< Previous8-26 Safety Management Manual (SMM) 8.5.5.12 Improving safety performance of operational safety risk tends to be reactive, while improving safety risk management processes tends to be proactive. Improving State processes that better support management of safety risk enables the identification and control of hazards before they manifest as negative outcomes. Achieving the ALoSP 8.5.5.13 A State’s safety performance as indicated by its SPIs and SPTs demonstrate the ALoSP achieved. If any of the SPTs are not met, an evaluation may be needed to better understand why and to determine what actions should be taken. It could be because: a) the targets were not achievable or realistic; b) the actions taken to achieve the target were not appropriate or deviated from the original intent (practical drift); c) changes in other safety risk priorities diverted resources away from meeting a particular target; or d) emerging risks occurred that had not been considered when the targets were set. 8.5.5.14 For the targets that were not met, there will be a need to understand why and for a management decision on whether the safety improvement is sufficient even if it has not met the target and what further actions are required. This may require additional analysis that could identify some risk factors that were not addressed or maybe some risk mitigations in place that are not effective. 8.5.6 Management of change: State perspective 8.5.6.1 Annex 19 does not explicitly require a State to establish formal activities for the management of change under the SSP. However, changes are an ever-present fact in the contemporary aviation system. When changes are introduced into a system, the established safety risk picture of the system will change. Changes may introduce hazards that may impact the effectiveness of existing defences. This could result in new risk or changes to existing safety risks. States should evaluate and manage the impact of change in their aviation systems. 8.5.6.2 An SSP should develop procedures to assess the impact of changes at a State level. The procedures should allow a State to proactively identify the safety impact of change in the aviation system before they are implemented, and plan and execute proposed changes in a structured way. 8.5.6.3 When changes are planned, the State should analyse the impact of the change on the existing system and, using the existing SRM process, analyse, assess and if appropriate mitigate any new or altered safety risks. No operation should take place in a changed system or operational context until all safety risks are evaluated. 8.5.6.4 A State will face two types of change under its SSP: organizational change (for example, reallocation of responsibilities or restructuring within State aviation authorities) and operational change (for example, a change in airspace usage). The management of change under SSP should focus on those changes that could have a significant impact on the State’s ability to fulfil its legal obligations (process change) and on the State safety management capabilities. This might include a combination of process and operational changes. 8.5.6.5 Examples of changes with potential for significant impact to the safety risks of the State include, but are not limited to: a) reorganization of State aviation authorities (including downsizing); b) changes in the SSP processes, including changes in methodology such as SRBS, SRM and safety assurance processes. Chapter 8. State Safety Management 8-27 c) changes in the regulatory environment, such as changes in existing State safety policies, programmes, and regulations; d) changes in the operational environment, such as introduction of new technologies, changes in infrastructure, equipment and services; e) rapidly changing industry (expanding, contracting, morphing) and its potential impact on the State oversight and performance monitoring capabilities. 8.5.6.6 Communicating the changes is fundamental to the effectiveness of the management of change. It is essential that effected personnel within the State and affected service provider(s) are well aware of the change, its timing and impacts. 8.6 COMPONENT 4: STATE SAFETY PROMOTION 8.6.1 From a State perspective, the need to implement internal and external State safety promotion action is established in Annex 19 as one of the components in States’ safety management responsibilities. Internally, CAAs and other aviation authorities involved with the SSP should establish mechanisms to provide relevant safety information to its personnel to support the development of a culture that fosters an effective and efficient SSP. The communication of its safety policies, safety plans, as well as other important SSP documentation can also improve awareness and collaboration among their staff, so that safety management processes put in place by States remain effective. 8.6.2 The improvement of safety performance within a State or a specific aviation sector is highly dependent on its safety culture. Actions related to the management of safety tend to be more effective when the organization has a positive safety culture. When visibly supported by upper- and middle management, frontline employees tend to feel a sense of shared responsibilities towards achieving their safety objectives. 8.6.3 Among other actions for the improvement of safety culture within an aviation system, the need for communication stands out for its importance. By constantly communicating its priorities, best practices, risks that standout in a particular operation, a State can foster a positive safety culture and maximise the potential of achieving its safety objectives, be it among the professionals of CAAs or service providers. Further details on safety culture can be found in Chapter 3. 