Safety Management Systems for Airports, Volume 2: Guidebook (2009)

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33 A system is defined as a set of interacting or interdependent entities, real or abstract, forming an integrated whole. An SMS has several functions or parts that need to work well together to be effective in helping maintain the airport as a safe place. Implementing an SMS involves following a small number of basic principles and then adapt- ing proven SMS pillars to fit the size, type, and management style of the operation. As you read this document, you will likely find that most of the pillars and elements for SMS are already pres- ent in your airport. To have an SMS, the airport operator needs to put in place the elements or functions required by an SMS. For example, one of the required SMS elements is a safety reporting process. The air- port should make available one or more means to allow airport workers (staff and non-staff), and even passengers, to report safety issues and hazards. For example, a phone line that is acces- sible to anyone using or working at the airport could be an alternative. However, the process involves much more than the phone line. The notification provided needs to be forwarded to the right person, who is responsible for recording, analyzing, and taking specific actions. The reporter also needs to get some feedback on his/her report; otherwise, the reporter may not feel like submitting another report. The requirements for each SMS process are described in this guidebook. The implementation process and phases are described in Chapter 4. The airport operator needs to follow six basic steps to achieve the goal of implementing the system. This chapter will help you take the initial steps toward SMS implementation at your airport. Each section describes one step on the SMS planning phase before the implementation is initi- ated. These steps include the following: 1. Obtaining support from management to develop the SMS (Section 3.1) 2. Finding the right project manager to coordinate the SMS planning activities (Section 3.2) 3. Selecting an appropriate SMS structure or model (Section 3.3) 4. Determining how to use the resources and SMS processes that the airport already has and build upon them (Section 3.4) 5. Conducting a gap analysis to determine which SMS elements the airport already has, which ones need to be adapted, and which ones need to be created (Section 3.5) 6. Documenting the SMS (Section 3.6) 3.1 Management Commitment Safety, it is often said, is everybody’s business. Every member of an organization has a role to play in the management of safety. However, for SMS to be anything other than a collection of C H A P T E R 3 Getting Started

34 Safety Management Systems for Airports papers, it needs true support from management. Management support from the very beginning will be extremely important. It starts with a strong safety policy statement and a commitment to its elements. Management will then, among other things, allocate sufficient resources for the development and implementation of the SMS, and facilitate the flow of information (between departments, by authorizing meetings, posters, etc). Some of the resources necessary to start the process are an “SMS Champion” (to coordinate the process), time (for meetings, information gathering, planning, and communications), and expertise (consultants and specialists as required). 3.2 Appoint an SMS Champion The SMS Champion will coordinate and oversee SMS through planning, development, and implementation. Once your SMS is up and running, the job of on-going coordination and administration of the system will be transferred to the SMS Manager. The SMS Champion’s main role is project management for SMS implementation. This indi- vidual should have a good understanding of management principles, as well as functional knowl- edge of operational activities of the airport. It is advantageous for this person to have good communication skills, as well as respect and recognition within the airport organization, since most of the job will be to promote SMS with line personnel and middle management and to obtain resources and support from top management. Who should lead the SMS implementation effort? In this case, skills and experi- ence are more important than job title. The SMS Champion should have good people skills, a solid understanding of SMS, a track record of earning respect within the airport, and good project management capabilities. You need a Champion who can be both advocate and manager. Depending on the size of the airport organization, the SMS Champion could be responsible for planning and executing all phases of the implementation alone or with the support of a team. If the support of a team is available, it is desirable that team members represent a cross section of all areas of the organization. The SMS Champion and the SMS Manager can be the same person or not. The future SMS Manager should be involved with the implementation as early as possible, and it is desirable to have the future SMS Manager responsible for the implementation. At large airports, the person that will be appointed SMS Manager may not have the project management skills or experience to carry out the implementation and, in this case, it is justifiable to have an SMS Champion or Project Manager for SMS Implementation that is not the future SMS Manager.

