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Getting Started 41 Table 3. Contents of a gap analysis report. Item Report Section Content 1 Executive Summary The gap analysis purpose and a summary of the process and main conclusions 2 Introduction Gap analysis date and team 2.1 Goal General objective of the process 2.2 Scope Specific scope of the gap analysis associated with the SMS scope (e.g., whole airport, airside) 2.3 Gap Analysis Process How the information for the gap analysis was gathered and the source of the checklist used 3 Analysis Summary of the main gaps relative to the selected SMS model A Annex A. Gap Analysis Tables Assessment tables consolidating the information gathered and analyzed during the gap analysis B Annex B. Gap Analysis Data Major sources of data Sources B.1 Gap Analysis Interviews List of personnel interviewed, including their position and department B.2 Documents Reviewed List of airport documents reviewed B.3 Other Activities Other activities associated with the gap analysis, including visit to the airport facilities, demonstration of existing software, etc. 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.

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Table 4. Example of a gap analysis table. 1. SAFETY RISK MANAGEMENT Expectations Organization Eval. Remarks (specific expectation or best Reference practice) 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 Daily self-inspection There are proactive mechanisms to identify and identification of hazards and reports, maintenance report hazards, such as daily self-inspections, a Part assessment of risks is established and the methodology is defined. reports 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, Computer-Aided Yes. Radio and telephone calls to dispatch. which is simple and accessible. Dispatch (CAD) records, incident reports 1.1.1.3 Reports are reviewed at the Yes. appropriate level of management. 1.1.1.4 There is a feedback process Not found. to notify contributors that their reports have been received and to share the results of the analysis. 1.1.1.5 All identified hazard data are Not consistently. If there is an associated incident systematically recorded, stored, and number or case number the event is recorded in the analyzed. 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 Not found, other than casual interactions through significant safety event information conferences and industry events. with other similar organizations, subject to reasonable restriction on proprietary and confidential information. Meets expectations Needs improvement Not in place

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Getting Started 43 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. 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

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44 Safety Management Systems for Airports 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.