FAA SMS Framework Guide
FAA SMS Framework Guide
FRAMEWORK
For:
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Component 1.0 Safety Policy and Objectives ........................................................................... 17 Element 1.1 Safety Policy......................................................................................................... 18 Element 1.2 Management Commitment and Safety Accountabilities ...................................... 19 Element 1.3 Key Safety Personnel............................................................................................ 19 Element 1.4 Emergency Preparedness and Response............................................................... 20 Element 1.5 SMS Documentation and Records........................................................................ 20 Component 2.0 Safety Risk Management (SRM) .................................................................... 22 Element 2.1 Hazard Identification and Analysis ...................................................................... 23 Process 2.1.1 System and Task Analysis............................................................................... 23 Process 2.1.2 Identify Hazards ............................................................................................. 23 Element 2.2 Risk Assessment and Control ............................................................................... 23 Process 2.2.1 Analyze Safety Risk......................................................................................... 23 Process 2.2.3 Control/Mitigate Safety Risk .......................................................................... 24 Component 3.0 Safety Assurance .............................................................................................. 26 Element 3.1 Safety Performance Monitoring and Measurement.............................................. 26 Process 3.1.1 Continuous Monitoring .................................................................................. 26 Process 3.1.2 Internal Audits by Operational Departments................................................. 27 Process 3.1.3 Internal Evaluation ........................................................................................ 28 Process 3.1.4 External Auditing of the SMS ......................................................................... 29 Process 3.1.5 Investigation ................................................................................................... 29 Process 3.1.6 Employee Reporting and Feedback System. .................................................. 29 i
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FAA: SMS Framework AVIATION SERVICE PROVIDER SAFETY MANAGEMENT SYSTEM (SMS) FRAMEWORK 1. Introduction: Background
One of the key objectives of the Office of the Associate Administrator for Aviation Safety (AVS) and of the Flight Standards Service (AFS) is to produce a system of expectations, guidance, and tools that allow aviation service providers to develop and implement corporatelevel safety management systems (SMSs) across multiple types of business and FAA certificates. AVS and AFS seek to minimize the need for multiple management systems in companies that must, due to the nature of their businesses, interact with multiple regulatory authorities. A functional framework consisting of a set of requirements for SMS processes was originally developed and published as Appendix 1 to AC 120-92. The elements of that process were considered to be essential to development and implementation of an effective, comprehensive SMS for an aviation service providers organization. This revised SMS framework, based on the original expression of expectations, as been reorganized to address the issues outlined below. AVS and AFS have conducted and continue to conduct, extensive dialogue with our domestic industry constituents as well as with foreign authorities and businesses who have FAA-issued certificates and other authorizations. The structure of the framework for aviation service providers reflects four key issues: 1. To provide aviation service providers in industry with a standardized set of concepts, documents, and tools for voluntary development and implementation of safety management systems; 2. To bring SMS standards for implementation of safety management systems into conformance with AVS policy in FAA Order VS 8000.367, appendix B; 3. To align the structure and format of Flight Standards documents and tools with the ICAO SMS frameworks, and; 4. To produce a set of documentation and tools that are internally mapped in a manner that is easier to use than the first generation of tools. Except for changes in titles and a small number of changes to text, which were necessitated to align with the requirements in FAA Order VS 8000.367, the expectations in this document are unchanged from original guidance. However, they have been restructured to align with the structure of the ICAO Frameworks. Consequently, some text has been moved from the original placement. To provide clearer understanding, components, elements and processes are defined in terms of functional expectations, i.e., those characteristics that would be expected to be incorporated in a robust SMS. Functional expectations are further defined in terms of performance objectives and design expectations to better align with current system safety and ATOS models. 1
4. References
This Framework is in accordance with the following documents, as revised: Annex 6 to the Convention on International Civil Aviation, Operation of Aircraft International Civil Aviation Organization (ICAO) Document 9859, ICAO Safety Management Manual (SMM) 2
Audit scheduled, formal reviews and verifications to evaluate compliance with policy, standards, and/or contractual requirements. The starting point for an audit is the management and operations of the organization, and it moves outward to the organization's activities and products/services. Internal audit an audit conducted by, or on behalf of, the organization being audited. External audit an audit conducted by an entity outside of the organization being audited.
