues & concerns

32. Safety Assurance 5.73 Safety performance assessment (b) Upon completion of the assessment, if ineffective controls or new or potential hazards are identified under paragraph (a)(2) through (a)(4) of this section, the Certificate Holder must use the safety risk management process... • Evaluate the performance of the SMS. • Evaluate the effectiveness of the safety risk controls established under §5.55(c) and identify any ineffective controls. • Identify changes in the operational environment that may introduce hazards. • Identify new hazards. (a)

33. Safety Assurance 5.75 Continuous Improvement The Certificate Holder must establish and implement processes tocorrect safety performance identified in the assessments conducted under § 5.73.

34. SMS Documentation and Recordkeeping 5.95 SMS Documentation The Certificate Holder must develop and maintain SMS documentation that describes the Certificate Holder's: (a) Safety policy (b) SMS processes and procedures

35. SMS Documentation and Recordkeeping 5.97 SMS Records • The Certificate Holder must maintain recordsof outputs of SRM…records must be retained for as long as the control remains relevant to the operation.

36. SMS Documentation and Recordkeeping 5.97 SMS Records • The Certificate Holder must maintain recordsof outputs of SRM…records must be retained for as long as the control remains relevant to the operation. • Maintaining records: • Safety Assurance - 5 years • SRM – As long as the risk control is relevant • Training– As long as employed • Communication – 24 consecutive calendar months

37. Analogous to the “certification” process SMSVP, Vol 17, Ch 4 Sec 2 • 17-4-2-1 – Preparation Phase • 17-4-2-3 – CMT Validation Phase • 17-4-2-5 – Documentation Validation Phase • 17-4-2-7 – Performance Demonstration Phase • 17-4-2-9 – Administrative Process Phase Ref: Vol 17, Ch 4, Sec 2

38. Implementation Planning Preparation Phase The Certificate Holder should: • Examine its organizational structure and manuals to identify “Process Owners” within the organization. • Process Owners are members of management responsible for developing, implementing, and maintaining SMS processes within their respective areas of responsibility. (Reference, 5.23(a)(2)) Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-1 E1

39. Active Applicant Considerations The Certificate Holder andCMT should: • Agree on communication strategy • Agree on management of non-compliance discovery • An understanding of Certificate Holders; SMS application, use of terms & implementation methods Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-1B

40. Preparation Phase An Implementation Plan is… A Service Provider’s Road Map to conform with “The SMSVP Standard”: • A listing of the SMSVP standard requirements and associated reference sources; • A brief narrative describing where processes conform with the SMSVP Standard, or what actions the organization will take to comply with the specific expectation; • Identification of specific employees that will be responsible for implementing required actions; • Estimated target dates that each expectation will be ready for design validation and design demonstration. * Note: The completion date should include the date when the CMT can expect to conduct validation on that element of the system. Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-1 E3

41. CMT Validation Phase SMS SMS = “…an organization-wide approach to managing safety” Implementation Plan Review Scope & Depth = Incorporating all “safety related” processes in the organization Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-1 E4

42. Implementation Plan Review Content Considerations: • When certain areas will be available for assessment • Evaluate processes for building the SMS; similarities, simplicity or complexity • Adequacy of identified guidance to show conformance Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-1 E3

43. Implementation Plan Review Content Considerations: • Documentation and records management • How training will be implemented • Identifying key individuals (by title) in the safety management process • Ultimately – does the plan look workable & achievable?

44. Unacceptable Submission • Return it to the certificate holder with explanation of deficiencies • May be necessary to meet with certificate holder • Any Plan suitability issues may be referred to the Regional Point-of-Contact for input • SMS Program Office is available for technical assistance Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-3 D

45. CMT Validation Project Plan • Is based off of information from the Implementation Plan • The scope and depth of the validation activities is at the discretion of the CMT • Validate both the Design and Performance of SMS activity in the organization • Designate a member to manage the Validation Project Plan Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-3 E

46. Validation Considerations • No one-to-one relationship to the Implementation Plan • What can be accomplished remotely – and what cannot • Allow for assessment, correction and reassessment Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-3 F

47. Validation Planning Meeting • CMT presents their SMS Validation Project Plan • Discuss how changes in the Implementation Plan might impact Validation activity • Inform the certificate holder of the Design Validation & Design Demonstration Job Aids and their use • Acknowledgement of the Implementation Plan and describe forthcoming formal announcement Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-3 G

48. Implementation Plan Acknowledgment • SMS Program Office Review: • Performs Quality Check • Issue an Acknowledgement Letter to the certificate holder • Send copy to CMT Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-3 H

49. Recording Preparation Phase Accomplishments Minimum SMSVP activities recorded in Program Tracking Reporting Subsystem (PTRS): • Implementation plan review • Validation plan completion • CMT recommendation of acknowledgment to the SMSPO • Activity Code 1045/3045/5045, as appropriate • “SMSPREP” in the National Use Box • Use comments section to describe specifics Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-3 I

50. Documentation Validation • Design Job Aids are used to evaluate documentation • Certificate Holder perform internal assessments of their design prior to CMT validation Review Figures 17-4-3 B-E • Ref: Vol 17, Ch 4, Sec 2 para 17-4-2-5