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

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5 According to the FAA 2010 Annual Runway Safety Report, “the FAA is responsible for the oversight and regulation of the world’s most advanced and safest aviation system” and “the FAA is responsible for the largest and most complex National Airspace System in the world” (FAA 2010). FAA cites strong aviation partnerships and collaboration as a foundation on which safety is maintained. A variety of ini- tiatives including advanced technologies, training, human factors, and nonpunitive reporting are currently underway within the United States to improve aviation safety. The International Civil Aviation Organization (ICAO) Council (of which the United States is a member) adopts standards and provides direction and recommendations for air transportation worldwide. In 2001, ICAO introduced Standards and Recommended Practices for Aerodrome Safety Management, and in November 2005, ICAO amended Annex 14, Volume I (Aerodrome Design and Operations) to require contracting states to establish a safety management system (SMS). According to FAA’s Notice of Proposed Rule- making (NPRM), [it] “supports conformity of U.S. aviation safety regulations with ICAO standards and recommended practices. The agency intends to meet the intent of the ICAO standard in a way that complements existing airport safety regulations in 14 CFR Part 139” (FAA 2010). Consequently, the United States, as a contracting state within ICAO, initiated SMS rulemaking efforts for certifi- cated airports under 14 CFR Part 139. In September 2008, FAA mandated SMS development within its own lines of business, including the Air Traffic Organization, Office of Aviation Safety, and Office of Airports through FAA Order 8000.369, Safety Management System Guidance. SAFETY MANAGEMENT SYSTEM DEFINED As described in the Advisory Circular (AC) 150/5200-37, SMS is the formal, top-down business-like approach to man- aging safety risk (FAA 2007). It includes systematic proce- dures, practices, and policies for the management of safety (including safety policy, safety risk management, safety assurance, and safety promotion). More specifically, a SMS program is a systematic, comprehensive process for manag- ing safety risks. The SMS sets goals, implements policies, develops processes, and tracks and measures performance. It concerns itself with organizational safety rather than strictly conventional health and safety issues at work. SMS defines how an airport intends to manage safety as an integral part of its business management activities. The functional result of a SMS is to proactively manage risk, detect and correct safety problems before those problems result in an accident or inci- dent, and reduce the impact and cost of incidents (FAA 2007). According to ICAO, an SMS can be likened to a toolbox that contains the tools that an aviation organization needs in order to be able to control the safety risks of the consequences of the hazards it must face during the delivery of the services for which the orga- nization is in business. It is important to acknowledge that an SMS itself is neither a tool nor a process. An SMS is the toolbox, where the actual tools employed to conduct the two basic safety management processes (hazard identification and Safety Risk Management) are contained and protected. What an SMS does for an organization is to provide a toolbox that is appropriate, in size and complexity, to the size and complex- ity of the organization (ICAO 2009). ICAO further explains that an SMS aims to make continuous improvements to the over- all level of safety of an organization. An SMS is a constant, never-ending operation that aims at maintaining and, if pos- sible, improving safety levels that are commensurate with the organization’s strategic objectives and supporting core busi- ness functions. In this sense, an SMS is profoundly different from the traditional notion of accident investigation, which waited for an accident to occur, then extracted and distributed as many safety lessons as possible learned from the investiga- tion in order to prevent similar accidents. An SMS actively looks for hazards, continuously assesses safety risks, to con- tain them before they result in an accident (ICAO 2009). SMS is comprised of four key components (described as pillars in ICAO documentation): safety policy, safety risk management, safety assurance, and safety promotion. A brief overview of the four SMS components is presented here. Safety Policy FAA states in the 2010 NPRM that “Safety Policy provides the foundation or framework for the SMS. It outlines the methods and tools for achieving desired safety outcomes. Safety Policy also details management’s responsibility and accountability for safety” (FAA 2010). Fundamentally the safety policy serves as the overarching guide to the SMS and chapter one INTRODUCTION

