Building and Implementing a Robust Safety Management Framework

Building and Implementing a Robust Safety Management Framework - A Regulator's Perspective August 2013 FAA Michael Daniel, PMP Senior Manager (Retired) Proud Member Flight Safety Foundation

Overview ◢ What SMS is to Regulators ◢ What Regulators Are Applying ◢ What Service Providers Should Do ◢ FAA & EASA on SMS ◢ Recommendations Risk Uncertainty Premises 1. There are knowns; there are things we know that we know 2. There are known unknowns; meaning, there are things that we now know we don’t know 3. There also unknowns; there are thing we do not know we don’t know 2 Raising The Bar

ICAO Safety Management Framework Annex 19 reinforces the role played by States in managing aviation safety, stressing the concept of overall safety performance in all domains in coordination with service providers. Policy WHAT IS REQUIRED Principles Gravitas Procedures ACTIONS TO BE TAKEN Accountabilities WHO IS RESPONSIBLE HOW IS IT ACHIEVED 3

The Evolving Annex 19 Ø Recommendations for Amendment to Annex 19 - Due 4 Quarter 2014 Ø Guidance material due in 2014 and 2016 Ø States need to file differences by October 2013 nt ro e vem tu es niti r ppo O 4 fo p r Im

Safety Management Manual (Doc 9859 3 rd Ed) Restructured according to the SSP and SMS frameworks. Its Objective is to provide States and Product/Service providers with: • An overview of accepted safety management fundamentals. • A summary of ICAO SARPs. • Guidance on the ICAO harmonized State Safety Programme (SSP) framework and its implementation and operation. • Guidance for product and service providers on Safety Management System (SMS) framework and its implementation and operation. (i. e. SMS Policy, SMS Manager Position, Sample PD’s, Gap Analysis) 5

The Regulator: Change in Role and Position State Safety Plan (SSP): Ø Responsible for regulations Ø Responsible for periodic or special on-site audits of the SMS including verification of procedures Basic Role of the Regulator: Ø Ø To agree key safety standards and principles To ensure national standards meet international To resist unacceptable shortcuts to safety To ensure service providers have appropriate safety measures in place (including SMS) Ø To monitor overall safety performance Ø To ensure implementation of remedial actions 6

Regulator Basic Expectations of Safety Management • A structured means of safety risk management decision making • A means of demonstrating safety management capability before system failures occur • Increased confidence in risk controls though structured safety assurance processes • An effective interface for knowledge sharing between regulator and certificate holder • A safety promotion framework to support a sound safety culture 7

The Regulator(s) Can Present Several Challenges to The Service Provider Examples of Different Regulator Applications: Ø Requiring Two Accountable Managers Ø Not Designating an SMS Manager for Large Organizations Ø Performing SMS Audits (On-Site) Ø Not Performing Audits Ø Approving SMS Manuals Ø Accepting Manuals Approved by Other Authorities Ø Requiring SMS as part of QMS Ø Not Requiring or Enforcing SMS 8

The Regulator’s Enforcement Policy – Disclosure of Safety Data Does the SSP enforcement policy include provision to protect the sources of information obtained from voluntary incident reporting systems? [3. 4. 8(d); App 3; App 11] And De-conflict Enforcement Policies with Accident/Incident Policies! 9

Role of the Safety Manager: What are the Regulators Requiring? Is it Safety or Quality? At What Level? Quality and Safety Management Key Points Ø QMS and SMS – Common Methods and Techniques, but different Objectives: • QMS Objective is Customer Satisfaction • SMS Objective is Aviation Safety Focused Ø Not required to have a QMS, but if an entity does have one, it cannot conflict with SMS "It is how the tools and techniques are used, along with a focus on investigation of events, which makes the quality and safety management systems different. The quality systems do not investigate incidents or accidents for risk assessment. Quality systems audit output of a process only for variance, and makes adjustments. SMS investigates events, looking for contributing factors from all influencing sources. " Source: "Flight Safety Information February 12, 2010 No. 034 10

What Service Providers Should Do ? Service providers should demonstrate a proactive and systematic approach to its stakeholders Provide comments suggestions to ICAO, Regulators, Associations The use by industry of SMS is an increasingly necessary basis for fulfilling service-providers’ safety responsibilities. Service Provider: Ø Responsible for ensuring safety Ø Responsible for complying with SARPS Ø Responsible for showing to the Regulators that they are managing safety Ø Group Consensus Collaboration Ø Use Industry Tools (i. e. CAST – Safety Enhancements 11

What the FAA is doing Ø Ø 12 1 State Safety Program (SSP) Overview 2 FAA SMS Overview 3 FAA SMS and the Aviation Industry 4 International Collaboration

