CAR PART X SAFETY MANAGEMENT SYSTEM (SMS) - ISSUE 05-Corrected
CAR PART X SAFETY MANAGEMENT SYSTEM (SMS) - ISSUE 05-Corrected
CAR PART X SAFETY MANAGEMENT SYSTEM (SMS) - ISSUE 05-Corrected
1. This is issue 05 of CAR PART X. No NPA has been deemed necessary since the change will have
This regulation establishes the Safety Management System (SMS) requirements for organisations
approved / certified in accordance with:
- CAR Part IV Special Purpose Operations (Section A) until such a time, organisations approved
under Section A, have implemented CAR –ORA,
- CAR Part V Chapter 3 CAR 145 for UAE based CAR 145 organisations holding Class A or B ratings,
- CAR Part V Chapter 5 CAR 21 (Subparts G, F or J) for UAE based organisations involved in the
design and production of complete aircraft,
Where the organisation holds more than one organisation certificate, the Safety Management System
shall be combined and integrated. This includes AOC holders who are at the same time holding flight
training organisation approval in accordance with CAR-ORA.
The SMS shall correspond to the size of the organisation and the nature and complexity of its activities,
taking into account the hazards and associated risks inherent in these activities.
Where the term “periodic” or “periodically” is used, the organisation shall define the timeframe within its
manuals.
GM1 to 1
AOC Holders should include in their safety management system, the activities conducted under their other
approval(s) such as CAR M and CAR 145 Approvals.
This section specifies the framework for the implementation and maintenance of a SMS which shall be
met by the applicable organisations and accepted by the GCAA. The framework comprises four
components and twelve elements as the minimum requirements for SMS implementation.
GM1 to 2
As the establishment of the Safety Management System requires time, new organisations and
organisations that are transitioning from traditional safety programme to an integrated SMS should follow
a phased approach. APPENDIX 6 provides an example of how a phased approach towards SMS
implementation may be established for organisations not having SMS. While sequencing the
establishment of the different elements is left to the organisation, the GCAA expects elements mentioned
under Phase 1 to be provided at the time of application.
Upon completion of the phases, the GCAA will check the SMS for effectiveness.
GM2 to 2
As part of its surveillance system, the GCAA will evaluate the effectiveness of the SMS by the conduct of
regular SMS evaluation using GTF-SMS-002ab. This form includes the approach, methodology to be
followed by the organisation as well as the GCAA for the purpose of completing the evaluation.
Safety policy outlines the principles, processes and methods of the organisation’s SMS to achieve the
desired safety outcomes. The policy establishes senior management’s commitment to incorporate and
continually improve safety in all aspects of its activities. Senior management develops measureable and
attainable organisation wide safety objectives to be achieved.
(b) include a clear statement about the provision of the necessary resources for the
implementation of the safety policy and achievement of the safety objectives;
(c) establish a non-punitive approach which supports safety reporting and encourages an open
reporting culture for the purpose of safety improvement, not to apportion blame;
(g) be periodically reviewed to ensure it remains relevant and appropriate to the organisation.
GM to 2.1.1(b)
Safety objectives identify what the organisation intends to achieve in terms of safety management. The
safety objectives are expressed as a top-level statement describing the organisation’s commitment to
achieving safety. The safety objectives are linked with the Safety Performance Indicators, targets and
mitigation plans (For more guidance see also APPENDIX 7 – Safety Performance Indicators).
GM to 2.1.1(c)
(a) identify the Accountable Manager who has full control of the resources, final authority over
operations under the certificate approval of the organisation and ultimate responsibility and
accountability for the establishment, implementation and maintenance of the SMS; safety
policies and the resolution of all safety issues.
(b) clearly define lines of safety accountability throughout the organisation, including a direct
accountability for safety on the part of senior management;
(c) identify 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;
(d) document and communicate safety responsibilities, accountabilities and authorities throughout
the organisation; and
(e) define the levels of management with authority to make decisions regarding safety risk
tolerability.
The Accountable Manager’s authorities and accountabilities should include, but are not limited to:
AMC2 to 2.1.2(a)
Depending on the size, structure and complexity of the organisation, the Accountable Manager should be:
(a) the chief executive officer (CEO) of the Organisation; or equivalent;
(b) the chairperson of the board of directors;
(c) A person holding an appropriate delegation by a legally authorised person to act as an
Accountable Manager
(d) a partner; or
(e) the proprietor.
The organisation shall appoint a properly educated, trained and experienced person who fulfils the
role of Post Holder SMS for the development and maintenance of an effective Safety Management
System.
The appointed person shall have direct access to the Accountable Manager to ensure that the
Accountable Manager is kept properly informed on safety matters.
The Post Holder SMS is a senior management position and shall not hold other positions that may
conflict or impair his role as Post Holder SMS unless specifically approved by the GCAA.
AMC to 2.1.3.1
The Post Holder SMS functions should include but are not limited to:
Depending on size, complexity and nature the organisation may need to establish a Safety Review Board
(SRB) which is a high level committee that considers matters of strategic safety importance in support of
the Accountable Manager’s safety accountability.
The SRB provides the platform to achieve the objectives of resource allocation and to assess the
effectiveness and efficiency of risk mitigation strategies. The SRB is chaired by the Accountable Manager
and composed of senior managers, including line managers responsible for functional areas as well as
those from relevant administrative departments. The Post Holder SMS participates in the SRB in an
advisory capacity. The SRB meets periodically.
The SRB:
(a) monitors the effectiveness of the SMS;
(b) monitors that any necessary corrective action is taken in a timely manner;
(c) monitors safety performance against the organisation‘s safety policy and objectives;
(d) monitors the effectiveness of the organisation‘s safety management processes which support
the declared corporate priority of safety management as another core business process;
(e) monitors the effectiveness of the safety supervision of subcontracted operations;
(f) ensures that appropriate resources are allocated to achieve safety performance beyond that
required by regulatory compliance.
GM1 to 2.1.3.1
Below are examples of which may be considered to meet the proper education, training and experience
requirement:
GM2 to 2.1.3.1
Organisations may establish a Safety Action Group to achieve the established performance, which reports
to and takes strategic direction from the SRB.
