< Previous8-6 Safety Management Manual (SMM) 8.3.5.6 In contrast, Standards which enable performance-based regulations are expressed in terms of the desired outcome. The resulting performance-based regulations require that the service provider demonstrate that its proposed approach will achieve the desired outcome. The following is an example of a performance-based Standard from Annex 6, Part I. 7.2.11 The aeroplane shall be sufficiently provided with navigation equipment to ensure that, in the event of the failure of one item of equipment at any stage of the flight, the remaining equipment will enable the aeroplane to navigate in accordance with 7.2.1 and, where applicable, 7.2.2, 7.2.5 and 7.2.6. 8.3.5.7 Note that the Standard above does not indicate the specific navigation equipment required. Instead, it describes the outcome that is desired, that is, that in the event of the failure of one item, the remaining equipment need to enable the aircraft to still be navigated safely. The required equipment would depend on the design of the aircraft. Regulations written in this manner would require the air operator[2] to provide the necessary data to the authority to show how it complies with this requirement. This can be done through its own analysis, but for such types of performance-based regulations, the information needed is often available from other sources. In this case, both the authority and air operator would make use of data from aircraft manufacturers to guide their decision, and there is no need for the air operator to develop its own novel solution. When writing performance-based regulations, States need to keep in mind how compliance can be demonstrated. There may be a need for the State to develop guidance material and/or acceptable means of compliance to support the industry in meeting the requirement. 8.3.5.8 The following is another example of a performance-based Standard from Appendix 4 of Annex 19. 2.1.1 The service provider shall develop and maintain a process to identify hazards associated with its aviation products or services. 8.3.5.9 In the example above, although the Standard requires that a process be put in place to identify hazards, it does not specify what such a process should look like. States may allow service providers to design their own methodology. The regulator’s role would be to assess whether the service provider’s methodology, processes and system would indeed result in hazards being identified. The authority would also make an assessment of the performance of the service provider’s hazard identification process, for example by evaluating the volume, types and significance of the hazards identified. Performance-based regulations that are written in this manner require regulators to have the skills and expertise to assess the performance of the system, rather than to merely assess prescriptive compliance with the letter of the regulations. More resources are also required for evaluation as implementation would differ from one service provider to another. Providing prescriptive and performance-based options 8.3.5.10 In some cases, ICAO SARPs require that prescriptive regulations be established, and at the same time offer States the choice of establishing performance-based regulations to support alternative means of compliance. Where States establish both prescriptive and performance-based regulatory options, service providers that do not have the expertise to develop their own approach to meet the performance-based regulations can choose to comply with the prescriptive regulations. For those service providers who do have such expertise, the resulting regulations allow service providers to develop a means of compliance appropriate to their own operations, and may also offer potential for increased operational flexibility and more efficient use of resources. Fatigue management Standards, such as those in Annex 6, Part I, provide a good example of this: 4.10.1 The State of the Operator shall establish regulations for the purpose of managing fatigue. These regulations shall be based upon scientific principles, knowledge and operational experience with the aim of ensuring that flight and cabin crew members are performing at an adequate level of alertness. Accordingly, the State of the Operator shall establish: a) regulations for flight time, flight duty period, duty period and rest period limitations; and Chapter 8. State Safety Management 8-7 b) where authorizing the operator to use a Fatigue Risk Management System (FRMS) to manage fatigue, FRMS regulations. 4.10.2 The State of the Operator shall require that the operator, in compliance with 4.10.1 and for the purposes of managing its fatigue-related safety risks, establish either: a) flight time, flight duty period, duty period and rest period limitations that are within the prescriptive fatigue management regulations established by the State of the Operator; or b) a Fatigue Risk Management System (FRMS) in compliance with 4.10.6 for all operations; or c) an FRMS in compliance with 4.10.6 for part of its operations and the requirements of 4.10.2 a) for the remainder of its operations. 