Getting Started 35 3.3 Select an SMS Model Structure SMS requirements typically are performance-based. This means that though SMS must achieve certain objectives, the manner to achieve them is left to the operator. It is important when selecting an SMS model that it is based on the PDCA cycle and that it allows for external audits. Most published models have the following features: • FAA AC 150/5200-37—Safety Management Systems (SMS) for Airport Operators: 4 pillars (safety policy and objectives; safety risk management; safety assurance; and safety promotion) and 18 elements • FAA AC 120-92—Introduction to Safety Management System for Air Operator: 4 pillars • Occupational Health & Safety Assessment Series (OHSAS) 18001(16): 17 elements* • ICAO(3): 4 pillars and 12 elements • Transport Canada(17),(18),(19),(20): 17 elements** • Civil Aviation Authority of UK(21),(22),(23),(24): 6 elements** • Civil Aviation Safety Authority of Australia(10): 8 elements** When you choose a model for your SMS, make sure that it covers all of the elements described in this document. One way to make sure that your model is complete is to create a table of con- cordance that shows where the SMS elements are within your system. Using the model depicted in FAA AC 150/5200-37 may facilitate verifying agree- ment with these recommendations. *OSHA focus is on occupational health and safety; SMS goes beyond these to operational safety, however both use the same principles **to date, Canada, the United Kingdom, and Australia have not integrated OSHA and SMS 3.4 Build on What You Have An SMS will be most effective if it is built on existing practices and tailored to the airport’s size, complexity, type of operation, safety culture, and operating environment. Before designing your SMS, you will try to identify the SMS processes that you already have in place; this is called gap analysis and will be discussed in more detail in Section 3.5. You may be surprised to find how much you already have at your airport. If your airport is certificated under Part 139, many of the safety responsibilities are described in your Certification Manual. Moreover, you already have some proactive hazard identification procedures as part of the required daily self-inspections. In many cases, there are document and records management processes. Some airports even have other comprehensive management systems, such as environmental and wildlife management systems(15) that can be adapted or built on to handle safety issues using similar processes. Some airports collect safety data and perform trend analysis; however, most airports without SMS have no formal SRM process in place. Currently, most airports do not have a regular or ad hoc plan for safety audits or assessments, and they may need to create the processes and train staff. Table 1 lists some of the elements that you may already have at your airport and describes how they can be helpful to your SMS.

36 Safety Management Systems for Airports Examples of Existing Resources How to Use It in Your SMS A phone hotline that people can use to report safety issues to the department of operations. Small and medium airports can use an existing line for safety reporting. Larger airports may want to install a specific SMS hotline if necessary. An intranet and/or an Internet website. disseminate safety information and provide a forum where people can report hazards and other safety issues. An airport newsletter. safety to facilitate disseminating safety information at the airport. Regular meetings with managers and airport stakeholders. Your SMS documentation may include a requirement to have safety as a mandatory agenda item at some meetings. These meetings are excellent forums for discussions and brainstorming on safety issues, and they provide an excellent source of input to the SMS Manager. Procedures for daily self-inspections of the airside areas. Such activities are mandatory for Part 139 airports and are very effective for hazard identification. Extending the self-inspections to the landside and to the terminal, if not yet in place, will create an effective procedure for hazard identification when your SMS scope covers such areas. Introducing processes to pass the safety information from these inspections to the SMS Manager will integrate the self-inspection process to the SMS. Environmental and/or wildlife management systems. Most of the processes available for these systems can be adapted and used for your SMS. Much of the existing experience can be transferred to the SMS team. Some of the airlines operating at your airport may have some SMS elements in place. At airports sharing civilian and military operations, it is possible that the military organization has an SMS in place. In general, other organizations are willing to share their experience and, in some cases, even their tools. The airport SMS team has much to learn and gain from other organizations’ experience with SMS processes. Your airport can create an SMS webpage to You may want to add a specific section on Procedures for accident/incident investigations. If your airport has a risk management section, the staff may have a good starting point for safety investigation procedures and perhaps qualified people to provide training. Public safety and enforcement officers also have specific procedures and experience conducting accident investigations. In most cases, public safety investigations obtain information on how the accident occurred rather than on the root causes when determining why an accident happened. The existing investigation procedures can be adapted and staff trained to search for root causes of accidents and incidents. Part 139 requires airports to keep records of training, fueling agent inspections, self-inspections, accidents, and incidents. SMS also recommends keeping such records. They can be very helpful for accident and incident investigations. Part 139 records may be an excellent source of data for developing trend analysis. Control of documents and records. hubs have approved procedures for document and records control. These procedures are also applicable to SMS. Many airports, particularly medium and large Table 1. Using your existing resources.