(a) A Safety Action Group may be established as a standing group or as an ad hoc group to assist
the Post Holder SMS or Safety Review Board.
(b) More than one Safety Action Group may be established depending on the scope of the task and
specific expertise required.
(c) The Safety Action Group should report to, and take strategic direction from the Safety Review
Board.
(d) The Safety Action Group may, assist the Post Holder SMS in:
1) oversee operational safety performance within the functional areas of the organisation
and ensures that appropriate safety risk management activities are carried out with staff
involvement as necessary to build up safety awareness;
(e) The Safety Action Group may also be tasked with the review the effectiveness of previous safety
actions and safety promotion.
(f) The Post Holder SMS may also be included in the SAG.
The organisation shall ensure that the Emergency Response Plan (ERP) is properly coordinated with the
Emergency Response Plans of those organisations it must interface with during the provision of its
services.
AMC to 2.1.4
The ERP should be documented in the format of a manual or directly integrated into the SMS Manual and
reflect the size, nature and complexity of the activities performed by the organisation. If the Emergency
Response Plan is documented in a separate document, it should be cross-linked to SMS manual.
(a) ensure an orderly, safe and efficient transition from normal to emergency operations, and back
to normal;
(b) ensure delegation of emergency authority;
(c) ensure authorisation by key personnel for actions contained in the plan;
(d) ensure coordination of efforts to cope with the emergency;
(e) ensure that the responsibilities, roles and actions of various agencies and personnel involved in
dealing with emergencies are defined and personnel trained;
(f) periodically be tested for the adequacy of the plan and the results reviewed to improve its
effectiveness.
1) governing policies;
2) organisation;
3) notifications;
4) initial response;
5) additional assistance;
6) Crisis Management Centre (CMC);
7) records;
8) accident site;
9) news media;
10) formal investigations;
11) family assistance;
12) post-critical incident stress counselling; and
13) post-occurrence review.
GM to 2.1.4
The Emergency Response Plan addresses possible or likely emergency/crisis scenarios relating to the
organization’s aviation product or service deliveries.
GM to AMC 2.1.4
(a) The organisation shall develop an SMS Manual endorsed by the Accountable Manager and
acceptable to the GCAA to demonstrate how the organisation will comply with this PART.
(b) The organisation shall establish a system of record keeping that allows adequate storage and
reliable traceability of all records related to Safety Management System processes.
AMC to 2.1.5(a)
An SMS manual defines the organisation’s approach to the management of safety in a manner that meets
the organisation’s safety policy and the requirements of this PART. The organisation should develop and
maintain SMS documentation that describes how the organisation is going to comply with this regulation;
and describes its:
GM to AMC 2.1.5(a)
AMC to 2.1.5(b)
(a) The format of the records should be specified in the organisation’s procedures.
(b) Records should be stored in a manner that ensures protection from damage, alteration, and
theft.
(c) The record keeping system should ensure that all records are accessible whenever needed and
records should be organised in a way that ensures traceability throughout the required
retention period.
(d) Paper systems should use robust material which can withstand normal handling and filing.
Computer systems should have at least one backup system which should be updated within 24
hours of any new entry. Computer systems should include safeguards against the ability of
unauthorised personnel to alter the data.
(e) All computer hardware used to ensure data backup should be stored in a different location from
that containing the working data, and in an environment that ensures they remain in good
condition. When hardware or software changes take place, special care should be taken that all
necessary data continues to be accessible at least through the full period specified in the
relevant provision. In the absence of such indication, all records should be kept for a minimum
period of 5 years.
(f) The records should remain legible throughout the required retention period. The retention
period starts when the record has been created or last amended.
(g) Records related to Safety Management System processes should include but are not limited to:
1) The results of the assessment of the potential adverse consequences or outcome of each
hazard (APPENDIX 10);
2) Safety Performance Indicators, targets and related charts;
3) record of completed or in-progress safety assessments;
4) SMS internal review or audit records;
5) safety promotion records;
6) personnel SMS/safety training records;
7) SMS/safety committee meeting minutes; and
Safety risk management shall include hazard identification, safety risk assessment and mitigation
processes.
GM to 2.2
An example of the safety risk management process is illustrated in APPENDIX 3, in addition, other risk
management methods e.g. BowTie can be useful particularly in the implementation of the mitigations and
controls. APPENDIX 11 shows an Example of BowTie model.
The organisation shall develop, implement and maintain a process that ensures that hazards associated
with its aviation products or services are identified.
In order to ensure continuity of data flow through internal safety reporting systems, the organisation shall
ensure that it effectively implements 2.1.1 (c).
In addition to the proactive and reactive methods of safety data collection the organisation should employ
where practical predictive methodologies which could arrest risks from potential hazards.
AMC1 to 2.2.1
Data sources of hazard identification should be both internal and external to the organisation:
Organisations should establish internal confidential reporting channels to maximise data capturing.
AMC2 to 2.2.1
The internal safety reporting system should contain the following elements:
(a) the collection and evaluation of those errors, near-misses, and hazards reported internally;
(b) corrective and preventive actions are taken internally to address any safety issues and hazards;
1) identify and address the factors contributing to occurrences in order to reduce the
likelihood of reoccurrence;
2) identify adverse trends;
3) identify those reports which require further investigation; and
4) establish all root causes, including any technical, organisational, managerial, or human
factors issues, and any other contributing factors relating to the event (APPENDIX 10).
GM to AMC1 to 2.2.1
(a) In addition to the internal reporting systems, flight data analysis and internal audits, Internal
hazard identification data sources may include:
GM to 2.2.1
The following may be considered while engaged in the hazard identification process:
The organisation shall develop, implement and maintain a process that ensures analysis, assessment, and
acceptable control of the safety risks associated with identified hazards.
AMC to 2.2.2
Written procedures for developing and implementing Corrective Actions should be established. These
should:
(a) Result in a specific corrective action plan that addresses the following:
2) Analysis and final approval level of the corrective action, including who is responsible for
approval of the corrective action.