8.3.5.11 In the example above, the Standard requires States to establish prescriptive flight and duty limitation regulations, while the establishment of regulations to support FRMS is optional. FRMS gives the air operator the opportunity to better address its specific fatigue risks and at the same time offers the potential for operational flexibility outside the prescriptive flight and duty limitation regulations. A State needs to consider whether it is necessary to provide FRMS regulations as an alternative to the mandatory prescriptive limitation regulations and whether it has the necessary resources to provide appropriate oversight of FRMS. Standard 4.10.2 then goes on to clarify that air operators[3] are required to manage their fatigue-related safety risks. Where FRMS regulations are established, they can do so within the prescriptive limitations regulations referenced in 4.10.2 (a), or by implementing a performance-based FRMS referenced in 4.10.2 (b) and (c). Air operators that do not have the expertise to develop an FRMS and meet the associated regulatory requirements would need to comply with the prescriptive regulations. 8.3.5.12 It should be apparent that performance-based regulations are not always appropriate. Prescriptive requirements continue to be appropriate when a standardized means of compliance is necessary, for example to facilitate interoperability. Requirements for runway markings, for example, are necessarily prescriptive in nature. 8.3.5.13 In practice, regulations are rarely fully prescriptive or fully performance-based, but rather contain elements of both. They are also performance-based to different degrees. As a State considers implementing performance-based regulations, it needs to consider the capability and maturity of the industry, specific sectors of industry, or even the maturity of individual service providers and their SMS. Performance-based regulations also demand more of the regulator, requiring them to not only check for compliance, but to also be able to evaluate systems and assess safety performance taking into account the specific operational context of each service provider. States need to ensure that they are able to continue to oversee and manage the industry, noting that higher levels of expertise, as well as more resources, are required. SMS provide a foundation and tools for service providers to meet performance-based regulations, but it is not an automatic assurance that every service provider with an SMS has the ability to do so. It depends on the demands of the specific performance-based requirement. 8.3.5.14 Performance-based regulations also have an impact on enforcement. Enforcement of prescriptive regulations is straightforward as non-compliance can be easily determined. Enforcement is more challenging with performance-based regulations. For example, a service provider may be able to show that it has a process in place that meets the regulation (for example, it has a hazard reporting system in place), but is unable to show that the process can deliver the intended outcome (for example, whether the hazard reporting system is effective). This could lead to the establishment of systems or processes that merely meet the “letter of the law” but does not deliver on the required safety outcome. Regulators may need to involve the relevant enforcement agencies in the development of performance-based regulations to ensure that the regulations are enforceable. 8-8 Safety Management Manual (SMM) 8.3.6 State system and functions 8.3.6.1 Guidance on State system and functions (CE-3), can be found in Doc 9734, Part A. Organization responsible for coordinating the SSP 8.3.6.2 State’s safety management responsibilities can be discharged by multiple aviation authorities within the State. For example, the CAA and an independent AIA. States should clarify which authority within the State is responsible for coordinating the maintenance and implementation of the SSP. Many States assign this role to the CAA, given that the CAA is normally responsible for most of the SSP responsibilities. The roles and responsibilities of all the authorities involved should be identified and documented. SSP coordination group 8.3.6.3 The State should establish a suitable coordination group with representation from the impacted aviation authorities with responsibilities related to the implementation and maintenance of the SSP. Appointment of a coordination group will facilitate good communication, avoid duplication of effort and conflicting policies and ensure effective and efficient SSP implementation. This group is a form of committee chaired by the head of the organization responsible for coordinating the SSP. 8.3.6.4 The State may also find it beneficial to allocate the day-to-day planning and management of the SSP implementation to a person, a department or a team. Such a person, department or team can ensure that the various aspects work together to deliver the State’s safety objectives. SSP functions and activities 8.3.6.5 How States choose to organize their workforce and organizational structure to address the acceptance and monitoring of SMS implementation by service providers in compliance with Annex 19 is a matter for each State to decide. A State can choose to establish a new office or to add this responsibility to the responsibilities of existing offices, for example: airworthiness office, flight operation office, air navigation and aerodrome office, etc. The decision will depend on how the State chooses to address its new competency requirements. 8.3.6.6 It is important for the various aviation authorities to have role clarity. This should include all of their SSP obligations, functions and activities. The State should ensure that each authority understands its contribution to meeting each Annex 19 requirement. Most importantly, their responsibility for management of safety in the State. The obligations and functions of each aviation authority with respect to SSP implementation should be documented to avoid ambiguity. 