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AC 005-01 Safety Management Systems (SMS)

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GACA®
الهييه العامه للطيران المدني
General Authority of Civil Aviation
ADVISORY CIRCULAR
<table><tr><td>SUBJECT:</td><td>DATE:</td><td>AC NUMBER:</td><td>VERSION:</td></tr><tr><td>SAFETY MANAGEMENT SYSTEMS</td><td>2021-04-20</td><td>005-01</td><td>6.0</td></tr></table>
NOTE: THIS ADVISORY CIRCULAR IS PUBLISHED TO PROVIDE REGULATORY INFORMATION AND DESCRIBE ACCEPTABLE MEANS OF COMPLIANCE WITH THE GENERAL AUTHORITY OF CIVIL AVIATION REGULATIONS (GACAR).
CHAPTER 1 – BACKGROUND
1.1 Purpose.
The purpose of this Advisory Circular is to describe the framework of an acceptable Safety Management System (SMS) as well as acceptable means of compliance with the safety management system requirements of GACAR Part 5. Additionally, this Advisory Circular describes the processes for SMS implementation by aviation organizations (i.e., aviation service providers) and for the formal acceptance of the SMS by the General Authority of Civil Aviation (GACA). Lastly, this Advisory Circular describes an acceptable means of compliance with the phased implementation requirement for safety management systems as prescribed in GACAR Part 199.
1.2 Applicability.
This Advisory Circular is applicable to all aviation organizations required to have an SMS under the General Authority of Civil Aviation Regulations (GACAR) Part 5.
1.3 Cancellation.
This is the first official version of this Advisory Circular and it cancels no other Advisory Circulars.
1.4 Related Regulatory Provisions.
GACAR Parts 1, 5, 119, 121, 125, 135, 139, 141, 142, 145, 170, 171, 172, 173, 175, and 199.
1.5 Related Reading Material.
None.
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1.6 Definitions of Terms Used in this Advisory Circular.
Affected parties should refer to Subpart A of GACAR Part 1 for a full listing of defined terms used in the new GACAR and specifically those related to safety management. This Advisory Circular introduces several additional definitions to aid in a common understanding of the ideas presented in this document. In cases where the definitions in this document differ from an identical term defined in GACAR Part 1, the definition in GACAR Part 1 will prevail when interpreting regulatory requirements.
1.7 Approval.
This Advisory Circular has been approved for publication by the Assistant President, Safety, Security and Air Transport (SS&AT) Sector of the General Authority of Civil Aviation.
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CHAPTER 2 – THE SMS FRAMEWORK
2.1 Introduction.
The SMS framework is composed of components, elements, and processes, each of which is explained in terms of its functional expectations, or how they would need to be used in order to contribute to an effective SMS. These functional expectations are further defined in terms of performance objectives (what the process needs to do) and design expectations (what needs to be developed in order for the process to function as intended).
The SMS framework addresses two important needs:
a) To provide one standard set of concepts, documents, and tools for the development and implementation of SMS that complies with General Authority of Civil Aviation Regulation (GACAR) Part 5.
b) To make the SMS documents and tools align with the structure and format of the International Civil Aviation Organization (ICAO) SMS Framework.
The Framework describes the objectives and expectations for an aviation organization's SMS. The Framework is intended to address only operational and support processes and activities that are related to aviation safety and not to address those related to occupational safety, environmental protection, or customer service quality, all of which are outside of the scope of the GACAR.
Aviation organizations are responsible for the safety of services or products they purchase or contract from other organizations. This document describes the minimum objectives and expectations for an effective and compliant SMS; aviation organizations may establish additional or stricter requirements.
2.2 Scope.
This Framework provides guidance for SMS development by aviation organizations (e.g., air operators, repair stations, flight training organizations, air traffic service providers, and aerodrome operators) and forms the basis for SMS assessments which are described later in this document.
2.3 Applicability.
The President views the objectives and expectations in the Framework as a minimum for an aviation organization to develop and implement in order to comply with the SMS requirements as specified in GACAR Part 5.
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الهييه العامه للطيران المدني
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2.4 References.
The Framework is in accordance with the following documents:
• ICAO Annex 19, Safety Management
- International Civil Aviation Organization (ICAO) Document 9859, 3rd Edition (as amended), ICAO Safety Management Manual (SMM)
• ICAO Document 9734, Safety Oversight Manual
2.5 Definitions.
a. Accident. An unplanned event or series of events that results in death, injury, occupational illness, damage to or loss of equipment or property, or damage to the environment.
b. Accountable Executive. The single, identifiable person having authority and final responsibility for the effective and efficient performance of the organization’s SMS. Depending on the size and complexity of the organization, the Accountable Executive may be the chief executive officer (CEO), the chairperson of the board of directors, a partner, or the proprietor. The authorities and responsibilities carried out by the Accountable Executive include, but are not limited to:
a. full authority for human resources issues;
b. authority for major financial issues;
c. direct responsibility for the conduct of the organization's affairs;
d. final authority over operations under certificate; and
e. final responsibility for all safety issues.
c. Analysis. The process of identifying a question or issue to be addressed, modeling the issue, investigating model results, interpreting the results, and possibly making a recommendation. Analysis typically involves using scientific or mathematical methods for evaluation.
d. Assessment. The process of measuring or judging the value or level of something.