7) Who will monitor the status of the corrective action and how.
8) Reporting the status of the corrective action (to whom, with what frequency).
GM to 2.2.2
The process starts with the identification of hazards and their potential consequences. The safety risks are
then assessed in terms of probability and severity, to define the level of safety risk (safety risk index). An
example of a safety risk matrix is illustrated in APPENDIX 4.The completed hazard identification and safety
risk assessment and mitigation process is then documented and approved as appropriate.
Risk acceptance criteria is established based on the organisation’s safety policy and objectives.
Once risks have been assessed, the organisation should engage in a decision-making process to determine
the need to implement risk mitigation measures. Each safety risk mitigation measure should be examined
from the following perspectives:
(a) Effectiveness: The extent to which the measure reduces or eliminates the safety risk.
Effectiveness can be determined in terms of the technical, training and procedural defences
that can reduce or eliminate safety risks.
(b) Cost/benefit: The extent to which the perceived benefits of the mitigation outweigh the costs.
(c) Practicality: The extent to which the mitigation is implementable and appropriate in terms of
available technology, financial and administrative resources etc…
(d) Acceptability: The extent to which the stakeholders willingly adopt and embrace them.
(e) Enforceability: The extent to which compliance with new operating procedures can be
monitored.
(f) Durability: The extent to which the measure will be sustainable and effective.
(g) Residual safety risks: The degree of safety risk that remains subsequent to the implementation
of the initial mitigation, and which may necessitate additional risk control measures.
(h) Unintended consequences: The introduction of new hazards and related safety risks associated
with the implementation of any mitigation alternative.
(a) Avoidance. The activity is suspended, either because the associated safety risks are intolerable
or deemed unacceptable vis-à-vis the associated benefits.
(b) Reduction. Some safety risk exposure is accepted, although the severity or probability
associated with the risks are lessened, possibly by measures that mitigate the related
consequences.
(c) Segregation of exposure. Action is taken to isolate the potential consequences related to the
hazard or to establish multiple layers of defences to protect against them.
A risk mitigation strategy may involve one of the approaches described above, or may include multiple
approaches. It is important to consider the full range of possible control measures to find an optimal
solution. The effectiveness of each alternative strategy should be evaluated before a decision can be
taken.
Once the mitigation has been approved and implemented, any associated impact on safety performance
provides feedback to the Organisation‘s safety assurance process. This is necessary to ensure integrity,
efficiency and effectiveness of the defences under the new operational conditions.
The effective implementation of all above mentioned processes, including evidences of its day by day
proper implementation, should be available and used on the internal organisation quality assurance
process, with the aim to accomplish its utmost objectives.
Quality assurance process should be developed in a documented continuous monitoring audit approach.
It should ensure, that investigations are effectively performed to find occurrences’ root causes and issue
targeted and feasible recommendations to implement corrective actions by the accountable managerial
staff on due time.
The organisation shall develop, document and maintain safety assurance processes to ensure that the
safety risks controls established as a consequence of the hazard identification and risk management
activities achieve their intended objectives.
GM to 2.3
Safety assurance consists of processes and activities undertaken by the organisation to determine
whether the SMS is operating according to expectations and requirements. The organisation should
The safety assurance process complements the quality assurance process, with each having requirements
for analysis, documentation, and management reviews to ensure that certain performance criteria are
met. While quality assurance typically focuses on the organisation‘s compliance with regulatory
requirements, safety assurance specifically monitors the effectiveness of safety risk controls.
The organisation shall establish safety performance monitoring and measurement processes by the
establishment of Safety Performance Indicators (SPI) and Safety Performance Targets (SPT) to verify its
safety performance and validate the effectiveness of the safety risk controls.
The indicators, targets, alert levels and relevant action plans defined to achieve the targets shall be agreed
with the GCAA.
The actual performance shall be regularly provided to the GCAA in a form and manner established by the
GCAA for monitoring purposes along with statistical data required for the GCAA to establish and monitor
the State Acceptable Level of Safety Performance (ALoSP).
For organisations that do not have sufficient data for the establishment of SPI’s and SPT’s, the organisation
shall establish safety initiatives aiming at continuous improvement in relation to safety standards. These
initiatives shall be in line with the safety objectives of the organisation.
If an alert level or a target has been breached, the organisation shall immediately report it the GCAA and
submit a corrective plan accordingly.
AMC1 to 2.3.1
Safety Performance Monitoring processes and systems should include processes and systems for the
following:
(a) Continuous monitoring of operational processes including establishment and monitoring of SPIs and
SPTs, SPTs, alert levels and the required reporting of safety performance or other statistics data to the
GCAA;
(f) Evaluation of contextual data related the organisation environment, conditions, resources and
management.
Note 1: Upon completion of the assessments, evaluations and reviews, if ineffective controls, new hazards,
or potential hazards are identified, the Organisation should use the safety risk management process.
AMC2 to 2.3.1
The continuous acceptance of an SMS requires that the GCAA is satisfied that the proposed SPIs are
appropriate and pertinent to the organisation’s aviation activities prior to be agreement. The agreement
should be between the GCAA Principal Inspector and the organisation. The GCAA Principal Inspector will
review the proposed SPIs, SPTs, and alert levels to ensure that:
- they are appropriate, and relevant to the scope and complexity of the specific operational context; and
- their development has used the appropriate measuring matrix and is dependent on the size and
complexity of the organisation.
AMC3 to 2.3.1
The baseline objectives for organisations with insufficient data should target matters of concern for the
organisation such as enhancing the safety culture, just culture, reporting and/or improving the level of
safety. These initiatives have broad spectrum and may range from Intern low consequence events having
a direct bearing on the way activities and processes are implemented; to major possible safety risks,
adoption of best industry practices and maintaining zero occurrence levels for particular events even if
the organisation did not encounter such events. In this sense, these initiatives act as proactive defences
without the presence of actual SPIs. Such defences should be checked for effectiveness as part of the
safety assurance processes.
For the GCAA to periodically monitor the SPTs and also the State ALoSP, organisations should submit flight
hours, engine hours, cycles, number of movements and other required information to the GCAA.
