Lessons Learned from Airport Safety Management Systems Pilot Studies (2012)

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In 2001, the International Civil Aviation Organization (ICAO), an agency of the United Nations with international aviation oversight, adopted a new standard in Annexes 6 (Operation of Air- craft), 11 (Air Traffic Services), and 14 (Aerodromes), requiring that all 192 contracting states establish safety management system (SMS) requirements. According to ICAO, “safety is increasingly viewed as the outcome of the management of certain organizational processes, which have the objective of keeping the safety risks of the consequences of hazards in opera- tional contexts under organizational control. Thus . . . safety is considered to have the following meaning: The state in which the possibility of harm to persons or of property damage is reduced to, and maintained at or below, an acceptable level through a continuing process of hazard iden- tification and safety risk management.” ICAO further clarifies the function of a SMS by stating that “the difference between traditional system safety and present-day safety management is that, because of its engi- neering roots, system safety focused mostly on the safety implications of technical aspects and components of the system under consideration, somewhat at the expense of the human component. Safety management, on the other hand, builds upon the dogma of system safety (hazard identification and safety risk management), and expands the field of perspective to include Human Factors and human performance as key safety issues during system design and operation.” In simple terms, SMS is a proactive business approach to managing and miti- gating potential hazards within the organization to improve safety performance. SMS is comprised of four components (or pillars), including safety policy, safety risk management, safety assurance, and safety promotion. The FAA defines each component as follows: • Safety Policy. Safety policy provides the foundation or framework for the SMS. It out- lines the methods and tools for achieving desired safety outcomes. Safety policy also details management’s responsibility and accountability for safety. • Safety Risk Management. As a core activity of SMS, safety risk management uses a set of standard processes to proactively identify hazards, analyze and assess potential risks, and design appropriate risk mitigation strategies. • Safety Assurance. Safety assurance is a set of processes that monitor the organization’s performance in meeting its current safety standards and objectives as well as contrib- ute to continuous safety improvement. Safety assurance processes include information acquisition, analysis, system assessment, and development of preventive or corrective actions for nonconformance. • Safety Promotion. Safety promotion includes processes and procedures used to create an environment in which safety objectives can be achieved. Safety promotion is essen- tial to create an organization’s positive safety culture. Safety culture is characterized by knowledge and understanding of an organization’s SMS, effective communications, competency in job responsibilities, ongoing training, and information sharing. Safety promotion elements include training programs, communication of critical safety issues, and confidential reporting systems. SUMMARY LESSONS LEARNED FROM AIRPORT SAFETY MANAGEMENT SYSTEMS PILOT STUDIES

2 FAA, as one of the 192 ICAO contracting states, indicates in the October 7, 2010, Notice of Proposed Rulemaking Safety Management Systems for Certificated Airports, that it “supports conformity of U.S. aviation safety regulations with ICAO standards and recommended practices and intends to meet the intent of the ICAO standard in a way that complements existing airport safety regulations in 14 CFR Part 139.” This notice also states: “This action would require each certificate holder to establish a SMS for its entire airfield environment (including movement and non-movement areas) to improve safety at airports hosting air carrier operations.” FAA defines SMS as, “a formalized approach to managing safety by developing an organization-wide safety policy, developing formal methods of identifying hazards, analyzing and mitigating risk, devel- oping methods for ensuring continuous safety improvement, and creating organization-wide safety promotion strategies. When systematically applied in a SMS, these activities provide a set of decision-making tools that airport management can use to improve safety.” FAA’s approach to assessing the impact of SMS on 14 Code of Federal Regulations Part 139 certificated airports included “developing advisory guidance, researching airport SMS recommended practices, and conducting airport pilot studies.” Beginning in April 2007 and concluding in early 2012, FAA provided opportunities for U.S. airports to gain knowl- edge from and provide information and feedback to FAA by conducting SMS airport pilot studies. To date, 31 airports of various sizes, operations, and regions have participated in four SMS airport pilot studies, including the following: 1. FAA SMS Pilot Study 1—Gap Analysis and SMS Manual and Program Plan Develop- ment for Class I, II, III, and IV Airports; 2. FAA SMS Pilot Study 2—Gap Analysis and SMS Manual and Program Plan Develop- ment Limited to Class II, III, and IV Airports; 3. FAA SMS Pilot Study 3—SMS Follow-on/Proof-of-Concept Study; and 4. FAA SMS Pilot Study 4—SMS Implementation Study. This Synthesis study’s objective is to provide airport operators with data and experience from SMS pilot study airports through survey results, lessons learned, and general findings and trends. The proposed audience is U.S. Part 139 certificated airport operators; however, while intended for Part 139 airports, the results gathered in this Synthesis of Practice may be helpful to all airports. The study approach focused on completing a literature review of current SMS industry documentation and conducting interviews with SMS pilot study airport representatives and consultants. Sources for the literature review included FAA, ICAO, the Government Account- ability Office, various ACRP resources, Transport Canada, the Australian Government’s Civil Aviation Safety Authority, and academic and industry references relating to SMS. The SMS pilot study interviews consisted of on-site or telephone discussions ranging from 30 to 90 min using a 36-question survey tool to address all aspects of the four SMS pilot studies, includ- ing program logistics, planning, staffing, and SMS integration and implementation. Of the 31 participating SMS pilot study airports, 26 airport operators responded—an 84% response rate. Airports participants were represented from each of the four studies and from Class I, II, and IV airports (no Class III airports participated in the survey). Throughout this Synthesis study report, de-identified data and findings are presented by airport class to address differences in operational scale and staffing. Definitions of class size are presented in the Glossary of Terms and Acronyms. A summary of findings and lessons learned from a survey of pilot study airport operators for this Synthesis study are presented here: • SMS Pilot Study Program Management. Program management is the set of struc- tures, tools, activities, and personnel that is employed by airports to realize a fully functional and operational SMS, including a program gap analysis, program plan, and schedule. All airports participating in Pilot Studies 1 and 2 conducted a program gap