e. Attributes. System Attributes, or the inherent characteristics of a system, are present in any well-defined organization and apply to an effective SMS. The six system safety attributes for the
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purpose of this document are: Procedures; Controls; Process Measures; Interfaces; Responsibility; and Authority. Each safety attribute is defined in this section.
f. Audit. Scheduled, formal reviews and verifications that evaluate whether an organization has complied with policy, standards, and/or contract requirements. An audit starts with the management and operations of the organization and then moves to the organization's activities and products/services.
g. Authority. Who can direct, control, or change the process, as well as who can make key decisions such as risk acceptance. This attribute also includes the concept of empowerment.
h. Aviation System. The functional operation or production system used by an organization to produce an aviation product or service (see System and Functional below).
i. Complete. Nothing has been omitted and what is stated is essential and appropriate to the level of detail.
j. Conformity. Fulfilling or complying with a requirement [ref. ISO 9001-2000]; this includes but is not limited to complying with aviation safety regulations. It also includes complying with company requirements, requirements of operator-developed risk controls, or operator policies and procedures.
k. Continuous Monitoring. Uninterrupted (constant) watchfulness (checks, audits, etc.) over a system.
I. Controls. Controls are elements of the system, including hardware, software, special procedures or procedural steps, and supervisory practices designed to keep processes on track to achieve their intended results. Organizational process controls are typically defined in terms of special procedures, supervisory and management practices, and processes. Many controls are inherent features of the SMS Framework. Practices such as continuous monitoring, internal audits, internal evaluations, and management reviews (all parts of the safety assurance component) are identified as controls within the design expectations. Additionally, other practices such as documentation, process reviews, and data tracking are identified as controls within specific elements and processes.
m. Corrective Action. Action to eliminate (remove) or mitigate (lessen) the cause or reduce the effects of a detected nonconformity or other undesirable (unwanted) situation.
n. Correct. Accurate without ambiguity or error in its attributes.
o. Credible. Implies that it is reasonable to expect the assumed combination of extreme conditions will occur within the operational lifetime of the system.
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p. Documentation. Information or meaningful data and its supporting medium (e.g., paper, electronic, etc.). In this context, documentation is different from records because documentation is the written description of policies, processes, procedures, objectives, requirements, authorities, responsibilities, or work instructions; whereas Records are the evidence of results achieved or activities performed.
q. Evaluation. An independent review of company policies, procedures, and systems. If accomplished by the company itself, the evaluation should be done by a person or organization in the company other than the one performing the function being evaluated. The evaluation process builds on the concepts of auditing and inspection. An evaluation is an anticipatory process designed to identify and correct potential problems before they happen. An evaluation is synonymous with the term “systems audit.”
r. External Audit. An audit conducted by an entity outside of the organization being audited (e.g., the flight operations division audits the flight training department).
s. Functional. The term “function” refers to “what” is expected to be incorporated into each process (e.g., human tasks, software, hardware, procedures, etc.) rather than “how” the function is accomplished by the system. This makes for a more performance-based system and allows for a broad range of techniques to be used to accomplish the performance objectives. This, in turn, maximizes scalability while preserving standardization of results across the aviation organization communities.
t. Hazard. Any existing or potential condition or object that can lead to an accident, incident; or damage to the environment. A hazard is a condition that might cause (is a prerequisite to) an accident or incident.
u. Incident. It is a near-miss episode with minor consequences that could have resulted in greater loss, or an unplanned event that could have resulted in an accident or did result in minor damage. An incident indicates that a hazard or hazardous condition exists, though it may not identify what that hazard or hazardous condition is.
v. Interfaces. This aspect includes examining such things as lines of authority between departments, lines of communication between employees, consistency of procedures, and clearly delineating lines of responsibility between organizations, work units, and employees. Interfaces are the “Inputs” and “Outputs” of a process.
w. Interfaces in Safety Risk Management and Safety Assurance. Safety Risk Management (SRM) and Safety Assurance (SA) are the key processes of the SMS. They are also highly interactive, especially in the input-output relationships between the activities in the processes. This is especially important where interfaces between processes involve interactions between different
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departments, contractors, etc. Assessments of these relationships should pay special attention to flow of authority, responsibility, and communication, as well as procedures and documentation.
x. Internal Audit. An audit conducted by, or on behalf of, the organization being audited (e.g., the flight training department audits the flight training department).
y. Lessons Learned. Knowledge or understanding gained by experience, which may be positive, such as a successful test or mission, or negative, such as a mishap or failure. Lessons learned should be developed from information obtained from inside and outside of the organization and/or industry.
z. Likelihood. The estimated probability or frequency, in quantitative or qualitative terms, of an occurrence related to the hazard.
aa. Line Management. The management structure that operates (controls, supervises, etc.) the operational activities and processes of the aviation system.
bb. Nonconformity. Non-fulfillment of a requirement [ref. ISO 9001-2000]. This could include but is not limited to, noncompliance with regulations, company requirements, requirements of operator-developed risk controls, or operator-specified policies and procedures.
cc. Objective. The desired state or performance target of a process. Usually it is the final state of a process and contains the results and outputs used to obtain the desired state or performance target.
dd. Operational Life Cycle. Period of time from implementation of a product/service until it is no longer in use.
ee. Organization. Indicates both certificated and non-certificated aviation organizations who are engaged in providing aviation services.