8.6.4 Once employees embrace and understand their responsibilities towards safety performance, it is expected they will actively seek means and information that can be used for effectively accomplishing their responsibilities towards a safe aviation. This is an opportunity for safety promotion to play a key role in safety management. Externally, the establishment of communication channels with service providers should enable the sharing of lessons learned, best practices, SPIs and the provision of information on specific safety risks. This should support the implementation of safety management practices within service providers, supporting the development of a positive safety culture among peer organizations. Also, the establishment of routine communication efforts with service providers may increase general awareness on aviation safety issues and encourage further collaboration in identifying safety enhancement initiatives. 8.6.5 As States make decisions or take actions to improve aviation safety (e.g., establishing regulations or implementing changes to surveillance methods) it is also important they communicate internally as well as externally. This can strengthen the perception of the State commitment throughout the aviation community. This in turn may contribute to achievement of the State safety objectives. 8.6.6 Many resources and tools are available to support States in establishing their safety promotion actions. One way of structuring the many promotion actions a State can adopt is establishing a communications plan. Such plan could include, at a minimum, the mapping of interested members of the aviation community, the messages and information conveyed to each of its groups and the means this information will be transmitted. The communication plan may also act as a roadmap supporting the CAA to effectively develop the capability and 8-28 Safety Management Manual (SMM) channels to communicate with these internal and external audiences. This can be instrumental to States building a safety culture as well as in providing the necessary data and tools required by successful safety management, both from States’ perspective as well as service providers’. 8.6.7 Some information can be communicated through less formal bulletins and posts using social media, while others are better addressed in dedicated meetings or seminars. It is the role of the State to implement the adequate safety promotion channels and media they believe will achieve best results in developing a positive safety culture within the State and ultimately achieve an effective SSP and a safer civil aviation system within the State. 8.6.8 Internal communication and dissemination of information Note. — Safety information from voluntary safety reporting systems shall be protected, unless a principle of protection applies. This can be extended to safety information from a mandatory reporting system. Please see Chapter 7 for more details on the protection of safety data, safety information and related sources. 8.6.8.1 Safety promotion actions and publications can also improve coordination and collaboration among different organizations involved with safety oversight within a State. The SSP document and its associated State safety and enforcement policies are fundamental to achieving the integration of training, communication and the dissemination of related information. State regulatory authorities responsible for the different aviation sectors as well as other independent administrative entities such as the AIA should have an integrated approach to their respective roles in State safety promotion. States should establish formal communication channels between the members of the SSP Coordination Group (State entities involved in implementing and maintaining the SSP). 8.6.8.2 From an operational perspective, it is important that SSP operational strategies, including harmonized SMS requirements and monitoring of the respective service providers are shared, communicated and coordinated amongst the State aviation authorities. An open communication channel may avoid the creation of conflicting SMS requirements or acceptance criteria for different aviation sectors. 8.6.8.3 Examples of information States should address in their internal communication and dissemination include: a) SSP documentation, policies, and procedures; b) SPIs; c) sector safety performance information; d) sector organizational safety risks profiles; e) communication of system safety responsibility; f) lessons learned from accidents and incidents; and g) concepts and best practices of safety management. 8.6.8.4 There is a particular need for open lines of safety communication when service providers are approved by more than one State. 8.6.8.5 There are several means State organizations may adopt to convey safety communication internally, such as newsletters, bulletins, leaflets, publications, seminars, meetings, training, websites, mailing lists, publications on social media, discussions in collaboration groups, among others. 8.6.8.6 When assessing which type of media should be used to convey a particular message, the organization should assess which one is more appropriate to each message and its targeted audience. SSP Chapter 8. State Safety Management 8-29 documents may be posted on a website that is readily available to personnel when they are needed. Other information such as lessons-learned and best practices may be more suitable for a periodic bulletin or newsletter. 8.6.8.7 Establishing campaigns to address a particular concern or hazard using multiple media may be effective in increasing awareness to the issue and changing personnel attitude. 8.6.9 External communication and dissemination of safety information 8.6.9.1 The State should establish appropriate communication platforms or media to facilitate SMS implementation and improve system-wide safety culture. 