6 includes the development of the oversight and objectives of the SMS program, including top management’s commitment to safety for staff. Policy also includes roles and responsi- bilities for the safety manager and accountable executive and other collateral duties performed by staff, as well as a defini- tion of duties for safety committees and their participants. Safety Risk Management FAA defines safety risk management (SRM) as “a core activ- ity of SMS. SRM uses a set of standard processes to pro- actively identify hazards, analyze and assess potential risks, and design appropriate risk mitigation strategies” (FAA 2010). At the core of a SMS is the ability to collect informa- tion on hazards, identify and quantify the associated risks through severity and likelihood, and determine the corrective action (if any). Risk analysis may be conducted by a variety of subject matter experts who weigh in on the potential risk scenarios, typically using an organizationally developed risk matrix. Either individually or as a group, risks are ranked and recorded for resolution, monitoring, and reporting. Safety Assurance FAA defines safety assurance as “a set of processes that monitor the organization’s performance in meeting its cur- rent safety standards and objectives as well as contribute to continuous safety improvement. Safety assurance processes include information acquisition, analysis, system assess- ment, and development of preventive or corrective actions for nonconformance” (FAA 2010). Safety assurance essen- tially serves as a checks-and-balances system to ensure that SMS processes and procedures and risk mitigation strategies are having their intended effect. Safety Promotion According to FAA, “safety promotion includes processes and procedures used to create an environment where safety objectives can be achieved. Safety promotion is essential to create an organization’s positive safety culture. Safety cul- ture is characterized by knowledge and understanding of an organization’s SMS, effective communications, competency in job responsibilities, ongoing training, and information sharing” (FAA 2010). A successful SMS includes a struc- tured method to communicate safety-related information to staff and tenants. This communication can take on multiple forms, such as posters, meetings, alerts, safety fairs, safety exhibits, and so forth. According to ICAO, the two SMS core components of safety risk and safely assurance take place under the umbrella provided by Safety Policy and objectives and are supported by safety promotion. These two components [Safety Risk and Safely Assurance] of an SMS encompass the necessary organizational arrangements with- out which hazard identification and Safety Risk Management would be impossible, or seriously flawed. It can therefore be considered that Safety Risk Management and Safety Assurance are the actual “doing” of SMS; they are the operational activities underlying a performing SMS. Safety policies and objectives and safety promotion, on the other hand, provide the frame of reference as well as the support that allow the operational activities underlying Safety Risk Management and Safety Assurance to be effectively con- ducted (ICAO 2009). RULEMAKING AND SAFETY MANAGEMENT SYSTEM PILOT STUDY ACTIVITIES In February of 2007, FAA initiated a rulemaking action to consider an amendment to Part 139, Certification of Airports, as well as AC 150/5200-37 entitled Introduction to Safety Management Systems for Airport Operators. The proposed rulemaking requires certificated airports to implement a SMS consistent with the ICAO Annex 14 requirement. The NPRM further states that In a new §139.402, the FAA would require each airport SMS to include the four SMS components: Safety Policy, SRM, Safety Assurance, and Safety Promotion. To support each of these components, the FAA proposes a certificate holder implement a number of elements. Together the components and elements provide the general framework for an organization-wide safety management approach to airport operations. To make these components and elements effective, a certificate holder would develop processes and procedures appropriate to the airport’s operating environment. The FAA understands that a certificate holder could comply with these requirements through a variety of means (FAA 2010). To gain specific insight and information relating to the inte- gration of SMS into the broad range of Part 139 certificated airports throughout the United States., FAA launched a series of SMS pilot studies commencing in 2007 and concluding in early 2012. A total of 31 airports of varying size, location, and operations participated in four individual