Getting Started 37 Examples of Existing Resources How to Use It in Your SMS Many airports have safety committees toSafety committees. coordinate operations, ramp activities, runway incursion, and FOD programs, etc. The same committees can be part of your SMS organizational structure. Safety management for Part 139 requirements (training, condition of movement areas, wildlife control, emergency response, plan for snow and ice control, reporting airport conditions, handling and storage of hazardous substances and materials, access and traffic control of movement and safety areas, control of obstructions and protection of navigational aids (NAVAIDs), public safety, identification of construction and unserviceable areas) Each of these requirements should be addressed from both Part 139 compliance and SMS standpoints. SMS may help improve these processes using its systematic and proactive approach; however, when compliance and SMS priorities are not in agreement, even when risks are considered under control, compliance should be achieved for continuity of operations. Operational responsibilities of key staff defined in the Airport Certification Manual (ACM). The organizational structure and safety responsibilities described in the SMS Manual should be compatible and built on this structure. It will be necessary to include a safety management function that covers all areas within the SMS scope (airside, landside, terminal) for the airport. controlling risks will involve the enforcement or improvement of existing procedures. Some airports, particularly large and mediumTrend analysis. hubs, regularly collect data on accidents at the ramp and keep monitoring trends. Certificated airports keep track of their runway incursions and identify “hot spots.” Wildlife management programs keep track of trends for wildlife hazards. An audit function (most likely available at larger airports). The audit unit may be able to carry out SMS and safety assessments. In this case, the assessment team should have members that are knowledgeable of the area being assessed. If this is not the case, the audit unit may have audit procedures and be able to train airport staff in conducting general Existing safety objectives. few safety objectives that are measured and monitored (e.g., reducing the number of ramp accidents by 15%). These same objectives can be maintained and even supported by departmental goals. Existing rules, regulations, and SOP. assessments that can be adapted to verify safety. Part 139 airports comply with OSHA regulations and may have the associated management processes. Many of the existing OSHA management processes can be adapted and used for your SMS. Much of the existing experience can be transferred to the SMS team. Some airports, particularly large hubs, have a Many of the actions identified in the SRM for Table 1. (Continued).

38 Safety Management Systems for Airports 3.5 Conduct a Gap Analysis Once you have selected the SMS model appropriate for your airport, you are ready to move forward and find out how your organization measures up against SMS best practices. To do this you will need to conduct a gap analysis. This task is performed before you write your SMS doc- umentation and implementation plan. It is intended to identify the processes already existing in your airport, compare what you have against the requirements established by the pillars and elements of the SMS model that you have chosen, and identify what should be done to make these two pictures match. It may be beneficial to get an independent person/group to help you conduct the gap analysis. This will ensure that you get an objective look at the strengths and weaknesses of your existing processes. Hiring a private consultant is not the only way of doing this; you could also make an agreement with another similar organization in your region to conduct each other’s gap analyses. The gap analysis process is a great opportunity, not only to find what is missing, but also to identify key airport staff for the SMS and how to fill the gaps identified. The Gap Analysis Process The gap analysis will include both a document review and interactions with airport staff from all levels. The document review will focus on existing operations, organization documentation, and current procedures. The interactions—in the form of interviews, meetings, and discussions—will reach personnel at every level (senior management, middle management, and hourly employees) of all relevant departments of the airport including the following: • Operations • Emergency Response (i.e., Aircraft Rescue and Fire Fighting [ARFF]) • Public Safety and Security • Maintenance • Engineering, Planning, and Development • Offices of Existing Management Systems (e.g., risk, environmental, wildlife) • Marketing and Business Development • Human Resources • Finance and Legal Affairs • Airlines • Fixed Base Operators (FBO) and Service Providers Depending on time availability and the information gathered during the document review and personnel interviews, follow-up meetings and meetings with external parties may be required. The gap analysis should not include • Assessment of facilities or processes within the airport that are not directly related to the scope of the SMS. For example, if the airport decides to start with the implementation for the airside only, then only those processes associated with safety in the airside area will be relevant.