8.3.6.7 There should be appropriate governance structures in States where the staff involved in safety are geographically dispersed. A complex governance structure may not be necessary for less complex aviation systems, where few people are involved in safety management. The State should ensure that all personnel have the same understanding of SSP implementation at a national level. The SSP implementation approach should be documented. State safety policy and safety objectives 8.3.6.8 Effective implementation of an SSP requires commitment by the State’s senior management and support of personnel at all levels. State safety policies and State safety objectives are high-level statements endorsed by the State aviation authorities. Combined, they guide safety behaviour and resource allocation. The State safety policy and objectives should be published and reviewed periodically to ensure they remain relevant and appropriate to the State. State safety policy 8.3.6.9 The commitment of senior management should be articulated in the State safety policy. The State safety policy is a formal document describing the State’s safety intentions and direction. The State safety policy Chapter 8. State Safety Management 8-9 projects senior management’s attitude to safety and to the promotion of a positive safety culture in the State. It can be thought of as the State’s safety mission and vision statement. 8.3.6.10 The safety policy should address key practices that are essential for safety management and how senior management expects to deliver on their safety responsibilities, (e.g. the use of a data-driven approach). The principles reflected in the safety policy should be clearly visible in the day-to-day practices of the State. 8.3.6.11 The State safety policy is endorsed by the State aviation authorities to demonstrate their safety intent and is implemented as a procedure or protocol. A typical policy statement is: “We will achieve safety through: (1) our acceptance of accountability for safe conditions and behaviours (2) a culture of safety leadership, collaboration, open communication, etc.”. State safety objectives 8.3.6.12 The development of safety objectives starts with a clear understanding of the highest safety risks in the aviation system. Safety risk in the aviation system is influenced by many different factors, such as the size and complexity of the aviation system as well as the operational environment. The development of a good system description will provide a good background and understanding. Refer to SSP implementation at the end of this chapter. 8.3.6.13 Quantitative data should be used where available to develop an understanding of its top safety risks. The State may also use qualitative information and expert analysis. A group of selected experts may be created to participate in guided discussions to gain understanding of the broader safety risks across the aviation system. This group would have a similar role as the service provider’s safety review board (SRB), as discussed in Chapter 9; in this case at State level. These experts can be guided by available safety trend information, known accidents and serious incidents contributing factors, or known deficiencies in the State’s SSO processes. They could also consider regional objectives or global objectives as identified in the GASP. This brainstorming-type approach could be done collaboratively with service providers, to identify “known” safety issues for each aviation sector. 8.3.6.14 State safety objectives are brief, high-level statements that provide direction for all relevant State aviation authorities. They represent the desired safety outcomes that the State aims to achieve. It is also important, when defining the safety objectives, to take into account the State’s ability to influence the desired outcomes. The safety objectives represent the State’s priorities for the management of safety and provide a blueprint for allocating and directing the State’s resources. 8.3.6.15 The safety objectives support the identification of the State’s SPIs and SPTs and the subsequent establishment of the acceptable level of safety performance (ALoSP), discussed later in this Chapter. Safety objectives work together as a package with SPIs and SPTs to enable the State to monitor and measure its safety performance. Further guidance on SPIs and SPTs can be found in Chapter 4. 8.3.6.16 Once the SSP is implemented, the State should periodically reassess its identified safety risks by analysing the safety information generated by the SSP. The analysis will also support the identification of emerging issues. Guidance on safety analysis can be found in Chapter 6. The State should also periodically review its progress toward achieving its safety objectives and their continued relevance, keeping in mind any reassessments of the current risks. State safety resources 8.3.6.17 The State needs to ensure that agencies that have safety responsibilities are given sufficient resources to carry out their mandates. This includes both financial resources as well as human resources. 