ff. Outputs. The product or end result of a SMS process that can be recorded, monitored, measured, and analyzed. Outputs are the minimum expectation for the product of each process area and the input for the next process area in succession. Each of the outputs of a process should have a method of measurement specified by the organization. Measures need not be quantitative where this is not practical; however, some method of providing objective evidence of the attainment of the expected output is necessary.
gg. Oversight. A function performed by a regulator (such as the GACA Safety and Air Transport Sector) that ensures that an aviation organization conforms with and uses safety-related standards, requirements, regulations, and associated procedures. A form of oversight can also result from a requirement to meet standards of a non-regulatory organization, e.g., the International Air Transport
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Association (IATA).
hh. Preventive Action. Preemptive action to eliminate or mitigate the potential cause or reduce the future effects of an identified or anticipated nonconformity or other undesirable situation.
ii. Procedures. ISO-9001-2000 defines “procedure” as “a specified way to carry out an activity or a process.” Procedures translate the “what” in goals and objectives into “how” in practical activities (things people do). Procedures are simply documented activities to accomplish processes (e.g., a way to perform a process). The organization should specify their own procedures for accomplishing processes in the context of their unique operational environment, organizational structure, and management objectives.
jj. Process. A set of interrelated or interacting activities that transform inputs into outputs.
kk. Process Measures. Ways to provide feedback to responsible parties that required actions are taking place, required outputs are being produced, and expected outcomes are being achieved. A basic principle of safety assurance is that fundamental processes be measured so that management decisions can be data-driven. The general expectations for Component 1, Policy, specify that SMS outputs be measured and analyzed. These measurements and analyses are accomplished in Component 3, Safety Assurance. Outputs of each process should, therefore, be identified during Component 3 activities. For example, these outputs should be the subjects of continuous monitoring, internal audits, and internal evaluation.
II. Product/Service. Anything that is offered or can be purchased that might satisfy a want or need in the air transportation system.
mm. Records. Evidence of results achieved or activities performed.
nn. Residual Safety Risk. The safety risk that exists after all controls have been implemented or exhausted and verified. Only verified/substantiated controls can be used for assessing residual safety risk.
oo. Responsibility. Who is accountable for management and overall quality of the process (planning, organizing, directing, controlling) and its ultimate accomplishment.
pp. Risk. The product of predicted severity (how bad) and likelihood (how probable) of the potential safety effect of a hazard in its worst credible (reasonable or believable) system state. The terms “risk” and “safety risk” are interchangeable.
qq. Risk Control. Steps taken to eliminate (remove) hazards or to mitigate (lessen) their effects by
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reducing the severity and/or likelihood of risk associated with those hazards.
rr. Safety Assurance (SA). A formal management process within the SMS that systematically provides confidence that an organization’s products/services meet or exceed safety requirements. A Safety Assurance flow diagram (found in section 5.4) includes the Framework element/process numbers and other notes to help the reader visualize the Framework in terms of a process flow (with interfaces), and understand the component/element/process expectations.
ss. Safety Culture. The product of individual and group values, attitudes, competencies, and patterns of behavior that determine the commitment to, and the style and proficiency of, the organization’s management of safety. Organizations with a positive safety culture are characterized by communications founded on mutual trust, by shared perceptions of the importance of safety, and by confidence in the efficacy of preventive measures.
tt. Safety Management System (SMS). The formal, management driven business-like approach to managing safety risk. It includes systematic procedures, practices, and policies for the management of safety (as described in this document it includes safety risk management, safety policy, safety assurance, and safety promotion).
uu. Safety Planning. Part of safety management focused on setting safety objectives and specifying needed operational processes and related resources to fulfill these objectives.
vv. Safety Promotion. A combination of safety culture, training, communications and data-sharing activities that support the implementation and operation of an SMS in an organization.
ww. Safety Risk. The product of predicted severity (how bad) and likelihood (how probable) of the potential safety effect of a hazard in its worst credible (reasonable or believable) system state. The terms “safety risk” and “risk” are interchangeable.
xx. Safety Risk Control. A characteristic of a system that reduces or mitigates (lessens) the potential undesirable effects of a hazard. Controls may include process design, equipment modification, work procedures, training, or protective devices. Safety risk controls must be written in requirements language, measurable, and monitored to ensure effectiveness.
yy. Safety Risk Management (SRM). A formal process within the SMS that describes the system, identifies the hazards, analyses the risk, assesses the risk, and controls the risk. The SRM process is embedded in the processes used to provide the product/service; it is not a separate/distinct process.
zz. Separate Aviation Maintenance Organizations. Independent maintenance organizations such as, but not limited to, certificated repair stations, non-certificated repair facilities, and separate
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maintenance organizations. This does not include an air operator's integral maintenance organization.
aaa. Severity. The degree of loss or harm resulting from a hazard.
bbb. Substitute Risk. A risk unintentionally created as a consequence of safety risk control(s).
ccc. 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.
ddd. System Attributes. Refer to definition for Attributes, above.
eee. Top Management. The person or group of people who direct and control an organization. In many large organizations, this can be the board of directors; in smaller organizations, this might be the owner of the company. The accountable executive generally heads the top management.
fff. Worst. The most unfavorable conditions expected.