Aviation system the functional operation/production system used by the service provider to produce the product/service (see Figure 1). Complete nothing has been omitted and the attributes stated are essential and appropriate to the level of detail. Conformity Fulfillment of a requirement (ref. ISO 9000-2000). This includes but is not limited to compliance with Federal regulations. It also includes company requirements, requirements of operator developed risk controls or operator specified policies and procedures. Continuous monitoring uninterrupted watchfulness over the system. Corrective action action to eliminate or mitigate the cause or reduce the effects of a detected nonconformity or other undesirable situation. Correct accurately reflects the item with an absence of ambiguity or error in its attributes. Documentation information or meaningful data and its supporting medium (e.g., paper, electronic, etc.). In this context it is distinct from records because it is the written description of policies, processes, procedures, objectives, requirements, authorities, responsibilities, or work instructions.
Safety objectives. something sought or aimed for, related to safety. NOTE 1: Safety objectives are generally based on the organizations safety policy. NOTE 2: Safety objectives are generally specified for relevant functions and levels in the organization.
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Safety planning part of safety management focused on setting safety objectives and specifying necessary operational processes and related resources to fulfill the quality objectives. Safety risk the composite of predicted severity and likelihood of the potential effect of a hazard. Safety risk control anything that reduces or mitigates the safety risk of a hazard. Safety risk controls must be written in requirements language, measurable, and monitored to ensure effectiveness. Safety Risk Management (SRM) a formal process within the SMS composed of describing the system, identifying the hazards, assessing the risk, analyzing the risk, and controlling the risk. The SRM process is embedded in the processes used to provide the product/service; it is not a separate/distinct process. The flow diagram of Safety Risk Management is at Figure 3, at the end of this definitions section. Safety promotion a combination of safety culture, training, and data sharing activities that support the implementation and operation of an SMS in an organization Separate Aviation Maintenance Service providers - This pertains to independent maintenance organizations, such as, but not limited to, certificated repair stations, non-certificated repair facilities, etc. This does not pertain to an air operators maintenance organization (it is not intended to duplicate 1.0 B) 1) a) 3) of an Air Operators organization). Severity the consequence or impact of a hazard in terms of degree of loss or harm. Substitute risk risk unintentionally created as a consequence of safety risk control(s). System an integrated set of constituent elements that are combined in an operational or support environment to accomplish a defined objective. These elements include people, hardware, software, firmware, information, procedures, facilities, services, and other support facets. System Attributes - See Attributes. Top Management (ref. ISO 9000-2000 definition 3.2.7) the person or group of people who directs and controls an organization.
Adapted from definition 3.2.5 in ISO 9000-2000 for quality objectives. Adapted from definition 3.2.9 in ISO 9000-2000 for quality planning.