8.3.6.18 Some aviation authorities receive their funding based on a State-allocated budget. Others are funded by fees and charges collected from those participating in the aviation system (such as licence and approval fees), or from those using services within the aviation system (for example levies on passengers or fuel). The source of funding that is most appropriate to the State depends on the circumstances of that State. For example, a State that 8-10 Safety Management Manual (SMM) has a small aviation industry may find that it is not enough for its CAA to rely only on fees and charges to fund its regulatory activities. A State may need to have multiple sources of funding for its aviation activities. 8.3.6.19 As a State starts to fully implement its SSP and adopt safety management practices, it may need to revisit its budget and funding to ensure that it continues to have a sufficient revenue stream. New functions are introduced and will need to be carried out well in order for a safety management approach to succeed, including for example SRM, data collection and analysis, and safety promotion. Safety management also requires the State’s aviation authorities to be able to continually monitor and review their own processes to manage risk. Inspectors and other personnel may need to be retrained. As such, the State may find it necessary to allocate sufficient financial resources for State agencies when transitioning to a safety management approach. National Aviation Safety Plan (NASP) 8.3.6.20 Assembly resolution A39-12 on ICAO global planning for safety and air navigation recognizes the importance of effective implementation of national aviation safety plans. It resolves that States should develop and implement national aviation safety plans, in line with the goals of the Global Aviation Safety Plan (GASP, Doc 10004). Each State should produce a national aviation safety plan. If the State has implemented an SSP, the plan should be linked to this programme. The national aviation safety plan presents the strategic direction for safety management at the national level, for a set time period. It outlines to all stakeholders where the State aviation authorities should target resources over the coming years. 8.3.6.21 Regional and national aviation safety plans should be developed in alignment with the GASP. At the regional level, the regional aviation safety groups (RASGs) coordinate the planning process. Regional and national safety enhancement initiative (SEIs) should be adapted based on issues faced by the States concerned. 8.3.6.22 At the international level, the GASP sets forth a strategy which supports the prioritization and continuous improvement of aviation safety. The national aviation safety plan should be developed in alignment with the GASP and the regional aviation safety plan. A national aviation safety plan allows the State to clearly communicate its strategy for improving safety at the national level to all stakeholders, including other government branches and the travelling public. It provides a transparent means to disclose how the CAAs and other entities involved in civil aviation work to identify hazards and manage operational safety risks and other safety issues. It also illustrates how planned SEIs will help the State meet the established goals. The national aviation safety plan emphasizes the State’s commitment to aviation safety. Since the plan contains information on safety performance measurement, it can also be used as a means to demonstrate the positive impact of investments in existing SEIs which have been successful, or as a way to justify the need for additional resources to address ongoing or future challenges. 8.3.6.23 The national aviation safety plan should include safety goals, targets and indicators in line with the GASP, as well as a series of SEIs that will be carried out to address national operational safety risks identified through the State and industry’s safety risk management processes. The plan should address the identification and prioritization of safety issues across the different sectors of aviation. The State should implement the SEIs contained in the plan through its existing safety management activities. SSP Documentation 8.3.6.24 The State should describe its SSP in a document to ensure that all relevant personnel have a common understanding. The document should include its structure and associated programmes, how its various components work together, as well as the roles of the different State aviation authorities. The documentation should complement existing processes and procedures and broadly describe how the various SSP sub-programmes work together to improve safety. Cross-references to safety responsibilities and accountabilities of authorities in supporting documentation may also be included. The State should choose a means of documentation and dissemination that would best serve its environment, for example in a physical document or on an appropriately controlled website. Regardless of the communication channel, the aim is to facilitate a common understanding of the SSP by all relevant personnel. Chapter 8. State Safety Management 8-11 8.3.7 Qualified technical personnel 8.3.7.1 Guidance on qualified technical personnel performing safety-related functions (CE-4) can be found in Doc 9734, Part A. General guidance 8.3.7.2 States will need to identify and address the competencies required for effective implementation of SSP taking into account the roles and responsibilities under the SSP performed by their personnel. These competencies are in addition to those required for the conduct of compliance oversight and may be addressed by training existing staff or by hiring additional staff and include, but are not limited to: a) enhanced leadership skills; b) understanding of business processes; c) experience and judgement required to assess performance and effectiveness; d) safety risk-based surveillance; e) safety data collection and analysis; f) safety performance measurement and monitoring; and g) safety promotion activities. 