8.6.9.2 When communicating and disseminating safety information externally with the aviation industry, in addition to the items presented in the previous section, States should also consider including: a) guidance material for the implementation of SMS; b) importance of reporting; c) identification of available safety training for the aviation community; d) promote the exchange of safety information: i) with and amongst service providers; and ii) between States. 8.6.9.3 The State’s SSP documentation and its related safety and enforcement policies should also be made available to service providers as appropriate. 8.6.9.4 Essentially, the same support media used for internal communications can be used externally as long as the content is useful for both audiences. For external communication, however, special attention may be given to solutions that reach larger audiences such as social media, mailing list bulletins, seminars, creating industry communities for the exchange of safety information, thus multiplying the messages’ outreach. 8.6.9.5 States should promote the establishment of safety information sharing or exchange networks among the aviation community, unless national law provides otherwise. 8.7 SSP IMPLEMENTATION As with any major project implementation exercise, SSP implementation involves many tasks and subtasks to be completed within a set timeframe. The number of tasks, as well as the scope of each task, is dependent upon the maturity of the State’s safety oversight system. In most States, several organizations and entities are involved in the development and implementation of an SSP. Development of an implementation plan can help to facilitate this process. This chapter lays out the steps from developing a comprehensive system description, considerations related to scalability, performing a gap analysis and developing an implementation plan that includes ensuring that a solid SSP foundation is established. This section also addresses the ongoing assessment of the maturity of an SSP. 8-30 Safety Management Manual (SMM) 8.7.1 State’s civil aviation system description and scalability considerations 8.7.1.1 The understanding of the size and complexity of a State’s aviation system and the interactions between the elements is fundamental to planning the SSP. State are required to implement an SSP, but how the requirements are met will depend on the size and complexity of the aviation system. More information about scalability can be found in Chapter 1. 8.7.1.2 The SSP will also have regards for the number of service providers in each aviation domain, their size and complexity and regional environment. States with a small number of service providers should consider establishing regional partnerships. Regional partnerships with other States or through RSOOs, and sharing lessons learned and safety risk information will minimise the impact while maximising the benefits of SSP implementation. 8.7.1.3 The State should describe the aviation system and the various State aviation authorities in a civil aviation system description. This should include an overview of organizational structures and interfaces. This is part of the SSP implementation planning process. Such a review should include a description of the following: a) the structure of the existing aviation regulatory framework, including the various State aviation authorities; b) safety management roles and accountabilities of the various regulatory authorities; c) platform or mechanism for coordination of the SSP amongst the organizations; and d) an internal review mechanism at the State level and within each organization. 8.7.2 SSP gap analysis and implementation plan SSP gap analysis 8.7.2.1 A gap analysis should be conducted before developing an SSP implementation plan. The gap analysis aims to gain a detailed understanding of the gap between the existing State structures and processes, and those required for an effective SSP implementation in the State. For many States, the gap analysis reveals that considerable safety management capability already exists. The challenge, typically, is to refine, realign and bolster these existing capabilities. The elements or processes identified as requiring action form the basis of the SSP implementation plan. SSP foundation 8.7.2.2 It is essential that States establish a mature foundation to support effective SSP implementation. The GASP objectives call for States to progressively implement effective safety oversight systems, SSPs and advanced safety management capabilities necessary to support future aviation systems. This foundation is comprised of the aspects of a safety oversight system that are needed to support a more performance-based approach. 8.7.2.3 Data collected through the ICAO Universal Safety Oversight Audit Programme (USOAP) can be used to identify deficiencies in this foundation. Addressing any unsatisfactory USOAP protocol questions related to issues that are linked to effective SSP implementation (e.g. mandatory reporting systems), should be the first step in implementing SSP. Chapter 8. State Safety Management 8-31 SSP implementation plan 8.7.2.4 The SSP implementation aims to progressively enhance the existing SSO and safety management processes. The appropriate tasks/subtasks are prioritized and documented in an action plan. An SSP implementation plan, together with the SSP top-level (exposition) document, provide the “blueprints” which guides the State’s journey toward effective SSP, and continuous improvement of safety performance. These two key documents should be made readily accessible to all relevant personnel to ensure everyone involved is aware of the SSP and its plans for implementation. 