What the FAA is doing 13

USA SSP The US FAA responsibilities include most of SSP requirements. Other US government organizations, such as National Transportation Safety Board (NTSB), will also need to be included in the US SSP USA meets the intent of most of ICAO SSP requirements (i. e. ATOS, VDRP, FOQA) Ø Differences Filed! 14

Additional SSP Activities 15 USA elected to further enhance SSP by incorporating SMS concepts into: Ø Joint Planning and Development Office (JPDO) SMS Standard Ø Department of Transportation (DOT) SMS Guidance Ø FAA SMS Policy and Guidance Ø Office of Aviation Safety (AVS) SMS Requirements Order Ø Office of Rule Making SMS Order Ø FAA AVS and Airports SMS rulemaking activities

FAA SMS Overview 16

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FAA SMS Order 18

FAA Risk Management 19

How the FAA Regulators Will Approach Safety Oversight 20

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Pilot Projects New FAA Part 5 Pending Issuance In executive coordination at this point and with Office of Management & Budget OMB 22

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Safety Management International Collaboration Group (SM ICG) • Purpose: to promote a common understanding of safety management principles and requirements, facilitating their application across the international aviation community – Collaborate on common SMS/SSP topics of interest – Share lessons learned – Encourage the progression of a harmonized SMS – Share products with the aviation community – Collaboration with international organizations such as ICAO and civil aviation authorities 24

25 SM ICG Products and Outputs • Harmonized SMS requirements and safety oversight processes and measures • Guidance material for regulatory authorities and industry • Standard terminology and hazard taxonomy • Knowledge sharing between authorities

SM ICG Areas of Focus Documentation Best practices Guidance and tools for industry and other authorities Safety behaviour assessment tools Training and promotion material Measurements Safety performance measurement framework Methodology for setting safety performance expectations (SMS and SSP) Process for identifying risk acceptance/thresholds within safety risk management (SRM) Standardization Common taxonomy for hazards Data analysis and sharing processes Comparison and alignment of international SMS and SSP terminology Others Data sharing State Safety Programme Cost and benefits Manufacturer requirements (challenges/questions regarding Annex 8) 26

FAA & EASA SMS Requirements for Foreign Operators? Ø FAA can only apply SMS provisions to Foreign Operators under FAR Part 129. Ø SMS requirements can only applied to the level of FAA compliance to ICAO SARPs. Ø Currently Not in FAA IASA Program Regulation (EC) No 216/2008 and Part-TCO EASA Third Country Evaluation Phase For operators in category A, the process will consist of a straight-forward desktop file review. Operators who have been grouped into categories B and C are required to provide additional information online including at least: - compliance statements with a set of selected ICAO SARPS, including references to the applicant’s operations manual; - additional information that will enable the Agency to prepare for the assessment in the areas airworthiness, operations and safety management; - a statement of the competent authority of the applicant confirming that all information is true and correct Basic Viewpoint “Equivalent Level of Safety” 27

12/JUL/2013: EASA Committee votes favourably on the EASA TCO proposal. The meeting of The EASA Committee took place in Brussels from Wednesday 10 to Friday 12 July, during which the proposal for a Commission Regulation on Third Country Operators (TCO) was adopted. The proposal will now undergo European Parliament and European Council scrutiny, and its final adoption and publication by the European Commission is expected before the end of 2013. And Other Authorities? - It may vary from requiring IATA IOSA Registration to having an Authority Approved Safety Management Program 28

With Reference to EASA SSP 29

Some Recommendations ◢ 1 st Conform with Home Authority’s SMS Reqmts. ◢ Have strong policy statement driven (ICAO template) ◢ Perform Continual Gap and SWOT Analysis ◢ Provide comments suggestions to ICAO, Regulators, Associations, SM ICG ◢ Have strong internal SMS audit program ◢ Third party audits on occasion and 30

Structure in SMS Vertical Alignment International Standards Corporate Policy Department Alignment Head of Section 31 • ICAO International Standards (Annex 19) • Regulatory Safety Requirements • Corporate Policy • Aligned CEO/Accountable Manager Statement • Organization Department Safety/Position Description Alignment • Processes-Procedures Alignment • Head of Section Safety/Position Description Alignment • Procedures/Forms-Template/Task Alignment

SMS Effectiveness Realization E f f e c t i v e n e s s Expected Effective Implementation 2009 SMS ICAO Standard 32 New Annex 19

Useful Links http: //www. skybrary. aero/index. php/Main_Page http: //www. aviation-insight. aero Michael Daniel, PMP FAA Senior Manager (Retired) mdaniel@aviation-insight. aero 33