8.3.7.3 Guidance on the development and maintenance of a strong inspectorate workforce can be found in the Manual on the Competencies of Civil Aviation Safety Inspectors (Doc 10070). 8.3.7.4 The State should determine the most appropriate training for personnel with different roles and responsibilities in the organization. The following are examples of training that should be considered: a) briefings or familiarization training for senior management on SSP, SMS, safety policy, objectives and ALoSP; b) training for inspectors on the SSP and SMS principles, how to carry out SMS assessments, how to evaluate a service provider’s SPIs for acceptance and how to generally oversee the service provider in a safety management environment; c) soft skills training (effective communication skills, negotiation skills, conflict resolution, etc.) to support inspectors in working collaboratively with service providers to improve safety performance whilst ensuring continued compliance with established regulations; d) training for personnel responsible for data analysis, safety objectives, SPIs and SPTs; e) training for aviation medical examiners and medical assessors; f) protection of safety data, safety information and related sources and enforcement policy training for legal personnel, etc.; and g) SSP and SMS training for service provider safety investigators. 8.3.7.5 Safety training programmes for personnel involved in SSP-related duties should be coordinated amongst State organizations, as appropriate. The scope of SSP and SMS training or familiarization should reflect the 8-12 Safety Management Manual (SMM) actual SSP processes, and the SSP itself as it evolves and matures. Initial SSP and SMS training may be limited to generic SSP elements or SMS framework elements and guidance. 8.3.7.6 To ensure all relevant technical staff is properly qualified, the State should: a) develop an internal training policy and procedures; and b) develop an SSP and SMS training programme for relevant staff. Priority should be given to SSP-SMS implementation personnel and operational/field inspectors involved in service providers’ SMS surveillance / monitoring; (including State-specific SSP processes and their relevance). 8.3.7.7 Many different types of SSP and SMS training are available including online courses, classroom courses, workshops, etc. The type and amount of training provided should ensure that relevant staff develops the competence needed to perform their roles and understand their contribution to the SSP. The aim is to ensure a person or team addresses each aspect of the SSP, and that they are trained to perform the allocated role. 8.3.7.8 Appropriate and sufficient training for inspectors will ensure consistent surveillance and required capabilities to be effective in a safety management environment. States should consider the following: a) Surveillance and monitoring of service providers’ SMS will require competencies that may not have been critical before SMS requirements were introduced. Inspectors will need to complement their existing technical knowledge with additional skills to assess the suitability and effectiveness of the service providers’ SMS implementation. This approach requires working in partnership with industry; to gain the trust of service providers to facilitate sharing of safety data and safety information. States will need to provide the appropriate training to ensure that personnel responsible for interaction with the industry have the competencies and flexibility to perform the surveillance activities in an SMS environment. A training needs analysis can be used to identify the appropriate training. b) The training should also provide staff with an awareness of the role and contributions of other departments within their aviation authority and other State aviation authorities. This will allow inspectors as well as staff from different State aviation authorities to have a consistent approach. It will also facilitate a better understanding of safety risks across various sectors. Inspectors can also better understand how they contribute to achieving the State safety objectives. 8.3.8 Technical guidance, tools and provision of safety-critical information 8.3.8.1 Guidance on Technical guidance, tools and the provision of safety-critical information (CE5) can be found in Doc 9734, Part A. 8.3.8.2 The State should consider providing guidance to their inspectors and service providers to help with the interpretation of safety management regulations. This will promote a positive safety culture and aid the service provider in meeting their safety objectives, and consequently, the State’s safety objectives, which are often achieved through regulation. The assessment of SMS may require additional tools to determine both the compliance and performance of the service providers’ SMS. Any tools developed will require training for affected staff before being implemented. Chapter 8. State Safety Management 8-13 8.4 COMPONENT 2: STATE SAFETY RISK MANAGEMENT 8.4.1 States need to identify potential safety risks to the aviation system. The State should augment its traditional methods of analysing the causes of an accident or incident with proactive processes to achieve this. Proactive processes enable the State to identify and address precursors and contributors of accidents, and strategically manage safety resources to maximize safety improvements. States should: a) require that their service providers implement SMS to manage and improve the safety of their aviation-related activities; b) establish means to determine whether service providers’ SRM is acceptable; and c) review and ensure that the service provider’s SMS remains effective. 