8.7.3 SSP maturity assessment Background and purpose 8.7.3.1 The assessment of the SSP’s maturity should be conducted using a tool that reflects ICAO SARPs and guidance material, developed by the State to meet its needs. The tool should be used by States to perform internal audits for the continuous improvement of the SSP. They should also be referred to by ICAO and other external entities as appropriate. The tool should be based on a series of questions (or expectations) that can be used by the State to assess the effectiveness of its SSP. The SSP maturity assessment will benefit from interactions, such as face-to-face discussions and interviews, with a cross-section with all interested parties. The tool should be flexible and account for the size and complexity of the State’s aviation system. Assessment 8.7.3.2 Once the basic aspects of the SSP are installed, an assessment of the documentation can be conducted. The assessment aims to discover whether or not the compliance and performance expectations of the SSP are present and suitable. Evidence should be collected to support the assessment. At a later stage, the SSP can be assessed to understand how well it is operating and how effective it is at achieving its objectives. Effectiveness is achieved when the outcome produces the desired result each time. A team with appropriate SSP competence and technical expertise normally conducts the assessment and collects the evidence. It is important to structure the assessment in a way that allows interaction with a number of people at different levels of the organization to determine effectiveness throughout the organization. For example, determining the extent that the safety policy has been promulgated and understood by staff will require interaction with a cross-section of personnel. Ongoing Monitoring and Continuous Improvement 8.7.3.3 The State may utilize the same tool to assess the effectiveness of its SSP during ongoing monitoring and continuous improvement. The assessment will likely identify changes to the aviation system. For most States, SSP will take time to implement and several years to mature to a level where all the elements are working effectively. Figure 23 illustrates the different levels of SSP maturity as a State implements and develops its SSP. Figure 23. SSP maturity journey 8-32 Safety Management Manual (SMM) 8.7.3.4 An SSP assessment can be carried out at various stages, looking initially for the presence and suitability of key elements. At a later stage, the SSP can be assessed to understand how well it is operating and how effective it is at achieving its objectives. States can continue to perform assessments periodically to support the continuous improvement towards excellence. ______________________ 9-1 Chapter 9 SAFETY MANAGEMENT SYSTEMS (SMS) 9.1 INTRODUCTION 9.1.1 This chapter provides guidance for service providers on the implementation of an SMS framework in accordance with Annex 19 and guidance for States on the oversight of SMS. 9.1.2 The purpose of an SMS is to provide service providers with a systematic approach to managing safety. It is designed to continuously improve safety performance through: the identification of hazards; the collection and analysis of safety data and safety information; and the continuous assessment of safety risks. The SMS seeks to proactively mitigate safety risks before they result in aviation accidents and incidents. It allows service providers to effectively manage their activities, safety performance and resources, while gaining a greater understanding of their contribution to aviation safety. An effective SMS demonstrates to States the service provider’s ability to manage safety risks and provides for effective management of safety at the State level. 9.1.3 International general aviation operators should determine the SMS criteria for the aircraft they are operating, as established by the State of Registry, and ensure their SMS is acceptable to the State of Registry. To facilitate the acceptability of the SMS, international general aviation operators should ask the State of Registry if the use of an industry code of practice is permitted. 9.1.4 Operators of large or turbojet aeroplanes under multiple States of Registry with an AOC issued in accordance with Annex 6, Part I, are considered to be service providers, therefore, the SMS needs to be made acceptable to the State of the Operator. 9.2 SMS FRAMEWORK 9.2.1 Annex 19 specifies the framework for the implementation and maintenance of an SMS. Regardless of the service provider’s size and complexity, all elements of the SMS framework apply. The implementation should be tailored to the organization and its activities. 9.2.2 The ICAO SMS framework is made up of the following four components and twelve elements: COMPONENT ELEMENT 1. Safety policy and objectives 1.1 Management commitment 1.2 Safety accountability and responsibilities 1.3 Appointment of key safety personnel 1.4 Coordination of emergency response planning 1.5 SMS documentation 2. Safety risk management 2.1 Hazard identification 2.2 Safety risk assessment and mitigation 3. Safety assurance 3.1 Safety performance monitoring and measurement 3.2 The management of change 3.3 Continuous improvement of the SMS 4. Safety promotion 4.1 Training and education 4.2 Safety communication 9-2 Safety Management Manual (SMM) 9.3 COMPONENT 1: SAFETY POLICY AND OBJECTIVES 9.3.1 The first component of the SMS framework focuses on creating an environment where safety management can be effective. It is founded on a safety policy and objectives that set out senior management’s commitment to safety, its goals and the supporting organizational structure. 9.3.2 Management commitment and safety leadership is key to the implementation of an effective SMS and is asserted through the safety policy and the establishment of safety objectives. Management commitment to safety is demonstrated through management decision-making and allocation of resources; these decisions and actions should always be consistent with the safety policy and objectives to cultivate a positive safety culture. 9.3.3 The safety policy should be developed and endorsed by senior management, and is to be signed by the accountable executive. Key safety personnel, and where appropriate, staff representative bodies (employee forums, trade unions) should be consulted in the development of the safety policy and safety objectives to promote a sense of shared responsibility. 