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59 This section provides an overview of each FAA SMS pilot study as issued by the FAA, including dates, duration, number of participants, FAA-defined objectives, scope of work, and key deliverables. This information can be found on the FAAâs Airport SMS site at the following URL: http://www.faa.gov/ airports/airport_safety/safety_management_systems/ FIRST SMS PILOT STUDY (STUDY 1)âCLASS I, II, III, AnD IV AIRPORTS Dates: April 2007 to late 2007 (staggered starts) Duration: 6 months (see Figure 1 for comprehensive SMS pilot study timelines) Number of Participants: 22 (see Table 2 for a list of participants) Objective: The FAA conducted the first pilot study program to evaluate the implementation of SMS at airports of varying size and complexity. The pilot program would allow airports and the FAA to gain experience establishing airport-specific SMSs that are tailored for the individual airport. This infor- mation would provide FAA information on SMS best prac- tices and lessons learned to assist the FAA in development of a Notice of Proposed Rulemaking to incorporate SMS into 14 C.F.R. Part 139, Certification of Airports. Scope of Work: The airport operators that participated in the first SMS pilot study were responsible for developing and documenting their SMS programs in a safety program manual (SPM). The SPM was required to identify âgapsâ between the Airport Certification Program and the SMS being developed for the airport. While developing the SPM, airport operators were advised to extract SMS principles from the existing airport certification manual, memorandums of understanding and memorandums of agreement, safety during construction plans, surface movement guidance con- trol plans, airport emergency plans, and other documents to address SMS requirements. Deliverables: The development of the SMS manual and program should be completed 6 months after award of the Airport Improvement Program (AIP) grant. To help FAA evaluate the SMS airport-specific development process, copies of the following documents must be provided to the FAA as they are completed. The FAA encourages sponsors and their consultants to refer other interim draft documents, questions, and comments to the FAA at any time in the pro- cess for consultation and information exchange. APPEnDIX C Detailed Safety Management System Pilot Study Background a. Gap Analysis The gap analysis should identify procedures, policies, docu- mentation, and actions that the airport needs to implement as part of its SMS that go beyond the current Part 139 require- ments addressed by the airportâs certification manual. Estimated completion date: 2 months from project start b. Draft Plan A draft of the complete SMS manual and program. The draft should address the gap analysis and describe safety risk manage- ment, risk mitigation strategies, and documentation processes. Estimated completion date: 5 months from project start c. Final Plan A copy of the final SMS manual and program to be imple- mented by the sponsor. Estimated completion date: 6 months from project start The contents and scope of the SMS manual and program plan should address the following: 1) Written safety policy statement and description of how it is communicated to airport employees. 2) Identification and description of the airport safety goals. 3) A plan for employee SMS indoctrination and training. SMS indoctrination training should provide an outline of proposed curriculum and resources. 4) Documented process to identify training requirements for systems safety. 5) A plan to validate training effectiveness and the process to gain training feedback, including usable metrics. 6) A defined process to communicate safety policies and objectives throughout the organization. Include exam- ples of how information will be communicated and any processes for follow-up. 7) A plan and description of employee nonpunitive report- ing systems, existing and new. 8) An organizational chart identifying the names and safety responsibilities of all key personnel, such as the following: ⢠Top management, ⢠Safety manager, ⢠Department heads/managers, and ⢠Established safety committees and chairpersons.