Initial designs of systems, organizational procedures, and products Development of operational procedures Planned Changes
Hazards documented Hazards tracked Assignment of severity and likelihood for each hazard (as documented in 2.1.2) Assessment of acceptability of each risk (as documented in 2.1.2) Risk control/mitigation plans for each hazard with unacceptable risk (as assessed in 2.2.2)
Component 3.0 - Safety Assurance 3.1.1 Continuous Monitoring 3.1.2 Internal Audit 3.1.1 3.1.2(B)(5)(b)(1) 3.1.2(B)(5)(b)(3) & (4) 3.1.3 Internal Evaluation 3.1.3(B)(3)(d)(2)(a) .1.3(B)(3)(d)(2) (c) & (d) 3.1.4 External Evaluation 3.1.5 Investigations 3.1.4 3.1.5(B)(1) 3.1.5(B)(1)(a) 3.1.5(B)(1)(b) 3.1.5(B)(1)(c) Objective evidence of monitoring activities IAW company policy Plans Reports/Records Plans Reports/Records Objective evidence of audit findings of external audits (e.g. IOSA, IS-BAO, ACSF, CASE, FAA) Data collected (e.g. records, reports) for investigations of: Incidents Accidents Regulatory violations (e.g. VDRP records)
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3.1.6(B)3) 3.1.6(B)(4) 3.1.7 Analysis of Data 3.1.7(B) 3.1.7(B)(1) 3.1.8 System Assessment 3.1.9 Preventive/Corrective Action 3.1.8(B)(4) 3.1.9(B)(1)
Evidence of monitoring of ERS data for hazards Evidence of analysis of ERS data Objective evidence of analysis processes for each data type Records of system assessments Corrective action plans
Records of disposition and status of corrective actions Objective evidence of management reviews (e.g. minutes, log)
Component 4.0 - Safety Promotion 4.1.1 Competency Requirements 4.1.2 Training 4.1.1(B)(1) 4.1.2(B)(1) 4.1.2(B)(3) 4.1.2(B)(4) Documented competency requirements IAW 1.2 (B)(3) & 1.3(B)(1) Plans/requirements Records Reviews
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Start
2 .1 H az a rd ID & A n aly s is
Inputs : 2.0 Safe ty Ris k M anage m en t, (B) (2) (a), (b) & (d) Ne w Sy ste m Sy ste m C hang e Ne w Opera tiona l Proc edure (2.1.1) Inputs : 2.0 Safe ty Ris k Man age m en t, (B) (2) (c) Also fro m SA: 3.1.8 (B) (3) (2.1.2)
2 .2 R is k A s s e s s m e n t & Co n tro l
Risk Ana lysis
(2.2.1) Evaluate C ontrols 2.2.3 C ontro l/ Mi tiga te Safe ty Risk, (B) (2) & (3)
Risk C ontrol
(2.2.3)
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System Operation
3.1.1 Continuous Monitoring 3.1.2 Internal Audits 3.1.3 Internal Evaluation 3.1.4 External Evaluation 3.1.5 Investigations 3.1.6 Employee Reporting
Analysis
System Assessment
Outputs: 3.1.8 System Assessment, (B) (3), into Safety Risk Management 2.0 (B) (2) (c) 3.1.8 System Assessment 3.1.10 Management Review
Corrective Action
Note: Each data source should be traceable through Analysis (3.1.7 (B) (1)), Assessment (3.1.8 (B) (1), and Corrective Action (3.1.9 (B) (1), where necessary.
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Measures are not expected for each procedural step. However, measures and criteria should be of sufficient depth and level of detail to ascertain and track accomplishment of objectives. Criteria and measures can be expressed in either quantitative or qualitative terms.
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Element 2.1 Hazard Identification and Analysis Process 2.1.1 System and Task Analysis
A) Performance Objective: The service provider will analyze its systems, operations, and operational environment to gain an understanding of critical design and performance factors, processes, and activities to identify hazards. B) Design Expectations: 1) System and task descriptions will be developed to the level of detail necessary to: a) Identify hazards, b) Develop operational procedures, and, c) Develop and implement risk controls.
Element 2.2 Risk Assessment and Control Process 2.2.1 Analyze Safety Risk
A) Performance Objective: The service provider will determine and analyze the severity and likelihood of potential events associated with identified hazards and identied factors associated with unacceptable levels of severity or likelihood.
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While it is recognized that identification of every conceivable hazard is impractical, operators are expected to exercise due diligence in identifying and controlling significant and reasonably foreseeable hazards related to their operations.
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Element 3.1 Safety Performance Monitoring and Measurement Process 3.1.1 Continuous Monitoring
A) Performance Objective: The service provider will monitor operational data, including products and services received from contractors, to identify hazards, measure the effectiveness of safety risk controls, and assess system performance. B) Design Expectations: 1) The service provider will monitor operational data (e.g., duty logs, crew reports, work cards, process sheets, and reports from the employee safety feedback system specified in Process 3.1.6) to: a) Determine conformity with safety risk controls (described in Process 2.2.3); b) Measure the effectiveness of safety risk controls (described in Process 2.2.3); c) Assess system performance; and d) Identify hazards. 2) The service provider will monitor products and services received from subcontractors.
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