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CHAPTER 3 - SMS FRAMEWORK STRUCTURE AND EXPECTATIONS
3.1 SMS Framework Structure.
The SMS Framework is broken down into components, elements, and processes. The components and elements are based on the ICAO SMS Framework.
3.2 Components.
There are four components of an SMS. Two components represent the core operational activities underlying an SMS, and two components represent the organizational arrangements that are necessary to support the two core operational activities. The four components of an SMS are:
(1) Safety Policy and Objectives (Component 1.0)
(2) Safety Risk Management (SRM) (Component 2.0)
(3) Safety Assurance (SA) (Component 3.0)
(4) Safety Promotion (Component 4.0)
The two core operational activities of an SMS are Safety Risk Management and Safety Assurance. Further detailed guidance on the processes and tools that are commonly associated with Safety Risk Management activities are located in Appendix D of this Advisory Circular.
3.3 Elements.
Each of the four components of an SMS is further subdivided into elements, each of which defines important aspects of the component. There are twelve elements in the SMS framework arranged as follows:
For Component 1.0 - Safety Policy and Objectives
(a) Element 1.1 - Safety policy
(b) Element 1.2 - Management commitment and safety accountabilities
(c) Element 1.3 - Key safety personnel
(d) Element 1.4 - Emergency preparedness and response
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(e) Element 1.5 - SMS documentation and records
For Component 2.0 - Safety Risk Management (SRM)
(a) Element 2.1 - Hazard identification and analysis
(b) Element 2.2 - Risk assessment and control
For Component 3.0 - Safety Assurance (SA)
(c) Element 3.1 - Safety performance monitoring and measurement
(d) Element 3.2 - The management of change
(e) Element 3.3 - Continuous improvement
For Component 4.0 - Safety Promotion
(f) Element 4.1 - Competencies and training.
(g) Element 4.2 - Communication and awareness.
3.4 Processes.
Certain elements in the Safety Risk Management, Safety Assurance and Safety Promotion components are further broken down into processes.
3.5 SMS Framework Expectations.
To make the SMS Framework easier to understand and use, components, elements, and processes have been defined in terms of functional expectations, or how an organization would need to use them in order for them to contribute to an effective SMS. They are called “functional” expectations because they describe the “what”, not the “how” of each process. For example, the “what” of a de-icing process is to prevent any aircraft from taking off with ice adhering to any critical control surface. The “how” of the de-icing process would include de-icing equipment procedures, flight crew de-icing procedures, holdover table activities, etc., and may be different between individual organizations. Organizations are expected to meet SMS Framework expectations by developing processes to fit their unique business and management models.
The SMS functional expectations are further defined in terms of performance objectives and design
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expectations:
(1) Performance Objectives. Performance Objectives are the desired outcomes of the particular element or process.
(2) Design Expectations. Design Expectations are the characteristics of the element or process that, if properly implemented, should provide the outcomes identified in the performance objectives.
The Performance Objectives and Design Expectations for the entire SMS Framework is found in Appendix A of this Advisory Circular.
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CHAPTER 4 - SMS IMPLEMENTATION
4.1 Purpose.
This chapter contains guidance, expectations, and procedures necessary to implement a SMS by aviation organizations that are eligible for a phased implementation of a SMS, as provided for by the GACAR Part 199.
4.2 Applicability.
The implementation guidance is designed for use in designing and managing an existing aviation organization's SMS phased implementation activities. Phased implementation guidance is not designed to be used by new applicants wishing to commence operations under GACAR Parts 121, 125, 135, 139, 141, 142, 145 or 171. These aviation organizations are required to have an SMS implemented at the time of their initial certification.
4.3 References.
The following references are recommended reading material for users of this implementation guidance in development and implementation of an SMS:
- International Civil Aviation Organization (ICAO) Document 9859, 3rd Edition, ICAO Safety Management Manual (SMM)
- SMS Framework Description in this document
- SMS Assessment Description in this document
4.4 Guidance and Tools.
The GACA developed SMS Framework guidance is the standard for implementation of SMS by aviation organizations. It is similar in scope and format to International Organization for Standardization (ISO) standards and is modeled after the safety, quality, and environmental management standards developed by a variety of organizations such as ISO, the British Standards Institute, Transport Canada, Standards Australia, and the International Air Transportation Association (IATA). The SMS Framework also incorporates the current requirements of ICAO, and it is closely aligned with the current ICAO SMS Framework.
a) SMS Assessment Guidance. The GACA has developed SMS Assessment Guidance as a tool, included in this document as Appendix C, for aviation organizations and GACA SS&AT staff.
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The SMS Assessment Guidance represents each functional expectation found in the SMS Framework in the form of a question and is intended to be used during the development and implementation of a SMS by an organization or by the GACA SS&AT staff for oversight guidance. Since the SMS Assessment Guidance is based entirely on the SMS Framework, compliance with the SMS Assessment Guidance will ensure compliance with the SMS Framework.
b) SMS Implementation Guidance. The SMS Implementation Guidance contains the expectations and procedures necessary to implement an SMS.
c) Gap Analysis Processes and Tools. An initial step in developing an SMS is for the aviation organization to analyze and assess its existing programs, systems, processes, and activities with respect to the SMS functional expectations found in the SMS Framework. This process is called a “gap analysis”; the “gaps” being those elements in the SMS Framework that are not already being performed by the aviation organization.