60 9) Description of the safety risk management process, including application of âThe Five Phases of SRM,â as discussed in the FAA Advisory Circular 150/5200- 37, Introduction to Safety Management Systems for Airport Operators. 10) Guidance on the use of SRM and trend analysis. 11) Defined process for documenting the results of SRM to include a description of how documents will be stored (i.e., electronic or paper). 12) Description of how top management will follow-up on SRM to ensure that safety mitigation strategies are appropriate. 13) A description of the airport quality management and/ or risk management program (if applicable) and its integration into the airport SMS. 14) Description of a plan to integrate apron safety man- agement into the airport SMS. (FAA review of the plan will be limited to measures to prevent accidents or incidents involving aircraft.) The plan could include the following: a. A description of current apron safety manage- ment practices already in place, such as reporting requirements to the NTSB, Flight Standards, or the Occupational Safety and Health Administration. b. An explanation of how current apron safety man- agement practices meet the intent of SMS. This could include the safety plans and practices of tenants and operators at the airport, which should complement the airport SMS. 15) A detailed method to document self-auditing pro- cesses and their findings. Self-auditing may be part of the airport self-inspection process. If it is, explain how the self-inspection process addresses systems safety (i.e., if the self-inspection program identifies a hazard on the airport it should determine the risk and document the process for follow-up). 16) A detailed method to document self-inspection reviews, analysis, and findings. 17) A description or plan to integrate the tailored SMS program plan into the overall operation of the airport. 18) Documented plan for training and education, safety communication, competency, and continuous improve- ment processes. 19) Procedures to promote safety awareness and partici- pation in nonpunitive reporting systems. 20) Process to document and review lessons learned from within the organization. 21) Schedule for implementation and anticipated associ- ated costs. SECOnD SMS PILOT STUDY (STUDY 2)â CLASS II, III, AnD IV AIRPORTS Dates: July 2008 to early 2010 Duration: 6 months (staggered starts) Number of Participants: 9 (see Table 2 for a list of participants) Objective: The second pilot study was aimed at collecting additional information to assist the FAA in determining scope, scalability, and implementation of SMS at smaller airport operations. Therefore, the second pilot study was limited to airports with Class II, III, and IV airport operating certificates. Scope of Work: Airports in the second SMS pilot study were tasked to assess their existing Part 139 operations with regard to integration of a SMS (including safety policy, safety risk management, safety assurance, and safety promotion) and to develop a SMS program plan and manual. The airports were not required to deploy the SMS, merely to prepare for and out- line the tasks, staff, and programs necessary to support the SMS. Deliverables: See SMS Pilot Study 1 for a list of deliver- ables; the same deliverables were required for Study 2. STUDY 3âFOLLOW-On/PROOF-OF-COnCEPT PILOT STUDY Dates: November 2008 to March 2010 Duration: 13 months (staggered starts) Number of Participants: 3 (see Table 2 for a list of participants) Objective: The FAA conducted the SMS follow-on/proof- of-concept pilot study at three airports of varying size and complexity. The follow-on study allowed the FAA to gain more information on the ability of airports to integrate an SMS into their operating structures. Information and experi- ence gained through this follow-on study will be helpful as FAA continues development of its Notice of Proposed Rule- making to incorporate SMS into Title 14 Code of Federal Regulations (CFR) Part 139, Certification of Airports. Scope of Work: In the SMS follow-on/proof-of-concept study, the three participating airports were directed to use a proof-of-concept approach to âprove-outâ key elements and components of the SMS manual and implementation plans developed in the first SMS pilot study. Airports began imple- mentation of their SMS manuals and verified whether key elements and components established or envisioned in the SMS manual were functional within the airport operating environment. The study tasks were extensive and reflect a 13-month project duration. A. Airport Safety Policy Task 1: Develop standard elements for an SMS policy. With the large variety of recommended policy statements avail- able internationally, the approach will be to develop a policy template with a yes/no decision tree for each airport to use. This policy template will provide guidance on what is appro- priate for an airport of similar size and operation. To com-
61 plete this task, the airport will develop a core set of policy elements and develop a decision tree that allows for an air- port to develop and refine its safety policy. Airports should also report on what policy or format works best in their oper- ating environment and if they have made any changes to their SMS program to incorporate findings under this task. Task 2: Define safety managerâs roles and responsibilities including safety committee functions, where applicable. While roles and responsibilities of a âsafety managerâ may vary at each airport, a core set of duties will be developed to help guide airports in determining who in the organization may best serve the SMS program. This includes develop- ment of a safety committeeâs functions, including authority and reporting capabilities. These roles will be reviewed with regard to the current Part 139 activities within the airportâs organization for assessment of future impact of SMS on Part 139 staffing and management. To complete this task, the airport will develop a comprehensive set of duties; develop options for shared and single safety management position, develop safety committee activities and sample process flows for reporting, and provide guidance on how to engage current staff in safety committee activities. If changes are made to the airportâs SMS as a result of the findings under this task, the airport should report