Getting Started 39 • For most airports, the initial scope of SMS will be restricted to the activities for which the air- port operator is responsible. Assessment of safety practices of tenants or organizations other than the airport organization may not be warranted. • Assessment of any other applicable health and safety requirements (i.e., OSHA requirements), such as those that might be required by state or federal regulations. It is desirable to have the airport designate a team of airport staff from different professional backgrounds to participate in selected meetings and discussions. Should this not be feasible, the SMS Champion should be the liaison between the parties and should facilitate team access to documentation and individuals. The gap analysis process needs to be well planned and executed. You need to have a checklist to remind you what to look for and to organize your notes. You will review the airport documents associated with organization and safety, and you will interview airport staff and stakeholders to assess how they take care of the airport’s safety, procedures they use, and coordination with other parties. Gap Analysis Tables You will need a checklist to make sure you cover all relevant SMS elements and to facilitate your annotations. You can use the SMS gap analysis and SMS assessment tables provided in Annex A; these tables are based on a general SMS model and were adapted using the SMS struc- ture described in FAA AC 150/5200-37. The tables are organized by SMS pillar and element. Each page provides space for the user to describe the specific airport reference where the information was identified, a space to assign a subjective level of conformity, and space to write notes. It is important to note that you need to evaluate the conformity for each sub-element before assessing the element as a whole. The same is true for the assessment of SMS pillars; you first need to evaluate each element before judging the main pillars. The documents in use by your airport may not have the same names described in these tables, or your airport may have documents that are applicable to more than one sub-element or element. Once the answers for a particular area are determined, you should rate the sub-elements, ele- ments, and SMS pillars, as described in Table 2. Obtaining Relevant Information The main sources of information to complete these tables are the airport documents (e.g., ACM, rules and regulations) and the interviews that you will conduct with airport staff and stakeholders. Review of Airport Documents Before moving ahead with interviews, the gap analysis team should be familiar with the airport and its documentation. The most common documents that should be analyzed are the following: • Airport Certification Manual • Airport Emergency Plan • Rules and regulations • Policies and procedures • Training records • Airport organizational chart

40 Safety Management Systems for Airports • Construction safety plans • Self-inspection reports • Accident investigation procedures (if available) • Minutes of safety meetings Other documents may be identified as relevant during the interview process and added to the list. Interviews Some airports prefer to submit the gap analysis tables as questionnaires to obtain written responses from staff and stakeholders. In general, this methodology is not very effective because the questionnaire may be too long, airport workers may not be familiar with SMS, and many of the elements are not related to their work activities. Also, the questionnaire will restrict important interactions between the interviewer and the interviewees. Interviews are preferred, and the interviewer should avoid going through each and every line of the tables. Before initiating the interview, the interviewer should explain the purpose and answer any questions the respondent may have about the interview. It is essential to point out to the interviewee that it is not an audit and to explain briefly what SMS is. The inter- viewer should make notes on the checklist, and these notes should be consolidated as soon as possible to avoid losing the information, particularly the interpretation of responses in regards to SMS. Gap Analysis Report Once the checklist is complete, the gap analysis team will generate the main conclusions. A report should be prepared to document the process and findings. The gap analysis report docu- ments the findings of the gap analysis. It provides a summary of what is missing within the airport processes and organization in regards to a formalized and structured SMS. This document provides Rate Shading Rate Rate Description Comment Not applicable (N/A) The sub-element may not be applicable because the SMS is not in place yet. The same tables can be used for SMS assessment after the SMS has been implemented. For example, consolidated documentation that describes the SMS and the interrelationships between all its pillars is N/A. Meets expectations Fulfills SMS needs, even if some minor work is necessary to incorporate it into the SMS. For example, license and permit requirements generally are in place, and legal requirements implemented for Part 139 airports. Needs improvement The concept is present but missing something. Some work will be required to incorporate it into the SMS. A safety policy may be in place, but if it lacks safety objectives, it should be rated in this level. Not in place The sub-element is missing and needs to be developed and implemented. Some airports do not have an SRM process in place. Table 2. Rating your SMS elements.

Getting Started 41 an important summary to assist airport management and is used to define the roadmap to SMS implementation. A typical gap report may contain the sections indicated in Table 3. Table 4 depicts an example of a populated gap analysis table. 3.6 Documenting Your SMS The SMS documentation is made up of the airport SMS Manual and the specific procedures for the SMS processes. Figure 3 depicts the different levels of documentation. Overall, the SMS documentation should provide a description on how the SMS will be or has been set up, who is responsible for what, which processes and procedures are going to be used and when. Because SMS is not a regulatory requirement in the United States at this time, the SMS Manual should remain separate from the ACM required under 14 CFR Part 139. The SMS Manual describes the SMS elements and how they will be established and will function. It is a document that may resemble the ACM. Whereas the ACM describes how the airport operates, the SMS manual describes how the SMS functions. Unless the FAA makes changes to Part 139, your SMS Manual should not be part of your ACM; for the time being, these two manuals should be separate documents. The SMS documentation should ensure that the information within the references (e.g., oper- ating manuals) is consistent with the top-level SMS document. All SMS documents need to be controlled, coordinated, cross-referenced, and managed. The SMS Manual can be used as the primary document to identify the key processes that are part of the management system. Where necessary, it should refer to other appropriate documentation, such as the ACM. Item Report Section Content 1 the process and main conclusions Gap analysis date and teamIntroduction2 General objective of the processGoal2.1 Specific scope of the gap analysis associated Scope2.2 with the SMS scope (e.g., whole airport, airside) 2.3 gathered and the source of the checklist used Summary of the main gaps relative to theAnalysis 3 selected SMS model A information gathered and analyzed during the gap analysis B Sources Major sources of data B.1 position and department B.2 B.3 analysis, including visit to the airport facilities, demonstration of existing software, etc. The gap analysis purpose and a summary of Executive Summary How the information for the gap analysis was Gap Analysis Process Assessment tables consolidating the Annex A. Gap Analysis Tables Annex B. Gap Analysis Data List of personnel interviewed, including their Gap Analysis Interviews List of airport documents reviewed Documents Reviewed Other activities associated with the gap Other Activities Table 3. Contents of a gap analysis report.