NOTE: The gap analysis processes cover all areas of company operations that are subject to regulatory control in accordance with the GACARs and all elements of the SMS Framework.
4.5 Roles, Responsibilities and Relationships.
The SMS Framework provides guidance for an aviation organization to develop and document its SMS. A separate SMS manual is not specifically required; however, many organizations find a separate manual useful. The SMS may be documented in a form and manner that best serves the organization’s need; however, any modifications of existing GACA SS&AT approved/accepted programs and their associated documents must be coordinated with the GACA SS&AT. Safety policies developed by organizations’ top management will be clearly communicated throughout the entire organization. Safety Risk Management (SRM) and Safety Assurance (SA) programs will be developed and maintained. Safety Promotion (SP) activities will take place to instill or reinforce a positive safety culture throughout the organization.
The GACA SS&AT office that normally provides regulatory safety oversight of the aviation organization will be referred to as the “oversight organization” and will continue all of its normal oversight and certificate management duties. As organizations develop their SMS, a natural interaction between the safety management efforts of the oversight organization and those of the aviation organization will develop. This relationship can leverage the efforts of both parties to provide a more effective, efficient, and proactive approach to meeting safety requirements while at the same time increasing the flexibility of the aviation organization to tailor their safety management efforts to their individual business models.
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- The aviation organization should expect the oversight organization to be fully engaged during SMS development and implementation.
- Specifically, the oversight organization will:
• Oversee and review gap analysis processes
- Review and accept the aviation organization’s implementation plan and other documents
- Discuss the requirements of the exit criteria for all implementation phases with the aviation organization. Exit criteria are those SMS development activities that must be completed prior to moving to the next implementation phase
4.6 SMS Implementation Strategy.
a) Phased Implementation. Initial SMS implementation strategy follows a four-phased process similar to that outlined in the ICAO Safety Management Manual (SMM). ICAO, as well as many other States that are in the process of implementing SMS requirements, favors a phased implementation process. The SMS implementation guidance presented in this document closely parallels the ICAO recommended phased implementation process outlined in ICAO Document 9859. The phases of implementation are arranged in four levels of implementation “maturity”. The timeline and milestone requirements for each implementation phase are according to the requirements outlined in the GACAR Part 199. The four phases (and implementation levels) of phased SMS implementation are:
Level 1 (ICAO Phase I) — Planning & Organizing SMS implementation;
Level 2 (ICAO Phase II) — Reactive Processes, Basic Safety Risk Management;
Level 3 (ICAP Phase III) — Proactive Processes, Looking Ahead; and
Level 4 (ICAO Phase IV) — Continuous Improvement, Continued Assurance.
Note: A summary diagram of the different phases of implementation can be found in the ICAO Safety Management Manual, Chapter 10.
b) The development and implementation of an SMS. This task is best accomplished by breaking down the task into smaller, more manageable subcomponents. In this way, overwhelming and sometimes confusing complexity, and its underlying workload, may be turned into simpler and more transparent subsets of activities that only require minor increases in workloads and
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resources. This partial allocation of resources may be more commensurate with the requirements of each activity as well as the resources available to the aviation organization.
c) Justification. The reasons that justify why a phased approach to SMS implementation is recommended can be expressed as: (a) providing a manageable series of steps to follow in implementing an SMS, including allocation of resources; and (b) effectively managing the workload associated with SMS implementation.
d) Cosmetic Compliance. An aviation organization should set as its objective the realistic implementation of a comprehensive and effective SMS, not the tokens of it. You simply cannot “buy” an SMS system or manual and expect the benefits of a fully implemented SMS.
e) Feedback. Implementation experiences have shown that while full SMS implementation will certainly take longer, the robustness of the resulting SMS will be enhanced and early benefits realized as each implementation phase is completed. In this way, simpler safety management processes are established and benefits realized before moving on to processes of greater complexity. This is especially true with regard to Safety Risk Management (SRM). In the reactive phase (Level 2), an aviation organization will build an SRM system around known hazards that are already identified. This allows company resources to be focused on developing risk analysis, assessment and control processes (that frequently resolve old long-term issues and hazards) unencumbered by the complexities necessary at the proactive (Level 3) and predictive phases (Level 4).
f) Summary. Guidance for a phased implementation of SMS aims at:
- Providing a manageable series of steps to follow in implementing an SMS, including allocation of resources,
- Effectively managing the workload associated with SMS implementation
- Pre-empting a “box checking” exercise
- Realization of safety management benefits and return on investment during an SMS implementation project
4.7 Implementation Levels.
The overall objective of the levels is to develop and implement an integrated, comprehensive SMS for the organization.
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Implementation Orientation & Commitment. SMS implementation by the aviation organization begins with a recognition by the aviation organization that the GACAR Part 5 is applicable, and the aviation organization's top management commitment to begin the steps of initiating the SMS development process, including gathering necessary information, evaluating corporate goals and objectives, and committing resources to the SMS implementation effort.
Implementation Level One: Planning and Organization. Level One begins when an aviation organization's top management commits to providing the resources necessary for full implementation of SMS throughout the organization.
i Gap Analysis. The first step in developing an SMS is for the aviation organization to analyze its existing programs, systems, and activities with respect to the SMS functional expectations found in the SMS Framework. This analysis is a process and is called a “gap analysis,” the “gaps” being those components, elements and processes in the SMS Framework that are not already being performed by the aviation organization.