SMS pilot studies since 2007 (see Table 2 for details regarding airport partici- pation). The FAA initiated the first SMS pilot study in 2007, which focused on (a) conducting a gap analysis to assess SMS integration into the airport’s Part 139 operations and (b) developing a draft and final SMS manual and SMS pro- gram plan. Grant funds were made available to 20 airports and 22 airports participated in the study. The first SMS pilot study was completed in 2008. FAA noted that this initial SMS pilot study was dominated by Class I airports, and in mid-2008 a second SMS pilot study was launched and limited to Class II, III, and IV airports; a total of nine airports participated. The second SMS pilot study was completed in 2010. In addition to the second round of SMS pilot studies, FAA invited three air- ports to conduct a follow-on/proof-of-concept study to “prove out” a series of tasks and SMS projects to gain a better under- standing of the complexities and interoperability of the SMS program and Part 139 airports. The follow-on SMS study, including three airport participants, was completed in early

7 2010. Finally, FAA offered a SMS implementation study in later 2010 to airports who participated in any of the prior SMS pilot studies. A total of 14 airports participated in the SMS implementation study and all programs were scheduled to be completed in early 2012. Detailed information for each of the studies is presented in Appendix C. SAFETY MANAGEMENT SYSTEM PILOT STUDY FINDINGS AND DOCUMENTATION To date, limited documentation of specific, compiled, or trended results associated with the SMS pilot studies is avail- able. In October 2008, a presentation by FAA was delivered at the AAAE/MITRE/ACI-NA Safety Management Systems for Airports Conference in Baltimore, Maryland. The presenta- tion provided a summary of findings from the first SMS pilot study; however, no formal data analysis was conducted and the report focused on key trends collected from the partici- pating airports. In May 2011, the FAA released the Technical Report on Airport Safety Management Systems (SMS) Pilot Studies (FAA 2011), which included a compiled summary of written surveys and interviews with 25 of the SMS pilot study airports. The document provided few summaries or trends and focused on compiling interview responses from airport repre- sentatives. In early June 2011, FAA posted a number of SMS pilot study airport documents to the Federal Docket Manage- ment System (Docket) and subsequently to the FAA’s SMS for implementations website. The documents included gap analy- ses and checklists, SMS manuals, and other relevant resources considered useful to airport operators as a reference library. On October 7, 2010, FAA released the NPRM Safety Management System for Certificated Airports (75 FR 62008) and, as such, requested comments from industry and airport operators through the Federal Docket Management System. Comments were initially due on or before January 5, 2011. The date was revised first to March 7, 2011, and extended a second time to July 5, 2011. In addition to NPRM comments, FAA requested formal submittal of clarifying questions to be delivered to the Docket by April 6, 2011. Responses to the clarifying questions were published on May 21, 2011. The timeline presented in Figure 1 provides a summary of key dates and SMS pilot study durations. The timeline end date coincides with the end of FAA’s SMS implementation study in early 2012. SYNTHESIS STUDY APPROACH AND OBJECTIVES The objective of this ACRP Synthesis study is to provide a structured report of findings from the 31 airports that par- ticipated in the FAA’s SMS pilot studies (SMS studies) to present airports’ experiences and lessons learned. Although intended for certificated (Part 139) airports, the results may be helpful to all airports. This report is comprised of eight chapters: Chapter One—Introduction, Chapter Two—Safety Management System Pilot Study Program Management, Chapter Three—Safety Management System and Safety Policy, Chapter Four—Safety Management System and Safety Risk Management, Chapter Five—Safety Management System and Safety Assurance, Chapter Six—Safety Management System and Safety Promotion, Chapter Seven—Safety Management System Challenges and Benefits, and Chapter Eight—Conclusions. FIGURE 1 SMS pilot study timeline.