Form GCAA GTF-SMS-005 should be used and provided by mid-month of following the month for
organisations operating aircraft (i.e. regulated by CAR-OPS 1 and 3 and CAR-ORA).
AMC5 to 2.3.1
The agreed safety performance of an organisation’s SMS should be periodically reviewed to ensure it
remains relevant and appropriate to the organisation. To facilitate this monitoring, the organisation
should provide the GCAA with the actual safety performance for every quarter of year (n) as per the
following schedule:
The Quarterly SPM Reports for every quarter of year (n) should be made using form GTF-SMS-006.
Immediately after submission of a Quarterly SPM Report as per above schedule, the organisation should
coordinate with its GCAA Principal Inspector for a review and agree on the need for adjustments to ensure
SPIs, SPTs and alert levels remain relevant and appropriate to the organisation. Adjustments should be
substantiated by appropriate safety data and duly documented.
GM1 to 2.3.1
The organisation shall develop, document, implement and maintain a process to identify changes which
may affect the level of safety risk associated with its aviation products or services and to identify and
manage the safety risks or hazards that may arise from those changes.
AMC to 2.3.2
(a) it has established a process, and conducts formal hazard analyses/risk assessment for major
operational changes, major organisational changes, and changes in key personnel
(b) safety assessment/risk assessments are aviation safety focused;
(c) key stakeholders are involved in the change management process, as appropriate;
GM1 to 2.3.2
1) organisational restructuring;
2) acquisition of equipment;
(f) The change also has the potential to introduce new, or exacerbate pre-existing, human factors
issues. For example, changes in machinery, equipment, technology, procedures, work
organisation, or work processes are likely to affect performance.
(g) The purpose of integrating human factors into the management of change is to minimise
potential risks by specifically considering the impact of the change on the people within a
system.
(h) Special consideration, including any human factors issues, should be given to the ‘transitional
period’. In addition, the activities utilised to manage these issues should be integrated into the
change management plan.
GM2 to 2.3.2
The organisation’s management of change process should take into account the following three
considerations:
(a) Criticality: Criticality assessments determine the systems, equipment or activities that are
essential to the safe operation of aircraft. While criticality is normally assessed during the
system design process, it is also relevant during a situation of change. Systems, equipment and
activities that have higher safety criticality should be reviewed following change to make sure
that corrective actions can be taken to control potentially emerging safety risks.
(b) Stability of systems and operational environments: Changes may be planned and under the
direct control of the organisation. Such changes include organisational growth or contraction,
the expansion of products or services delivered, or the introduction of new technologies.
The organisation shall monitor and assess the effectiveness of its SMS processes to enable continuous
improvement of the SMS.
AMC to 2.3.3
Monitoring and assessment activities conducted for the purpose of this requirement should be conducted
by persons that are functionally independent of the technical processes being evaluated.
GM to 2.3.3
(a) The organisation shall develop and maintain a safety training programme that ensures that
personnel are trained and competent to perform their duties relevant to the organisation’s
SMS.
AMC to 2.4.1
The following are elements that should be established and maintained as part of the Safety training
programme:
(a) Safety training and education curricula should consist of the following:
(b) Training requirements should be consistent with the needs and complexity of the organisation.
(c) Training procedures should specify initial and, if required, recurrent safety training standards
for operational personnel, managers and supervisors, senior managers and the Accountable
Manager. The SMS training documentation should also specify responsibilities for development
of training content and scheduling.
(d) Safety training for senior managers should include content related to compliance with national
and organisational safety requirements, allocation of resources and active promotion of the
SMS including effective interdepartmental safety communication. In addition, safety training
for senior managers should include material on establishing Safety Performance Targets and
alert levels.
(e) The Accountable Manager training should be at a high level providing an understanding of the
SMS and its relationship to the organisation’s overall business strategy.
The organisation shall develop, document, implement and maintain formal means for safety
communication that:
(a) ensures personnel are aware of the SMS to a degree commensurate with their positions in a
timely manner;
(b) conveys safety-critical information in a timely manner;
(c) explains why particular safety actions are taken; and
(d) explains why safety procedures are introduced or changed.
GM1 to 2.4.2
Safety communication is an essential foundation for the development and maintenance of an adequate
safety culture. The modes of communication may include:
(a) newsletters;
(b) presentations;
(c) safety notices;
(d) safety awareness posters;
(e) lectures;
(f) workshops; and
(g) workplace safety oriented meetings between staff and the Accountable Manager or Senior
Managers.
1) Acceptable Level of Safety Performance (ALoSP): The minimum level of safety performance of
civil aviation in a State, as defined in its State safety programme, or of a organisation, as defined
in its Safety Management System, expressed in terms of Safety Performance Targets and Safety
Performance Indicators.
2) Alert Level: An established level or criteria value outside of the normal operating range or out-
of-control region that triggers a warning that an adjustment or evaluation is needed.
3) Consequence: Actual or potential impact of a hazard that can be expressed qualitatively and/or
quantitatively. More than one consequence may evolve from an event.
4) Corrective Action: Action to eliminate the cause of or reduce the effects of a detected hazard
or potentially hazardous situation in order to prevent its recurrence.
5) Defences: Specific mitigating actions, preventive controls or recovery measures put in place to
prevent the realization of a hazard or its escalation into an undesirable consequence.
6) Error: An action or inaction by an operational person that leads to deviations from
organisational or the operational person‘s intentions or expectations.
7) Hazard: A condition that could cause or contribute to an aircraft incident or accident.
8) Hazard Analysis: Analysis performed to identify hazards, hazard effects, and hazard causal
factors used to determine system risk.
9) Hazard Identification: A process to establish a list of hazards relevant to the activity and the
causes/threats that could release them.
10) High-consequence Indicators: Safety Performance Indicators pertaining to the monitoring and
measurement of high-consequence occurrences, such as accidents or serious incidents. High-
consequence indicators are sometimes referred to as reactive indicators.
11) Human Factors: Principles which apply to aeronautical design, certification, training, operations
and maintenance and which seek safe interface between the human and other system
components by proper consideration to human performance.