on those changes. Task 3: Review nonpunitive programs with regard to legal authority. Preliminary research on nonpunitive SMS pro- grams reveals that an airport may not have the authority to protect the person from punitive measures by organizations outside the airportâs SMS program. To complete this task, the airport will develop nonpunitive language that can align with airportâs authority and recommend language for rules and regulations that may assist with nonpunitive program imple- mentation at airports of similar size and operations. If changes are made to the airportâs SMS as a result of work done under this task, the airport should report on those changes. Task 4: Research third-party data collection, collaboration, and reporting systems. Under the Freedom of Information Act, the public can request a variety of information from air- ports. To encourage reporting under the airportâs SMS pro- gram, research of a third-party database to collect, store, and report on SMS events, trends, and activities will protect the data from requests under the Act. Obviously, the level of detail and expanse of the reporting system will vary from airport to airport. Therefore, under this task, the airport will develop a list of requirements for third-party hosting, collaborate with FAAâs Joint Planning and Development Office for best prac- tices and possible joint development of a system, and report out on the pros and cons of systems with a recommendation for Part 139 airports of similar size and operations. B. Safety Risk Management Task 1: Identify hazards. Hazard identification is the core of the SMS program. An effective hazard identification approach is likely the most important aspect of risk manage- ment. Under this task, the airport will develop a typical list of hazards for movement and nonmovement areas, including the ramp and bagwell (if applicable), for the airport, which would also be applicable to airports of similar size, class, and operation, and a hazard analysis approach and checklist. The airport should report on any changes made to their SMS program as a result of work done under this task. Task 2: Determine the risk, assess the risk, and analyze the risk associated with hazards identified under Subpart B, Task 1. A variety of risk matrices exist in the aviation indus- try, many of which are automated. The focus of this task is to develop and refine the most effective risk matrix for a Part 139 airport of similar size, class, and operations. Although FAA suggested a risk matrix structure in its Advisory Cir- cular 150/5200-37, Introduction to Safety Management Sys- tems for Airport Operators, there may be risk matrices that are more applicable or useful to airport operators. Under this task, the airport will reevaluate the risk matrix developed during the first pilot study, develop a prototype risk matrix using findings from research and automate where possible, develop a guide to using the risk matrix, and develop a guide to assessing and analyzing risk that could be used by opera- tional personnel. If the airport finds FAAâs suggested risk matrix format sufficient for its operations and structure, the airport should report that finding and provide any additional information or data to explain the rationale for their finding. The airport should report on any changes made to its SMS program as a result of work accomplished under this task. Task 3: Treat (mitigate) the risks for hazards identified and analyzed under Subpart B, Tasks 1 and 2. Corrective measures and controls are directly related to risk mitigation and will be developed as part of the risk management pro- gram. Under this task, using the hazards developed under Subpart B, Task 1, the airport will develop business flows and tracking tools for corrective measures and overall risk mitigation for the given airportâs size, class, and operations; and develop a guide for developing and implementing risk mitigation strategies and individual corrective measures and controls. Task 4: Reevaluate, analyze, and communicate risks. Risk mitigation strategies are successful when a program for con- tinuous improvement is developed as part of the safety risk management process. Identified risks that are mitigated or resolved often lead to new risks. Trending and tracking of risks and outcomes allow for the SMS program to play a proactive role in airport safety. Under this task, the airport will develop a risk evaluation process and procedures appli- cable to an airport of similar size and operations, develop a guide to risk evaluation and reporting processes for use by operational personnel, and develop communication tools such as dashboards (i.e., quick reference charts, statistics, information) or charts with risk mitigation results that can be reported to top managers within the airport.
62 C. Safety Assurance Task 1: Establish a foreign object debris (FOD) program for the movement area, ramp, and bagwell areas (if appli- cable). Damage from foreign object debris to aircraft pres- ents a great challenge for airport operators. Under this task, the airport will identify areas on the airfield needing FOD control, develop new policy and procedures to reduce poten- tial for FOD damage, develop training protocols (i.e., who needs training, how often, what are major components of the training curriculum) for FOD training as appropriate for the given airportâs size and operations, and develop a tracking and trending program for FOD identification and control. Task 2: Develop a personnel training and record-keeping program that meets the requirements developed under the airportâs SMS program. Part 139 prescribes requirements for personnel training and record keeping. However, an airportâs SMS training and record-keeping requirements will far sur- pass those items currently required under Part 139. Under this task, the airport will develop record-keeping processes with abilities to alert or query data for recurrent or refresher train- ing or record-keeping elements under the airportâs SMS and develop a tracking system that can integrate into any of the airportâs related tracking or training programs currently in use. Task 3: Develop a ramp and bagwell (if applicable) self- inspection program that ensures that safety is maintained. Although FAA currently does not regulate airport ramp areas, the