9.3.4 Management commitment Safety Policy 9.3.4.1 The safety policy should be visibly endorsed by senior management and the accountable executive. “Visible endorsement” refers to making management’s active support of the safety policy visible to the rest of the organization. This can be done via any means of communication and through the alignment of activities to the safety policy. 9.3.4.2 It is the responsibility of management to communicate the safety policy throughout the organization to ensure all personnel understand and work in accordance with the safety policy. 9.3.4.3 To reflect the organization’s commitment on safety, the safety policy should include a commitment to: a) continuously improve the level of safety performance; b) promote and maintain a positive safety culture within the organization; c) comply with all applicable regulatory requirements; d) provide the necessary resources to deliver a safe product or service; e) ensure safety is a primary responsibility of all managers; and f) ensure it is understood, implemented and maintained at all levels. 9.3.4.4 The safety policy should also make reference to the safety reporting system to encourage the reporting of safety issues and inform personnel of the disciplinary policy applied in the case of safety events or safety issues that are reported. 9.3.4.5 The disciplinary policy is used to determine whether an error or rule breaking has occurred so that the organization can establish whether any disciplinary action should be taken. To ensure the fair treatment of persons involved, it is essential that those responsible for making that determination have the necessary technical expertise so that the context of the event may be fully considered. Chapter 9. Safety Management Systems (SMS) 9-3 9.3.4.6 A policy on the protection of safety data and safety information, as well as reporters, can have a positive effect on the reporting culture. The service provider and the State should allow for the de-identification and aggregation of reports to allow meaningful safety analyses to be conducted without having to implicate personnel or specific service providers. Because major occurrences may invoke processes and procedures outside of the service provider’s SMS, the relevant State authority may not permit the early de-identification of reports in all circumstances. Nonetheless, a policy allowing for the appropriate de-identification of reports can improve the quality of data collected. Safety objectives 9.3.4.7 Taking into consideration its safety policy, the service provider should also establish safety objectives to define what it aims to achieve in respect of safety outcomes. Safety objectives should be short, high-level statements of the organization’s safety priorities and should address its most significant safety risks. Safety objectives may be included in the safety policy (or documented separately), and requires the establishment of safety objectives defining what the organization intends to achieve in terms of safety management. Safety performance indicators (SPIs) and safety performance targets (SPTs) are needed to monitor the achievement of these safety objectives and are further elaborated on later in this Chapter under Component 3. 9.3.4.8 The safety policy and safety objectives should be periodically reviewed to ensure they remain current (a change in the accountable executive would require its review for instance). 9.3.5 Safety accountability and responsibilities Accountable Executive 9.3.5.1 The accountable executive is the person who has ultimate authority over the safe operation of the organization, typically known as the chief executive officer, the accountable executive establishes and promotes the safety policy and safety objectives that instil safety as a core organizational value. They should: have the authority to make decisions on behalf of the organization; have control of resources, both financial and human; and be responsible for ensuring appropriate actions are taken to address safety issues and safety risks, and responding to accidents and incidents. 9.3.5.2 There might be challenges for the service provider to identify the most appropriate person to be the accountable executive, especially in large complex organizations with multiple entities and approvals. It is important the person selected is organizationally situated at the highest level of the organization, thus ensuring the right strategic safety decisions are made. 9.3.5.3 The service provider is required to identify the accountable executive, placing the responsibility for the overall safety performance at a level in the organization with the authority to take action to ensure the SMS is effective. Specific safety accountabilities of all members of management should be defined and their role in relation to the SMS should reflect how they can contribute towards a positive safety culture. The safety responsibilities, accountabilities and authorities should be documented and communicated throughout the organization. The safety accountabilities of managers should include the allocation of the human, technical, financial or other resources necessary for the effective and efficient performance of the SMS. Note.— The term “accountability” refers to obligations which cannot be delegated. The term “responsibilities” refers to functions and activities which may be delegated. 9.3.5.4 In the case where an SMS applies to several different approvals, that are all part of the same legal entity, there should be a single accountable executive. Where this is not possible, individual accountable executives should be identified for each organization approval and clear lines of accountability defined; it is also important to identify how their safety accountabilities will be coordinated. Next >