3 analysis to compare their existing Part 139 operations and the four SMS components. Airports used a variety of checklists and templates to determine program gaps. Draft SMS manuals and program plans were then developed as a result of the gap analysis. SMS manuals developed in the first two pilot studies were nearly all revised by air- ports participating in the following pilot studies (Studies 3 and 4). Modifications were a reflection of the implementation program’s use of a theoretical document developed in the first studies. Many airports reduced the initial SMS manual content to align with staff needs and ease of use and others increased the content to include standard operat- ing procedures and detailed processes and procedures. Key lessons learned relating to SMS pilot study program management include the following: – Clearly defining the SMS project development documents, such as a program plan and schedule, assists with the airport’s ability to design, plan, and deploy the SMS. – Ensuring adequate or flexible SMS program timelines to conduct a gap analysis (or other business analysis efforts) assists airports in developing program plans. – Allowing adequate time to design, develop, test, and deploy the SMS manual through the life of the program implementation improves the quality of the manual and asso- ciated processes. – Developing program plans to be flexible supports the airport’s SMS implementation timelines and staffing constraints. – Local airport and U.S. Part 139 experience is a valuable SMS consultant skill in consultant selection in addition to SMS development and deployment expertise. – Formal SMS guidance, documentation, and information-sharing opportunities sup- port the SMS design and development. – Collateral duties are the reported norm for current and future SMS staff responsi- bilities; budget constraints and delayed hiring decisions based on forthcoming FAA rulemaking are cited as the primary reasons new hires are not planned. – Data collection, analysis, and trending are core functions of SMS and require early planning for adequate budgets to procure or build technological solutions. – The method to develop and deploy a safety policy statement requires various approval processes depending on the airport management structure. Airport safety policy development includes investigating the proper route and approval function early in the SMS program to ensure adequate time is allocated. • SMS Components Design, Development, and Deployment. As airports developed the four components of the SMS program (safety policy, safety risk management, safety assurance, and safety promotion), a number of references and resources were used. The majority of airports ensured a thorough review of FAA’s Advisory Circular (AC) 150/5200-37 regarding SMS implementation for Part 139 airports. The AC, authored in 2007, offered at the time of the initial studies (2007 and 2008) the only formal guid- ance published by FAA. Airports also reported reviewing the ICAO Safety Management Manual as the second most used document to develop the SMS manual and program. All airports surveyed, except one, hired consultants to assist with elements of the SMS studies. Management of the airport staff and the study consultants was most often assigned to a staff member from the airport operations department. All airports reported that the assigned SMS pilot study program manager took on the project management duties as a collateral assignment. Few airports reported hiring new staff to represent the safety (SMS) manager; most airports, again, assigned staff with additional or shared duties to support the SMS program. A series of lessons learned for SMS implementation, including aspects of each component, is presented here: – Deployment of the safety policy is unique to each airport’s internal and external com- munication paths. Some airports develop a communication plan to roll out the safety policy statement in conjunction with the SMS program. – Linking safety policy objectives to measurable goals and metrics provides manage- ment the ability to report on SMS program activities and progress.

4 – Safety risk management is facilitated by the development of various topic-related safety risk assessments (SRAs). – Airports are conducting SRAs outside the specific context of SMS pilot studies. SRAs are developed and managed by a broad range of personnel with subject matter expertise. – Expansion of the SMS program to the terminal and landside operations might be con- sidered in addition to the movement and nonmovement areas as the SMS program is being designed and developed. – Conducting a program audit in Year 1 can be challenging. Performing a program evaluation where incremental milestones have been achieved may be of greater use to management, especially with regard to assessing SMS policy objectives and goals. – Data collection and use as part of the safety assurance component of the airport SMS is being addressed by airports using fit-for-purpose solutions, such as commercial off-the-shelf software, custom application development, and paper-based systems. Data collection at some airports currently includes, or is planned to include, the landside and terminal areas for continuity of management and reporting. – Data collection and trending are at the core of safety assurance and data collection solutions vary depending on airport size and SMS program scope. – Training programs are scalable to each airport and operation, including staff skills development, based on positions and additional duties assigned. – Staff buy-in and reluctance to change can affect implementation of a SMS; early activities, such as direct communication and training, are documented means to pro- mote SMS. • SMS Challenges and Benefits. Airports participating in the FAA pilot studies found that there were challenges to SMS implementation as well as many benefits. Twenty- four of the 26 airports participating in the Synthesis survey reported they would con- tinue to pursue SMS implementation. Some airports indicated they were waiting for regulatory requirements to start implementation and to assign staff and budgets, but others, especially the 14 airports participating in the final SMS implementation study (Study 4), noted that they were underway and would continue to refine the SMS pro- gram in the upcoming year. Many airports also stated that they were allowing for addi- tional time and effort to possibly revise the current SMS program at the time the FAA Rule is finalized. Airports reported benefits and challenges including the following lessons learned: – Airports are awaiting additional resources and forthcoming SMS guidance from FAA. – Improved communication, increased safety awareness, integration of disparate departments and staff through collective assessment of risk and budgets, and data collection and trending analysis to provide a higher level of awareness are reported as benefits of the SMS pilot studies.