increase in safety-related incidents in the ramp and bag- gage makeup areas in airports is disturbing. Self-inspection techniques required under Part 139 for movement areas may be useful to an airport to decrease the number of incidents in nonmovement areas. Under this task, the airport will review Part 139 to determine if requirements for self-inspection in the movement areas would be useful for self-inspection in the nonmovement areas, including the ramp and bagwell (if applicable); develop maps of the nonmovement area; create an audit checklist/self-inspection form for the given airport; create forms for reporting and documenting hazards, inci- dents, and accidents; and develop processes for reporting, tracking, and trending safety issues on the ramp and baggage makeup area (if applicable). Task 4: Develop a minimum standard for safe operations on the ramp and in the bagwell (if applicable). As discussed under Task 3, the ramp and bagwell are not currently regu- lated under Part 139 and present increased potential for inci- dents and accidents. Under this task, the airport will develop a minimum standard for safe operations, identify areas of concern or potential for increased incidents and accidents, and list baseline incidents and accidents for trending. D. Safety Promotion: At this time, no federal funds may be used in the implemen- tation of proving of safety promotion actions under the air- portâs SMS. Deliverables: a. Monthly Progress Reporting: To help FAA evaluate implementation of the airportâs SMS while it develops its proposed rulemaking, the airport will report on the status of its efforts under this study on a monthly basis. Monthly prog- ress reports should include a written summary of status and an explanation of any difficulties or successes in implement- ing its SMS with specific focus on the tasks listed previously, any recommended changes to its SMS manual and imple- mentation plans developed under the first pilot study, and any findings made or items developed under the preceding tasks. b. Final Report: The final report will include all forms, tem- plates, training protocols, maps, and other documents for all tasks under this study, a report on the airportâs efforts under this study, and a revised estimate of cost for implementation of the airportâs SMS. Should the airport make any changes to its SMS documents developed under the first pilot study as a result of its efforts under this follow-on study, the airport will provide the FAA with its updated documents, including SMS manual and implementation plan with either a tracked changes copy or cover letter identifying the changes made. STUDY 4âSMS IMPLEMEnTATIOn PILOT STUDY Dates: September 2010 through spring of 2012 Duration: 13 months (staggered starts) Number of Participants: 14 (see Table 2 for a list of participants) Objective: The FAA conducted the SMS implementation study as a final SMS pilot study effort offered to all prior airport SMS pilot study participants. The intent of the study was to examine how airports implement safety risk manage- ment and safety assurance throughout their airfield environ- ment, including the movement and nonmovement areas where applicable. The study also intended to assess the validity of SMS documentation developed during the first pilot studies by reviewing and revising the SMS manual. Results of the study are expected to directly assist FAA in the development of stan- dards and guidance related to SMS for certificated airports. Scope of Work: 5. Implement safety risk management procedures, pro- cesses, or policies as formulated under the airportâs SMS manual or other documentation developed for the airport under the first pilot studies. 6. Conduct at least three safety risk analyses/assessments within 6 months of the AIP grant award or study start. These analyses/assessments should not include analyses/assessments required under FAA Air Traf- fic Organization SMS. The analyses/assessments can address hazards in the movement or nonmovement areas of the airport.
63 7. Implement a safety reporting and/or data collection system or applicable processes in conformance with the airportâs SMS manual or other documentation developed for the airport under the first pilot studies. 8. Collect hazard reports, incident and accident reports, and other safety-related data/information under the airportâs SMS manual or other applicable documenta- tion within 2 months of AIP grant award or study start. 9. Analyze the information collected through the reporting and/or data collection system or applicable processes within 5 months of AIP grant award or study start. 10. Conduct an internal audit/evaluation following the methods and procedures prescribed under the safety assurance component of the airportâs SMS manual or applicable documentation within 8 months of AIP grant award or study start. Deliverables: 1. Study Plan: Develop a plan for completing study tasks including proposed safety risk analysis/assessment and a report detailing what costs the airport plans to allocate to its AIP funding (i.e., consultant services, infrastructure, etc.). 2. Monthly Reports: Provide monthly reports on the status of implementing study tasks and developing study deliv- erables including any pertinent findings or challenges. 3. SRM Analysis: Provide documentation of the processes or procedures used to conduct the analysis and findings from the analysis. 4. Final Report: Provide a final report on study find- ings and deliverables for the airport. The report will include copies of all deliverables and any changes to the original SMS manual, implementation, or other documentation developed under the first pilot studies. The report will detail how the airport accomplished each of the study tasks and any trends discovered during safety risk management or safety assurance processes or procedures. If software is purchased or developed for the purposes of this study, the airport will report on the usefulness of the software; costs associated with development, procurement, and main- tenance; and challenges or lessons learned using the software. The report will also include a discussion of challenges or lessons learned through the study rela- tive to safety risk management and safety assurance. Finally, the airport will report the findings of its inter- nal audit and evaluation.