- The Gap Analysis process should consider and encompass the entire organization (e.g., functions, processes, organizational departments, etc.) to be covered by the SMS.
- The gap analysis should be continuously updated as the aviation organization progresses through the SMS implementation process
ii Implementation Plan. Once the gap analysis has been performed, an implementation plan is prepared. The implementation plan is simply a “road map” describing how the aviation organization intends to close the existing gaps by meeting the objectives and expectations in the SMS Framework. The implementation plan must be accepted by the GACA before specific implementation activities incorporated in the plan can be considered finalized.
- While no actual development activities are expected during level one, beyond those listed in the SMS Framework, Elements 1.1, 1.2 (partial), 1.3 and 4.1.1 (partial), the aviation organization organizes resources, assigns responsibilities, sets schedules, and defines objectives necessary to address all gaps identified.
- It should be noted that at each level of implementation, top management's approval of the implementation plan must include allocation of necessary resources IAW Element 1.2.
iii Level 1 – Exit Expectations. The following items are required prior to Level 1 exit:
- Objective evidence of top management’s commitment to implement SMS, define safety
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policy and convey safety expectations and objectives to all employees
- Objective evidence of top management’s commitment to insure adequate resources are available to implement SMS
- Designation of an accountable executive who will be responsible for SMS development
- Definition of safety-related positions for those who will participate in SMS development and implementation
- Completed gap analysis on the entire organization for all elements of the SMS Framework
- Completed comprehensive SMS implementation plan for all elements to take the organization through Level 4. This SMS implementation plan must be accepted by GACA.
- Identified safety competencies required, completed training appropriate to Level 1, implementation phase identified for competencies required, and a training plan for all employees
Implementation Level Two: Reactive Process, Basic Safety Risk Management. At level two, the aviation organization develops and implements a basic SRM process and plan, and organizes and prepares the organization for further SMS development. Information acquisition, processing, and analysis functions are implemented and a tracking system for risk control and corrective actions are established. At this phase, the aviation organization corrects known deficiencies in safety management practices and operational processes, develops an awareness of hazards, and responds with appropriate systematic application of preventative or corrective actions. This allows the aviation organization to react to unwanted events and problems as they occur and develop appropriate remedial action. For this reason, this level is termed “reactive.”
i Level 2 – Exit Expectations. The following items are required prior to Level 2 exit:
- Processes and procedures documented for operating the SMS to the level of reactive analysis, assessment and mitigating actions
- Develop documentation relevant to SMS implementation plan and SRM components (reactive processes)
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- Document and initiate voluntary non-punitive employee reporting and feedback program;
- Completed SMS training for the staff directly involved in the SMS process and initiated training for all employees to at least the level necessary for the SMS reactive processes
- Apply Safety Risk Management (SRM) processes and procedures to at least one known (existing) hazard and initiate the mitigation process to control/mitigate the risk associated with the hazard
- Update the detailed gap analysis on the entire organization for all elements of the SMS Framework
- Update the comprehensive SMS implementation plan for all elements to take the organization through Level 4
Implementation Level Three: Proactive Processes, Looking Ahead. The activities involved in the SRM processes involve careful analysis of systems and tasks involved; identification of potential hazards in these functions; and development of risk controls. The risk management process developed at level two is used to analyze, document, and track these activities. Because the aviation organization is now using the processes to look ahead, this level is termed “proactive.” At this level, however, these proactive processes have been implemented but their performance has not yet been proven. (Fully functioning SMS) Component 2.0 of the SMS Framework expects SRM to be applied to:
- Initial design of systems, processes, organizations, and products
- Development of operational procedures
- Planned changes to operational processes
i Level 3 – Exit Expectations. The following items are required prior to Level 3 exit:
• Demonstrated performance of Level 2 requirements
- Objective evidence that all SMS processes are being updated, maintained and practiced
- Objective evidence that the Safety Risk Management process has been
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conducted on all Component 2.0 operating processes
- Objective evidence of compliance with Process 2.1.1
- Objective evidence of compliance with Element 3.2
- Objective evidence of compliance with Element 4.1
- Objective evidence of compliance with Process 4.1.1
- All applicable SMS processes and procedures must have been applied to at least one existing hazard and the mitigation process must have been initiated
- Complete SMS training for the staff directly involved in the SMS process to the level of accomplishing all SMS processes
- Complete employee training commensurate with the requirements of Level 3
Implementation Level Four: Continuous Improvement, Continued Assurance. The final level of SMS maturity is the continuous improvement level. Processes have been in place, and their performance and effectiveness have been verified. The complete SA process, including continuous monitoring and the remaining features of the other SRM and SA processes are functioning. A major objective of a successful SMS is to attain and maintain this continuous improvement status for the life of the organization.
4.8 Analysis Processes.
Guidance and tools have been developed for use in directing and evaluating progress though the SMS implementation process. These tools are based on performance objectives and design expectations developed for each Component, Element, and Process of the SMS Framework.
- The SMS Framework is based on ICAO and GACA requirements/guidance
- The SMS Assessment Guide is based upon the SMS Framework, in question form
- The Gap Analysis Tools are based upon the ICAO SMS Gap Analysis tools in a user-friendly format
System Description and Analysis. Prior to performing the gap analysis process, the aviation organization should conduct an analysis of all of the organization's operational functions,
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programs, processes, and documentation in order to fully understand how their existing operations compare to the SMS framework.