8 The approach to data collection included development of an interview preparation document including a description of the synthesis objectives and a questionnaire comprised of 36 questions (see Appendix B). It was concluded that using an online or written survey instrument for the study would limit the project findings and constrain the ability to ask for clarification or discuss specific aspects of the responses. The preparation document was sent to all 31 SMS pilot study implementations by e-mail and included a schedule of avail- able interview times and dates. Airport representatives con- firmed availability and sessions were scheduled accordingly. All interviews were conducted by a minimum of two study members to facilitate the interview process; one posed the questions and the other captured interview notes electroni- cally. All notes were consolidated into a master database, standardized, de-identified, sorted, and trended and are pre- sented in this document. Of the total 31 airports in the sur- vey group, 26 were interviewed either by phone or in person, resulting in an 84% response rate. Table 1 provides a sum- mary of Synthesis surveys and interviews by each SMS pilot study airport representative and by class size. Table 2 provides a detailed list of airports that partici- pated in the FAA SMS studies, including a cross-referenced indication of which airports were interviewed as part of the Synthesis study. To support the interviews conducted, a focused literature search was performed using various indus- try, Internet, and publication resources. Source documents focused largely on U.S. resources to ensure that a Part 139 perspective and relevance were maintained. The literature search included a review of implementation SMS-related documents available on the FAA’s public website. Although not a part of the FAA studies, three Canadian airports were interviewed (all Class I equivalents) using the same set of questions to guide the discussion. The Canadian airports were selected based on size, location, and SMS implementation status. In 2005, Transport Canada, which certifies and regulates all airports in Canada, initiated an aviation-wide SMS program. Certain airports (with a cer- tificate issued under Section 302.03) began implementation in 2008 and are in the final phases of SMS implementation. Because U.S. airports are in the early stages of implementa- tion, the Canadian airport perspective (albeit a small survey group) was considered useful to provide a more thorough analysis of later stages within the implementation process. A summary of findings from Canadian interviews is presented in Appendix A. Canadian survey results are not included in the U.S. airport findings to ensure that an accurate reflection of SMS pilot study airport responses is presented. LITERATURE AND DATA SEARCH In the early stages of the SMS pilot study programs, few SMS resources were available to U.S. implementations; however, in the past 4 years a number of key documents have been authored, updated, and published to assist airports in developing a SMS program. As part of the Synthesis study interviews, airports were asked to provide a list of documents used to develop their SMS. The list of documents and links are presented in Table 3 and sorted alphabetically by organization or agency. Additional industry resources were included to supplement the surveyed list of references. Additional information regarding an airport’s reported most useful document is located in chapter two and a formal biblio graphy and list of references are provided. An additional set of resources available to airports develop- ing their SMS program includes a series of documents provided by SMS pilot study implementations to the FAA as part of their SMS pilot study deliverables. The types of documents submitted Description—Airports Surveyed by SMS Pilot Study Percentage Surveyed Yes No Total in Study Surveys Study 1 Airports Surveyed 90 20 2 22 Study 2 Airports Surveyed 66 6 3 9 Study 3 Airports Surveyed 100 3 0 3 Study 4 Airports Surveyed 100 14 0 14 Total of Study Airports Surveyed 84 26 5 31 Description—Airports Surveyed by Class Size Percentage Surveyed Yes No Total in Study Surveys Class I Airports Surveyed 90 18 2 20 Class II Airports Surveyed 100 3 0 3 Class III Airports Surveyed 0 0 2 2 Class IV Airports Surveyed 83 5 1 6 Total of Class Size Airports Surveyed 84 26 5 31 TABLE 1 SMS PILOT STUDY AIRPORTS PARTICIPATING IN SYNTHESIS STUDY SURVEYS

9 TABLE 2 AIRPORT SMS PILOT STUDY LIST OF AIRPORTS AND INTERVIEW STATUS No. Airports in Pilot Studies Airport ID Service Level Class State Study 1 Study 2 Study 3 Follow on Study 4 Implementation Interviewed 1. Atlanta—Hartsfield Atlanta International ATL Large Hub Class I GA X X Yes 2. Austin–Bergstrom International AUS Medium Hub Class I TX X No 3. Baltimore– Washington International BWI Large Hub Class I MD X Yes 4. Boeing Field BFI Non- Hub Class II WA X Yes 5. Cheyenne Regional CYS Non- Hub Class II WY X X Yes 6. Concord Regional JQF Reliever Class IV NC X X Yes 7. Dallas/Fort Worth International DFW Large Hub Class I TX X X Yes 8. Daytona Beach DAB Non- Hub Class I FL X Yes 9. Detroit Metro– Wayne County DET Large Hub Class I MI X Yes 10. Dubuque Regional DBQ Non- Hub Class I IA X X