8.4.2 The State SRM component includes the implementation of SMS by service providers, including hazard identification processes and the management of associated safety risks. 8.4.3 States should also apply the principles of SRM to their own activities. These include activities such as the development of regulations and prioritization of surveillance activities based on assessed risk. 8.4.4 An area often overlooked by service providers and regulators is the safety risk induced through interfaces with other entities. The interface between SSP and SMS(s) may pose a particular interface challenge for States and service providers. The State should consider highlighting the importance of the SMS interface risk management through its regulations and supporting guidance. Examples of interface risk include: • Dependency – organization A is dependent on organization B to provide goods or services. Organization B is not clear about the expectation and organization A’s dependency and fails to deliver. • Control – interfacing organizations often have minimal control of the quality or effectiveness of the interfacing organization(s). 8.4.5 In both of these instances, interface risk management can illuminate the risk, clarify the mutual expectations and mitigate unwanted consequences through mutually agreed boundary checks. Additional information on interfaces between service providers can be found in Chapter 2. 8.4.6 Licensing, certification, authorization and approval obligations 8.4.6.1 Guidance on licensing, certification, authorization and approval obligations (CE-6) can be found in Doc 9734, Part A. 8.4.6.2 Licensing, certification, authorization and approval obligations are important components of the State safety risk control strategy. They provide the State with assurance that service providers and other pertinent industry representative organizations have achieved the required standards to operate safely within the aviation system. Some States have established common operating regulations to facilitate the recognition or acceptance of certificates, approvals and licenses issued by other States. Such arrangements do not absolve the State from its obligations under the Chicago Convention. 8.4.7 Safety management system obligations SMS regulatory requirements 8.4.7.1 In accordance with Annex 19, the State shall require that service providers and international general aviation operators implement SMS. The requirements address the SMS framework found in Annex 19, 8-14 Safety Management Manual (SMM) Appendix 2 and the supporting guidance found in Chapter 9 of this manual. How these requirements are established will depend on the regulatory framework of the State. 8.4.7.2 States should institute a process that ensures the SMS is acceptable to the State. One approach is to establish timelines and milestones at the State level that represents the required SMS implementation progress. Additional guidance for service providers about how to develop and perform an SMS gap analysis and implementation plan can be found in Chapter 9. 8.4.7.3 The State’s SMS regulatory requirements and SMS guidance material should be periodically reviewed. The review should take into consideration: industry feedback, periodic review of the State safety risk profile, current status, and applicability of ICAO SMS SARPs and guidance material. International general aviation 8.4.7.4 SMS provisions for international general aviation (IGA) are addressed with some flexibility in Annex 19 and are therefore not included in the list of service providers. This sector of aviation is expected to implement the SMS framework. The difference between this and other sectors is that, in this case, States are allowed a degree of flexibility with how they establish the requirements. Consistent with other provisions found in Annex 6, Part II — International General Aviation — Aeroplanes, the State of Registry shall establish criteria for IGA operators to implement an SMS. 8.4.7.5 The establishment of the criteria should require the application of the SMS framework as described in Annex 19, but this might be achieved in a number of ways: a) criteria is established within the existing specific operating regulations for IGA; b) publication of requirements within the regulatory framework in a legal instrument other than specific operating regulations that defines the criteria; or c) making references within the regulatory framework to an SMS industry code of practice that is recognized by the State. 8.4.7.6 In selecting the best approach for the establishment of the SMS criteria for IGA, the State of Registry should consider how the monitoring of the SMS will be performed, including possible delegation of oversight to a third party. As with service providers’ SMS, when determining the acceptability of the SMS, the State of Registry should allow for scalability based on the size, operational environment and complexity of the operation. 