12) Investigation: A process conducted for the purpose of accident prevention which includes the
gathering and analysis of information, the drawing of conclusions, including the determination
of causes and, when appropriate, the making of safety recommendations.
13) Lower-consequence Indicator: Safety Performance Indicators pertaining to the monitoring and
measurement of lower-consequence occurrences, events or activities such as incidents, non-
conformance findings or deviations. Lower-consequence indicators are sometimes referred to
as proactive/predictive indicators.
14) Open Reporting Culture: An organisational perspective that actively encourages effective safety
reporting by defining acceptable behaviour (often unintended errors) and unacceptable
behaviour (such as recklessness, violations or sabotage), and provides fair protection to
reporters.
“Safety Culture is the set of enduring values and attitudes regarding safety issues, shared by every
member of every level of an organization. Safety Culture refers to the extent to which every individual
and every group of the organization is aware of the risks and unknown hazards induced by its
activities; is continuously behaving so as to preserve and enhance safety; is willing and able to adapt
itself when facing safety issues; is willing to communicate safety issues; and consistently evaluates
safety related behaviour.”
To support the assessment and management of Safety Culture, the six main components (called
Characteristics) of Safety Culture are described:
1. Commitment
2. Behaviour
3. Awareness
4. Adaptability
5. Information
6. Justness
Just Culture is clearly an element of [a Safety Culture framework] (in the Justness characteristic or
component).
Just culture is defined as: “‘a culture in which front line operators or others are not punished for actions,
omissions or decisions taken by them that are commensurate with their experience and training, but
where gross negligence, wilful violations and destructive acts are not tolerated.”
An important part of a good just culture depends on how an organization oversees safety reports which
may contain information about potentially unsafe/risky actions, either directly or indirectly taken by its
employees. These may be the result of slips, common mistakes, technical failures or can even be related
to systematic training issues. When reviewing such occurrences, consideration should be given as to
whether the person’s actions were reasonable. It could be that the actions taken were the same as what
another competent person may have reasonably taken in a similar situation. Part of this is ensuring that
the right level of expertise is available to help understand the context and situation surrounding what
occurred. Employees at all levels should be encouraged to report any occurrences or issues that may affect
safety and be open to learning from these.
A safety culture and a just culture should be fostered. However in the rare cases, in which gross
negligence, wilful violations or destructive acts are apparent, such acts/behaviour should not be tolerated.
Through following of clear and proper procedures, anyone involved in cases of possible gross negligence
should receive fair treatment and proportionate remedial action to prevent a reoccurrence.
Risk Severity
Catastrophic Hazardous Major Minor Negligible
Risk Probability A B C D E
Frequent 5 5A 5B 5C 5D 5E
Occasional 4 4A 4B 4C 4D 4E
Remote 3 3A 3B 3C 3D 3E
Improbable 2 2A 2B 2C 2D 2E
Extremely improbable 1 1A 1B 1C 1D 1E
Using this matrix, risks can be categorised according to an assessment of their potential severity and
probability. Based on this matrix example, risks reflected as being unacceptable (red and yellow
categories) must be mitigated so as to reduce their severity and/or probability. The organisation should
consider suspension of any activities that continue to expose the organisation to intolerable safety risks
in the absence of mitigating actions that reduce the risks to an acceptable level (green).
An ERP would normally be documented in the format of a manual that should set out the responsibilities,
roles and actions of the various agencies and personnel involved in dealing with specific emergencies. An
ERP should take account of such considerations as:
(a) Governing policies. The ERP should provide direction for responding to emergencies, such as
governing laws and regulations for investigations, agreements with local authorities, company
policies and priorities.
(b) Organisation. The ERP should outline management’s intentions with respect to the responding
organisations by:
1) designating who will lead and who will be assigned to the response teams;
2) defining the roles and responsibilities of personnel assigned to the response teams;
3) clarifying the reporting lines of authority;
4) setting up an Emergency Management Centre (EMC);
5) establishing procedures for receiving a large number of requests for information, especially
during the first few days after a major accident;
6) designating the corporate spokesperson for dealing with the media;
7) defining what resources will be available, including financial authorities for immediate
activities;
8) designating the company representative to any formal investigations undertaken by State
officials;
9) defining a call-out plan for key personnel.
(c) Notifications. The plan should specify who in the organisation should be notified of an emergency,
who will make external notifications and by what means. The notification needs of the following
should be considered:
1) management;
2) State authorities (search and rescue, the regulatory authority, the accident investigation
board, etc.);
3) local emergency response services (aerodrome authorities, fire fighters, police, ambulance,
medical agencies, etc.);
4) relatives of victims (a sensitive issue that, in many States, is handled by the police);
(d) Initial response. Depending on the circumstances, an initial response team may be dispatched to
the accident or crisis site to augment local resources and oversee the organisation’s interests.
Factors to be considered for such a team include:
(e) Additional assistance. Employees with appropriate training and experience can provide useful
support during the preparation, exercising and updating of an organisation’s ERP. Their expertise
may be useful in planning and executing such tasks as:
(f) Emergency Management Centre (EMC). An EMC (normally on standby mode) may be established at
the organisation’s headquarters once the activation criteria have been met. In addition, a command
post (CP) may be established at or near the crisis site. The ERP should address how the following
requirements are to be met:
1) staffing (perhaps for 24 hours a day, 7 days per week, during the initial response period);
2) communications equipment (telephones, facsimile, Internet, etc.);
3) documentation requirements, maintenance of emergency activity logs;
4) impounding related company records;
5) office furnishings and supplies; and
6) reference documents (such as emergency response checklists and procedures, company
manuals, aerodrome emergency plans and telephone lists).
The services of a crisis centre may be contracted from an airline or other specialist organisation to
look after the Organisation’s interests in a crisis away from home base. Company personnel would
normally supplement such a contracted centre as soon as possible.
