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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 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 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 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.

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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

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40 Safety Management Systems for Airports Table 2. Rating your SMS elements. Rate Rate Rate Description Comment Shading Not applicable The sub-element may not For example, consolidated (N/A) be applicable because documentation that describes the SMS is not in place the SMS and the yet. The same tables can interrelationships between all be used for SMS its pillars is N/A. assessment after the SMS has been implemented. Meets Fulfills SMS needs, even if For example, license and expectations some minor work is permit requirements generally necessary to incorporate are in place, and legal it into the SMS. requirements implemented for Part 139 airports. Needs The concept is present A safety policy may be in improvement but missing something. place, but if it lacks safety Some work will be objectives, it should be rated required to incorporate it in this level. into the SMS. Not in place The sub-element is Some airports do not have an missing and needs to be SRM process in place. developed and implemented. 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