Gap Analysis. The phased implementation of an SMS requires an aviation organization to conduct an analysis of its system to determine which components and elements of an SMS are currently in place and which components and elements must be added or modified to meet the implementation requirements. This analysis is known as gap analysis, and it involves comparing the SMS requirements against the existing resources of the aviation organization. A gap analysis tool based on the ICAO SMS Gap Analysis tool (Ref. ICAO SMM) can be used by aviation organizations. The GACA Assessment Tool that can be used as a gap analysis tool is in Appendix C of this document. The gap analysis tool provides, in checklist format, information to assist in the evaluation of the components and elements that comprise the SMS framework and to identify the components and elements that will need to be developed. Each question in the checklist is designed for a “Yes” or “No” response. A “Yes” answer indicates that the aviation organization already has the component or element of the SMS framework in question incorporated into its system and that it either matches or exceeds the requirement. A “No” answer indicates that a gap exists between the component/element of the SMS framework and the aviation organization’s system. Once the gap analysis is complete and documented, it will form one basis of the SMS implementation plan.
4.9 Implementation Plan.
Based on the results of the gap analysis process, an implementation plan is prepared to “fill the gaps”, the “gaps” being those elements in the SMS Framework that have not completely met expectations (e.g., are not already being performed) by the aviation organization. The SMS implementation plan is a realistic strategy for the implementation of an SMS that will meet the aviation organization’s safety objectives while supporting effective and efficient delivery of services. It describes how the aviation organization will achieve its corporate safety objectives and how it will meet any new or revised safety requirements, regulatory or otherwise. Further guidance on how to develop an SMS implementation plan is contained in the ICAO SMM.
The implementation plan need not be complex or excessively detailed, but should provide a basic roadmap to meet the overall objective stated in the SMS Framework to, “...develop and implement an integrated, comprehensive SMS for [the] entire organization.”
The implementation plan may consist of more than one document, details the actions to be taken, by whom and within what time-frame. The implementation plan can be created in any format that is useful to the company but should provide at least the following:
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- Component/element/process reference from the SMS Assurance guidance or SMS Framework,
- Brief description of the actions to be taken and manual(s) affected,
- Responsible organization and/or individual(s), and
• Expected completion date.
The Implementation Plan should span the entire SMS development process. Consideration of it should be a part of the discussions from the earliest stages of SMS planning and organization, and appropriate adjustment of it should continue through all levels of SMS implementation maturity. It should be updated as necessary (along with the detailed gap analysis) as the projects progress. At each level, top management's approval of the implementation plan must include allocation of necessary resources IAW element 1.2.
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CHAPTER 5 - SMS ACCEPTANCE
5.1 Introduction.
The objective of this chapter is to provide general information about GACA inspector responsibilities and activities for accepting or rejecting an aviation organization's Safety Management System (SMS). The SMS acceptance information addresses two important scenarios for an aviation organization's SMS proposal:
1. To accept or reject the development and implementation of a SMS, that complies with GACAR Part 5, for a new aviation organization seeking initial certification.
2. To accept or reject the development and implementation of a SMS, that complies with GACAR Part 5, for a currently certificated aviation organization eligible for the phased implementation process provided by the regulation.
This information is about the acceptance of a proposed SMS developed by aviation organizations (for example, air operators, flight training schools and training centers, and aerodrome operators) requiring certification by the GACARs.
5.2 References.
This information is in accordance with the following documents:
• ICAO Annex 19, Safety Management
- International Civil Aviation Organization (ICAO) Document 9859, 3rd Edition, ICAO Safety Management Manual (SMM)
• ICAO Document 9734, Safety Oversight Manual
5.3 New Aviation Organization Certification – SMS Acceptance.
It will be a responsibility of the GACA Aviation Safety Inspector (Inspector) to make an assessment of a proposed Safety Management System (SMS) submitted by a prospective aviation organization as part of the overall certification process. The assessment and acceptance of the proposed SMS will be by determination that the proposal is in accordance with the SMS framework described in this document. The assessment activities related to the acceptance of an SMS will be focused primarily on whether the applicant has implemented an SMS that meets all of the design expectations (i.e. design assessments) defined in the SMS framework. The assessment of the actual performance of the SMS (i.e.
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performance assessments) will occur after the initial SMS acceptance.
Requirements. The objectives and expectations outlined in the framework represent the minimum standard for an aviation organization to develop and implement in order to comply with the SMS requirements as specified in GACAR Part 5. The framework describes the objectives and expectations for an aviation organization’s SMS. The framework is intended to address only operational and support processes and activities that are related to aviation safety and not to address those related to occupational safety, environmental protection, or customer service quality. In addition, aviation organizations are responsible for the safety of services or products they purchase or contract from other organizations. The framework establishes the minimum objectives and expectations for an effective and compliant SMS; aviation organizations may establish additional or stricter requirements.