(h) Accident site. For a major accident, representatives from many jurisdictions have legitimate reasons
for accessing the site: for example, police; fire fighters; medics; aerodrome authorities; coroners
(medical examining officers) to deal with fatalities; State accident investigators; relief agencies such
as the Red Crescent and even the media. Although coordination of the activities of these
stakeholders is the responsibility of the State’s police and/or investigating authority, the
Organisation should clarify the following aspects of activities at the accident site:
i. at home base;
ii. away from home base;
iii. offshore or in a foreign State;
(i) News media. How the company responds to the media may affect how well the company
recovers from the event. Clear direction is required regarding, for example:
1) what information is protected by statute (FDR data, CVR and ATC recordings, witness
statements, etc.);
2) who may speak on behalf of the parent organisation at head office and at the accident site
(public relations manager, chief executive officer or other senior executive, manager,
owner);
(j) Formal investigations. Guidance for company personnel dealing with State accident
investigators and police should be provided.
(k) Family assistance. The ERP should also include guidance on the organisation’s approach
to assisting crisis victims or customer organisations. This guidance may include such
things as:
(l) Post-occurrence review. Direction should be provided to ensure that, following the
emergency, key personnel carry out a full debrief and record all significant lessons
learned which may result in amendments to the ERP and associated procedures.
This APPENDIX includes typical guidance of a SMS implementation plan for Organisations that are
transitioning from traditional safety programme in to an integrated SMS or for new Organisations.
A system review and description of the SMS framework and interface with existing systems and processes
is the first step in defining the scope and applicability of the SMS. This can be achieved by conducting a
gap analysis, which provides an opportunity to identify any gaps related to the organisation’s SMS
components and elements, including the interfaces within the organisation. The gap analysis facilitates
development of an SMS implementation plan by identifying the gaps that must be addressed to fully
implement an SMS. Once the gap analysis has been completed and fully documented, the resources and
processes that have been identified as missing or inadequate will form the basis of the SMS
implementation plan.
The SMS Implementation Plan consists of four implementation phases with each phase associated with
various elements (or sub-elements) as per the ICAO framework.
Phase 1
(a) The objective of Phase 1 of SMS implementation is to provide a blueprint of how the SMS
requirements can be met and integrated into the organisation’s control systems, as well as an
accountability framework for the implementation of the SMS.
(b) During Phase 1, basic planning and assignment of responsibilities are established. Central to Phase
1 is the gap analysis. From the gap analysis, an organisation can determine the status of its existing
safety management processes and can begin planning for the development of further safety
management processes. The significant output of Phase 1 is the SMS implementation plan.
(APPENDIX 6 to Chapter 3 of ICAO Doc 9859 - -SMS Acceptance/ Assessment (Example) provides
further guidance).
(c) At the completion of Phase 1, the following activities should be finalized in such a manner that
meets the expectations of the GCAA, as set forth in relevant requirements and guidance material:
(a) Identify the Accountable Manager and the safety accountabilities of managers. This activity is based
on Elements 2.1.1 and 2.1.2 of the SMS framework.
(b) Establish an SMS implementation team. The team should be comprised of representatives from the
relevant departments. The team’s role is to drive the SMS implementation from the planning stage
2) ensuring the adequate SMS training and technical expertise of the team in order to
effectively implement the SMS elements and related processes; and
3) monitoring of and reporting on the progress of the SMS implementation, providing regular
updates and coordinating with the Accountable Manager.
(c) Define the scope of the organisation’s activities (departments/divisions) to which the SMS will be
applicable. The scope of the organisation’s SMS applicability will subsequently need to be described
in the SMS document as appropriate. This activity is based on Element 2.1.5 of the SMS framework.
Guidance on the system description is provided in 2.1.5 of this chapter.
(d) Conduct a gap analysis of the organisation’s current systems and processes in relation to the ICAO
SMS framework requirements (or the relevant SMS regulatory requirements).
(a) Identify the key SMS person (safety/quality function) within the organisation who will be
responsible for administering the SMS on behalf of the Accountable Manager.
(b) Organize and set up schedules for appropriate training of all staff according to their individual
responsibilities and involvement in the SMS.
2) recurrent training.
2) websites;
Phase 2
The objective of Phase 2 is to implement essential safety management processes, while at the same
time correcting potential deficiencies in existing safety management processes. Most organisations will
have some basic safety management activities in place at different levels of implementation. This phase
aims at consolidating existing activities and developing those which do not yet exist.
(d) Establish a review schedule for the safety policy to ensure it remains relevant and appropriate to
the organisation.
(e) Establish safety objectives for the SMS by developing safety performance standards in terms of:
3) action plans.
1) establish a procedure to write SMS requirements into the contracting process; and
(a) Define safety accountabilities and communicate them throughout the organisation.
(d) Define clear functions for the SAG and the safety/SMS coordination committee.
(e) Establish lines of communication between the safety services office, the Accountable Manager, the
SAG and the safety/SMS coordination committee.
(f) Appoint the Accountable Manager as the chairperson of the safety/SMS coordination committee.
(g) Develop a schedule of meetings for the safety services office to meet with the safety/SMS
coordination committee and SAG as needed.
(a) Review the outline of the ERP related to the delegation of authority and assignment of emergency
responsibilities.
(b) Establish coordination procedures for action by key personnel during the emergency and the
return to normal operations.
(c) Identify external entities that will interact with the organisation during emergency situations.
(f) Incorporate information about the coordination between the different ERPs in the organisation’s
SMS documentation.
(a) Create an SMS documentation system to describe, store, retrieve and archive all SMS-related
information and records by:
2) establishing an SMS filing system to collect and maintain current records relating to the
organisation’s ongoing SMS processes;
3) maintaining records to provide a historical reference as well as the current status of all SMS
processes such as: a hazard register; an index of completed safety assessments; SMS/safety
training records; current SPIs and associated safety objectives; internal SMS audit reports;
SMS/safety committee meeting minutes and the SMS implementation plan;
4) maintaining records that will serve as evidence of the SMS operation and activities during
internal or external assessment or audit of the SMS.
Phase 3
The objective of Phase 3 is to establish safety risk management processes. Towards the end of Phase 3,
the organisation will be ready to collect safety data and perform safety analyses based on information
obtained through the various reporting systems.