1. SAFETY RISK MANAGEMENT Expectations (specific expectation or best practice) Organization Reference Eval. Remarks 1.1 Hazard identification Reactive hazard identification mechanisms are in place. Recording and analysis of hazards could be more comprehensive. Feedback and sharing of lessons learned is not systematic. 1.1.1 Hazard identification process 1.1.1.1 A procedure for the identification of hazards and assessment of risks is established and the methodology is defined. Daily self-inspection reports, maintenance reports There are proactive mechanisms to identify and report hazards, such as daily self-inspections, a Part 139 requirement. However, these inspections are aimed only at the airside and limited to staff trained for such inspection. Reporting systems 1.1.1.2 There is a reporting process, which is simple and accessible. Computer-Aided Dispatch (CAD) records, incident reports Yes. Radio and telephone calls to dispatch. 1.1.1.3 Reports are reviewed at the appropriate level of management. Yes. 1.1.1.4 There is a feedback process to notify contributors that their reports have been received and to share the results of the analysis. Not found. 1.1.1.5 All identified hazard data are systematically recorded, stored, and analyzed. Meets expectations Needs improvement Not in place Not consistently. If there is an associated incident number or case number the event is recorded in the CAD system; some hazards are recorded through work orders; otherwise, the information is passed on directly to the appropriate person and not recorded by dispatch. 1.1.1.6 There is a system to share significant safety event information with other similar organizations, subject to reasonable restriction on proprietary and confidential information. Not found, other than casual interactions through conferences and industry events. Table 4. Example of a gap analysis table.

Getting Started 43 The contents of an SMS Manual may include all or part of the following sections: • Policy statement • Objectives and goals • Organizational structure for SMS • Definitions of responsibility and accountability • Procedures for safety performance measurement and monitoring • Hazard reporting procedures Airport’s Safety Policy and Objectives Supporting Process- Level Documents; including the SMS Manual Supporting Procedures; including the SMS and Departmental Procedures Work Instructions and Checklists, Forms, Reports, Records, etc. Figure 3. Levels of SMS documentation. If a certain department already has a documented accident investigation proce- dure in place, the SMS documentation will make reference to that procedure when describing the related SMS pillar, instead of including (or repeating) it in the SMS documentation. For example, some airports have a risk management office that may have specific procedures that can be adapted and used for any type of accident in the airport. In most cases, the office of public safety has investigation procedures that can be modified for the identification of root causes of accidents and incidents. The extent of an SMS manual can vary from 5 pages in a very small airport to 50 pages or more in a larger airport.

• Procedures for hazard identification • Procedures for risk assessment • Procedures for risk control • Procedures for accident investigation • Terms of reference for safety committees • Procedures for document, record, and data management and control • Procedures for safety communication • Procedures for audits • Procedures for management review • Procedures for creating or modifying SOP • Others as needed Preferably, the SMS manual should contain only documentation that is not subject to frequent changes. Approving the SMS Manual may be a very time consuming process, particularly at medium and large airports, where the approval process may go all the way to board level. For example, one of the sections in the SMS Manual is “Objectives and Goals.” This section describes the process to set goals and objectives, possibly the frequency that these goals are modified, and points out the appendix of the SMS Manual where these goals can be found; however, the actual goals and objectives should be part of another document that can have a different approval process, and this document is incorporated as an appendix to the SMS Manual. Goals and objectives may be changed every year and sometimes are set by specific airport departments and sections, without the need to go to board level for approval. Once goals or objectives are modified, the appendix can be replaced without the need to approve the entire SMS Manual. 44 Safety Management Systems for Airports