8.4.7.7 In the case of large or turbojet aircraft under multiple States of Registry that are issued an air operator certificate (AOC) in accordance with Annex 6, Part I, the operator would be considered a service provider and treated as such with the SMS to be made acceptable to the State of the Operator. SMS acceptance 8.4.7.8 Many service providers have approvals from more than one State or conduct operations in more than one State. There is no Annex 19 requirement to oversee the SMS of a service provider that is outside of the State’s responsibility. However, harmonization of SMS requirements does facilitate acceptance of SMS between States. Harmonization reduces oversight duplication and the need for service providers to comply with similar SMS obligations through (potentially) dissimilar requirements. States should be conscious of policies that increase the administrative and financial burden for certificate holders without adding demonstrable safety value. Importantly, for service providers that do not benefit from common acceptance of basic certificate or approvals, the introduction of SMS has exacerbated the situation. States should try to achieve the benefits of implementation without imposing additional undue burden on service providers. 8.4.7.9 Further, States are encouraged to apply the requirements equally when granting approvals to other States’ service providers, without excessive technical, legal, and administrative burdens. Many service providers need additional resources for initial acceptance by multiple States, and to support periodic monitoring or audits from Chapter 8. State Safety Management 8-15 States who have accepted their SMS. Additional effort is also required when requirements vary, are interpreted differently or are in conflict. 8.4.7.10 Annex 19 provides SMS framework requirements. States transpose the requirements into the State’s regulatory framework. The performance of any organizational system or process, in practice, depends on how the requirements are implemented. There are two major components involved with SMS equivalence and the implications of SMS acceptance among States. 8.4.7.11 The first component is the formal aspects of recognition or acceptance of SMS. Some States have addressed these though bilateral or multilateral agreements that involve a mixture of diplomatic, legal, and technical arrangements between States. In some cases, the acceptance is mutual, but not in all circumstances. 8.4.7.12 The second component is technical equivalence. Technical equivalence can be divided into five areas: • Common requirements. While not sufficient to establish equivalence, use of a common set of requirements provides structure and efficiency for the technical evaluations. These have been established in the various ICAO Annexes. • Implementation expectations. Each State identifies specific expectations for processes, programmes, methods, and tools for the other authority to demonstrate implementation and performance. • Acceptance methodology. Methods States use to evaluate how processes and management capabilities vary between States. This is usually a function of the State’s oversight system (CE-6, Licensing, certification, authorization and approval obligations). • Performance measurement. The methodology used by each State to measure safety performance of certificated and approved organizations is aimed at improving the State’s understanding of the performance potential and status of each organization. • Monitoring policies and methods. Monitoring must assure the performance status of organizations and their SMSs. This is an aspect of the State’s surveillance obligations. Each State must develop an understanding and confidence in the methods used by another authority to oversee their SMSs. This supports acceptance or recognition the SMSs. 8.4.7.13 Service provider’s SMS must be made acceptable to the relevant State authority. Service providers are expected to conduct a gap analysis and develop a workable implementation plan (including approval by the State as a planned task). SMS implementations are generally conducted in three or four stages. Early, collaboration between the service provider and the State authorities will likely lead to smoother development and approval process. For information about SMS implementation see Chapter 9. Acceptance of SPIs and SPTs 8.4.7.14 Service providers’ proposed SPIs are reviewed and accepted by the relevant State regulatory authority as part of the SMS acceptance. States might consider planning the acceptance of a service provider’s SPIs later in the implementation process. This is especially practical for service providers at initial certification as they often do not have enough data to develop meaningful indications. The regulator may be satisfied that the proposed SPIs are appropriate and pertinent to the individual service provider’s aviation activities. Some of the service provider’s SPIs and SPTs may link to the State SPIs and SPTs for measuring and monitoring the ALoSP. This need not be the case for all SPIs and SPTs. More information on safety performance measurement is found in Chapter 4. 8.4.7.15 The acceptance of the service provider’s SPTs may be addressed after the SPIs have been monitored over a period of time. This establishes the baseline performance. It may be based on targets established at the State, regional or global level. Achievement of State SPTs will require the coordination of safety risk mitigation actions with the service provider. Next >