(b) Establish a programme/schedule for systematic review of all applicable aviation safety-related
processes/equipment that are eligible for the HIRM process.
(c) Establish a process for prioritization and assignment of identified hazards for risk mitigation.
(a) Establish a safety risk management procedure, including its approval and periodic review process.
(b) Develop and adopt safety risk matrices relevant to the organisation’s operational or production
processes.
(a) Establish an internal occurrence reporting and investigation procedure. This may include
mandatory or major defect reports (MDR) where applicable.
(b) Establish safety data collection, processing and analysis of high-consequence outcomes.
(c) Establish high consequence safety indicators (initial ALoSP) and their associated target and alert
settings. Examples of high-consequence safety indicators are accident rates, serious incident rates
and monitoring of high risk non-compliance outcomes. Refer to APPENDIX 7 for guidance on
Safety Performance Indicators.
d) Reach an agreement with the GCAA on Safety Performance Indicators and Safety Performance
Targets.
(a) Establish a formal process for the management of change that considers:
3) past performance;
(b) Ensure that management of change procedures address the impact on existing safety
performance and risk mitigation records before implementing new changes.
(c) Establish procedures to ensure that safety assessment of new aviation safety-related operations,
processes and equipment are conducted (or accounted for) as applicable, before they are
commissioned.
(d) Define a schedule for evaluation of facilities, equipment, documentation and procedures to be
completed through audits and surveys.
Phase 4
Phase 4 is the final phase of SMS implementation. This phase involves the mature implementation of
safety risk management and safety assurance. In this phase operational safety assurance is assessed
through the implementation of periodic monitoring, feedback and continuous corrective action to
maintain the effectiveness of safety risk controls.
(a) Enhance the existing disciplinary procedure/policy with due consideration of unintentional errors/
mistakes from deliberate/gross violations.
(a) Integrate the hazards identified from occurrence investigation reports with the voluntary
reporting system.
(b) Integrate hazard identification and risk management procedures with the subcontractor or
customer SMS where applicable.
(c) If necessary, develop a process for prioritizing collected hazards for risk mitigation based on areas
of greater need or concern. Refer to APPENDIX 3 and 4 for guidance.
(a) Enhance the safety data collection and processing system to include lower-consequence events.
(c) Reach an agreement with the GCAA on lower-consequence Safety Performance Indicators and
Safety Performance Target/alert levels.
(a) Establish SMS audits or integrate them into existing internal and external audit programmes.
(a) Establish mechanisms to promote safety information sharing and exchange internally and
externally.
a) Air operators
1. Document control
Describe how the manual(s) will be kept up to date and how the organisation will ensure that all
personnel involved in safety-related duties have the most current version.
Cross-reference documents
Address current SMS regulations and guidance material for necessary reference and awareness by all
concerned.
(a) Spell out the current SMS regulations/standards. Include the compliance timeframe and advisory
material references as applicable.
(b) Where appropriate, elaborate on or explain the significance and implications of the regulations to
the organisation.
(c) Establish a correlation with other safety-related requirements or standards where appropriate.
Cross-reference documents
Describe the scope and extent of the organisation’s aviation-related operations and facilities within
which the SMS will apply. The scope of the processes, equipment and operations deemed eligible for the
organisation’s hazard identification and risk management (HIRM) programme should also be addressed.
Cross-reference documents
4. Safety policy
Describe the organisation’s intentions, management principles and commitment to improving aviation
safety in terms of the product or Organisation. A safety policy should be a short description similar to a
mission statement.
(a) The safety policy should be appropriate to the size and complexity of the organisation.
(b) The safety policy states the organisation’s intentions, management principles and commitment
to continuous improvement in aviation safety.
(c) The safety policy is approved and signed by the Accountable Manager.
(d) The safety policy is promoted by the Accountable Manager and all other managers.
(e) The safety policy is reviewed periodically.
(f) Personnel at all levels are involved in the establishment and maintenance of the Safety
Management System.
(g) The safety policy is communicated to all employees with the intent that they are made aware of
their individual safety obligations.
Cross-reference documents
5. Safety objectives
Describe the safety objectives of the organisation. The safety objectives should be a short statement
that describes in broad terms what the organisation hopes to achieve.
Criteria
Cross-reference documents
Describe the safety authorities, responsibilities and accountabilities for personnel involved in the SMS.
(a) The Accountable Manager is responsible for ensuring that the Safety Management System is
properly implemented and is performing to requirements in all areas of the organisation.
(b) An appropriate safety manager (office), safety committee or Safety Action Groups have been
appointed as appropriate.
(c) Safety authorities, responsibilities and accountabilities of personnel at all levels of the
organisation are defined and documented.
(d) All personnel understand their authorities, responsibilities and accountabilities with regard to all
safety management processes, decisions and actions.
(e) An SMS organisational accountabilities diagram is available.
Cross-reference documents
7. Safety reporting
A reporting system should include both reactive (accident/incident reports, etc.) and proactive/
predictive (hazard reports). Describe the respective reporting systems. Factors to consider include:
report format, confidentiality, addressees, investigation/evaluation procedures, corrective/ preventive
actions and report dissemination.
Criteria
(a) The organisation has a procedure that provides for the capture of internal occurrences including
accidents, incidents and other occurrences relevant to SMS.
(b) A distinction is to be made between mandatory reports (accidents, serious incidents, major
defects, etc.), which are required to be notified to the GCAA, and other routine occurrence
reports, which remain within the organisation.
(c) There is also a voluntary and confidential hazard/occurrence reporting system, incorporating
appropriate identity/data protection as applicable.
(d) The respective reporting processes are simple, accessible and commensurate with the size of
the organisation.
(e) High-consequence reports and associated recommendations are addressed to and reviewed by
the appropriate level of management.
(f) Reports are collected in an appropriate database to facilitate the necessary analysis.
Cross-reference documents
Describe the hazard identification system and how such data are collated. Describe the process for the
categorization of hazards/risks and their subsequent prioritization for a documented safety assessment.
Describe how the safety assessment process is conducted and how preventive action plans are
implemented.