Assessment Tools and Techniques. As the Inspectors work through the process of assessing the proposed SMS for a new aviation organization's certification, there are two primary determinations that will be made to find the proposal acceptable: first, that the proposed SMS includes all the items required by the SMS framework; and, second, that the design expectations required by the framework have been adequately met by the documentation in the proposed SMS. The primary tool for assessing and accepting the proposed SMS is the acceptance tool found in Appendix B of this document and the assessment tool that is found in Appendix C of this document. The SMS Assessment Guide was developed to aid in the assessment of the design of aviation organizations' SMS programs in order to ensure that they comply with the SMS requirements specified in GACAR Part 5. For each required component, element and process, the SMS Assessment Guide includes:
• A brief statement of the performance objective
- A series of questions that are used to assess (i.e. evaluate) whether the design expectations have been met
- A “bottom line assessment” question is also included but this is only used during the periodic performance assessments.
Assessors, whether performing an assessment for the aviation organization or the GACA, should ask each question that pertains to the component, element or process under review and document their observations. From these assessments, the determination is made whether the SMS is meeting the minimum standards as specified in GACAR Part 5.
Agreement on the Aviation Organization's Safety Performance Indicators and Targets. In accordance with applicable GACA inspector guidance, the Inspector will ensure that agreement is reached and documented with the aviation organization as to the safety performance indicators,
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values and targets (goals) as part of the acceptance process and prior to formal SMS acceptance. This concept is described in more detail later in this document.
Formal SMS Acceptance. For new certification programs (i.e. new aerodrome, new repair station, new air operators, etc.) the formal acceptance of the SMS occurs at the time of certificate issuance. In accordance with the requirements of GACAR Part 5, the SMS is considered formally accepted when the President of the GACA, or his representative designated for the purpose of SMS acceptance, has specifically endorsed the aviation organization certification documentation for SMS acceptance, Formal SMS acceptance will be communicated to the aviation organization in writing.
5.4 Currently Certificated Aviation Organizations - SMS Acceptance.
It will be a responsibility of the GACA Aviation Safety Inspector (Inspector) to accept or reject implementation plans and implementation levels (phases) of a proposed SMS submitted by aviation organizations (air operators, repair stations, flight training organizations aerodromes, etc.) that are eligible for a phased implementation of a SMS, as provided for by the GACAR. The acceptance process will focus on determining that the requirements for phased implementation outlined in Section 5 of this document, including the completion of all the steps in the implementation plan, are met.
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CHAPTER 6 - AGREEMENT ON THE AVIATION ORGANIZATION'S SAFETY PERFORMANCE OBJECTIVES
Fundamental to safety management is the concept of continuous improvement and in order to achieve this it is necessary to have an ongoing knowledge of the level of safety within the system of the aviation organization. Determining the level of safety achieved, and comparing this to the minimum acceptable level of safety established by the aviation organization's safety policy and objectives, depends upon identifying, measuring and tracking safety indicators relative to safety targets established.
As part of the GACA Inspectors' oversight responsibilities, inspectors will establish agreements with aviation organizations about their safety performance indicators, safety performance indicator values to be used, safety performance target values as goals, and a plan to track indicator values and actions taken to achieve their target goals. This activity is associated with Element 1.1 of the aviation organization's SMS.
In order to structure an agreement with a particular aviation organization on safety performance indicators, values and targets to be used by the aviation organization, the individual operational environment for that aviation organization will be carefully considered.
The safety performance of the aviation organization related to the agreed upon safety indicators, values and goals must be tracked on a continual basis by the aviation organization in accordance with Component 3.0 (most notably Element 3.1) of the SMS Framework. This tracking activity and the readjustment of safety performance indicators and targets by the aviation organization, with the GACA agreement, will be reviewed periodically by the GACA as a part of Inspector oversight surveillance activities.
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CHAPTER 7 - CONCLUSIONS
The implementation of SMS represents a fundamental shift in the way we all do business. A SMS requires aviation organizations to adopt the components and elements detailed in this document and to incorporate them into their everyday business practices. SMS is also being integrated into the international arena with the introduction of International Civil Aviation Organization (ICAO) SMS requirements for all ICAO Contracting States.
Fundamental to the SMS is the development of a robust regulatory framework that accommodates safety management systems. GACAR Part 5 has been developed to meet the regulatory need.
The GACA has structured the system of oversight to accommodate the SMS framework and operational requirements of the aviation organizations. In the future, the GACA will oversee the effectiveness of the SMS. Interventions will focus on the systems in place to manage the organization's operations and the outputs of the system, rather than focusing oversight activities on line-by-line adherence to the regulations through rigorous inspections and auditing.
The aviation organization must have effective programs in place to identify, analyze and correct safety issues, with minimal intervention at the operational level from the GACA. This approach does not constitute self-regulation nor does it represent an abrogation of the role of the regulator for the oversight of the aviation organization. Aviation organizations will be required to involve the GACA when issues are identified through their SMS. This will provide the GACA with an awareness that the aviation organization's SMS is working effectively. The success of the system depends on the development of a safety culture that promotes open reporting, through the adoption of safety reporting policies and continual improvement through, proactive safety assessments and quality assurance. The SMS philosophy requires that responsibility and accountability for safety be retained within the management structure of the organization. The accountable executive and top management are ultimately responsible for safety, as they are for other aspects of the aviation organization. However, every member of the aviation organization has safety responsibilities, as well; in safety management, everyone has a role to play.
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COMPONENT 1.0 – SAFETY POLICY AND OBJECTIVES
Component Performance Objectives
The organization will develop and implement an integrated, comprehensive SMS for its organiza

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