(a) Identified hazards are evaluated, prioritized and processed for risk assessment as appropriate.
(b) There is a structured process for risk assessment involving the evaluation of severity, likelihood,
tolerability and preventive controls.
Cross-reference documents
(a) The formal process to develop and maintain a set of Safety Performance Indicators and their
associated performance targets.
(b) Correlation established between the SPIs and the organisation’s safety objectives where
applicable and the process of regulatory acceptance of the SPIs where required.
(c) The process of monitoring the performance of these SPIs including remedial action procedure
whenever unacceptable or abnormal trends are triggered.
(d) Any other supplementary SMS or safety performance monitoring and measurement criteria or
process.
Cross-reference documents
Describe how accidents/incidents/occurrences are investigated and processed within the organisation,
including their correlation with the organisation’s SMS hazard identification and risk management
system.
(a) Procedures to ensure that reported accidents and incidents are investigated internally.
(b) Dissemination of completed investigation reports internally as well as to the CAA as applicable.
(c) A process for ensuring that corrective actions taken or recommended are carried out and for
evaluating their outcomes/effectiveness.
(d) Procedure on disciplinary inquiry and actions associated with investigation report outcomes.
Cross-reference documents
Describe the type of SMS and other safety-related training that staff receive and the process for assuring
the effectiveness of the training. Describe how such training procedures are documented.
Cross-reference documents
Describe the process for the continuous review and improvement of the SMS.
(a) The process for regular internal audit/review of the organisation’s SMS to ensure its continuing
suitability, adequacy and effectiveness.
(b) Describe any other programmes contributing to continuous improvement of the organisation’s
SMS and safety performance, e.g. MEDA, safety surveys, ISO systems.
Cross-reference documents
(a) The organisation has an SMS records or archiving system that ensures the retention of all records
generated in conjunction with the implementation and operation of the SMS.
(b) Records to be kept include hazard reports, risk assessment reports, Safety Action Group/safety
meeting notes, Safety Performance Indicator charts, SMS audit reports and SMS training records.
(c) Records should be traceable for all elements of the SMS and be accessible for routine
administration of the SMS as well as internal and external audits purposes.
Cross-reference documents
Describe the organisation’s process for managing changes that may have an impact on safety risks and
how such processes are integrated with the SMS.
(a) Procedures to ensure that substantial organisational or operational changes take into
consideration any impact which they may have on existing safety risks.
(b) Procedures to ensure that appropriate safety assessment is performed prior to introduction of
new equipment or processes which have safety risk implications.
(c) Procedures for review of existing safety assessments whenever there are changes to the
associated process or equipment.
Cross-reference documents
Describe the organisation’s intentions regarding, and commitment to dealing with, emergency situations
and their corresponding recovery controls. Outline the roles and responsibilities of key personnel. The
Emergency Response Plan can be a separate document or it can be part of the SMS manual.
(a) The organisation has an emergency plan that outlines the roles and responsibilities in the event
of a major incident, crisis or accident.
Cross-reference documents
1. Introduction
Principles of RCA are closely related to those of risk assessment, particularly in terms of the
thoroughness of the analysis. Both processes consider not simply the person involved in an
issue, but all aspects of the organisation and each individual in that organisation where that
person works. This approach has the premise that human error is a consequence rather than a
deliberate action and, as such, proactive measures and continuous reform of different aspects
of the processes and organization can address latent conditions in the system and increase the
system’s resistance to operational hazards. The term “latent conditions” refers to flawed
procedures or organizational characteristics capable of creating hazards if the right conditions or
actions occur.
Therefore, RCA treats errors as defects in the system rather than in an individual. RCA looks
beyond the symptom to find the organizational defect that permitted an error to occur. The
more thorough the analysis, the greater the likelihood you will uncover why the system
deficiency could occur, and how your organization can respond definitively.
An effective RCA can be as simple as asking and answering a question (five times) about why
something happened. A superficial analysis might have led to disciplinary action against one
individual, which is indicative of a blame culture, and would, most likely, lead to a recurrence of
the same error by a different individual.
(b) Within the field organisation, human factors analysis looks at how their staffs communicate
and perform in the work environment and then seeks to incorporate that knowledge into the
design of equipment, processes, and organisations. This enhances safety and maximizes the
human contribution, partly by designing systems to anticipate the inevitability of human
error. The human factors discipline addresses a wider range of issues affecting how people
interface with technology and the operational system; how people learn about new or
changed equipment, technology, and documentation; and how people adapt to the general
workplace environment.
(c) Any organisation should be aware that knowledge gained from human factors can help to
avoid operational staff errors, ensure that individuals’ initial skill sets match task
requirements, ensure that individuals maintain and improve their skills, and enhance the
work environment.
GCAA expects that any RCA consider a human factors is part of the investigation of individual events
by any personnel designated to respond to safety related occurrences. Otherwise, data reviewed in
a quality assurance process could be incomplete
(d) A proper implementation of RCA, need a suitable and sustainable “Just Culture” environment,
which should discourage the temptation to quick fixes by blaming operational and looking for
corrective actions on unrealistic and unachievable human performance.
YES
a. Is an additional
procedure or policy
Did procedure or policy NO necessary?
exist to prevent failure? b. If yes, Describe
proposed additional
procedure or policy
YES
YES
YES
YES
Threats A possible direct cause that will potentially release a hazard by producing a top event.
Consequences A potential event resulting from the release of a Hazard, which directly results in loss or
damage.
Top Event A point in time which describes the release or loss of control over a Hazard (the undesired
system state).
Hazard: The condition, object or activity with the potential of causing injuries to personnel, damage to
equipment or structures, loss of material or reduction of ability to perform a prescribed function.
Escalation Factors: A condition that leads to increased risk by defeating or reducing the effectiveness of
controls (a control decay mechanism).
Escalation Factor Control: A control that manages the conditions which reduce the effectiveness of
other controls
Threat Barrier: Measures that are considered to reduce the likelihood of the top event to occur.
Recovery Measure: Measures that are considered to reduce the likelihood of the top event developing
into a consequence as well as mitigating the severity of the consequence.