Yes 11. Fort Worth Alliance AFW Reliever Class IV TX X Yes 12. Indianapolis International IND Medium Hub Class I IN X X Yes 13. Jackson Municipal JAN Small Hub Class I MS X Yes 14. Jacksonville International JAX Medium Hub Class I FL X X Yes 15. Kona International at Keahole KOA Small Hub Class I HI X Yes 16. Lexington—Blue Grass LEX Small Hub Class I KY X Yes 17. North Las Vegas VGT Non- Hub Class III NV X No 18. Ohio State University OSU Reliever Class IV OH X X Yes 19. Pittsburgh– Allegheny County PIT Medium Hub Class I PA X X Yes 20. Sacramento International SAC Medium Hub Class I CA X Yes 21. San Antonio International SAT Medium Hub Class I TX X X Yes 22. Santa Maria Public SMX Non- Hub Class I CA X No 23. Seattle–Tacoma International SEA Large Hub Class I WA X X X Yes 24. Show Low Regional SOW Non- Primary Class III AZ X No 25. Sloulin Field ISN Non- Hub Class II ND X Yes 26. South Bend Regional SBN Non- Hub Class I IN X X X Yes 27. Southern Illinois– Carbondale MDH GA Class IV IL X X Yes (continued on next page)

10 TABLE 2 (continued) 29. Tallahassee Regional TLH Small Class I FL X X Yes No. Airports in Pilot Studies Airport ID Service Level Class State Study 1 Study 2 Study 3 Follow on Study 4 Implementation Interviewed 30. Teterboro TEB Reliever Class IV NY X No 31. Toledo Express TOL Non- Hub Class I OH X X Yes Total Airport Count (By Study) 22 9 3 14 *Note: Talladega Municipal is no longer a Part 139 Class IV Certificated Airport; however, Synthesis study survey results are compiled with other Class IV airports. SMS Pilot Study Key Study 1—All Class Size Gap, Program Plan, and SMS Manual Study 3—Follow-on/Proof of Concept Study 2—Limited to Class II, III, and IV Gap, Program Plan, and SMS Manual Study 4—Implementation 28. *Talladega Municipal ASN GA NA AL X Yes TABLE 3 SMS RESOURCES No. SMS Documents/Resources/References Organization/Agency Link or ISBN 1. SMS Webinar, Presentations, Meetings Airport Consultants Council http://www.acconline.org 2. Report 1, Safety Management Systems for Airports ACRP http://www.trb.org/Publications/Blurbs/159030.as px 3. Report 1, Safety Management Systems for Airports, Volume 2: Guidebook ACRP http://www.trb.org/Publications/Blurbs/162491.as px 4. Various Meetings, Presentations, Seminars, Webinars, Papers regarding SMS Airports Council International–North America http://aci-na.org/ 5. Various Meetings, Presentations, Seminars, Webinars, Papers regarding SMS American Association of Airport Executives http://www.aaae.org/ 6. Safety Management Systems Website (Various Resources) Australian Civil Aviation Safety Authority http://www.casa.gov.au/scripts/nc.dll?WCMS:ST ANDARD::pc=PC_91430 7. Bangalore SMS Manual Bangalore International Airport http://fsfi.avia.ru/sem/subp/A.2.9BIALSMSManu alEngl.pdf 8. Implementing Safety Management Systems in Aviation Burlington, VT: Ashgate. Stolzer, A.J., Halford, C.D., and Goglia, J.J. (2011) ISBN: 978-1-4094-0165-0 9. Safety Management Systems in Aviation Burlington, VT: Ashgate. Stolzer, A.J., Halford, C.D., and Goglia, J.J. (2008) ISBN: 978-0-7546-7304-0 10. Documents from Multiple Canadian Airports Canadian Airport Council http://www.cacairports.ca/english/ 11. AC 150/5200-37, Introduction to Safety Management Systems for Airport Operators FAA http://www.faa.gov/airports/resources/advisory_c irculars/index.cfm/go/document.current/documen tNumber/150_5200-37 12. FAA Order 5200.11, FAA Airports (ARP) Safety Management System FAA http://www.faa.gov/regulations_policies/orders_n otices/index.cfm/go/document.current/document Number/5200.11 13. FAA Order 8000.369, Safety Management System Guidance FAA http://www.faa.gov/regulations_policies/orders_n otices/index.cfm/go/document.current/document Number/8000.369 14. FAA SMS Website (Various Resources) FAA http://www.faa.gov/airports/airport_safety/safety _management_systems/

11 are presented in Table 3 and are available on the FAA’s SMS for implementations website at the following address: http://www. faa.gov/airports/airport_safety/safety_management_systems/ external/pilot_studies/documentation/. The collected documents include SMS manuals, program plans, risk definitions and matrices, gap and audit checklists, safety policies, staff roles and responsibilities, data collec- tion strategies, legal references, and other relevant informa- tion developed from various airports. These shared resources provide SMS or program managers with samples of existing document formats, contents, and approaches. Table 4 includes service level and airport operating certificate class information for added reference and scalability of SMS program informa- tion collected. Of the 26 airports interviewed, three distinct groups were identified through interviews and analysis: 1. Airports that participated in the first, second, or third SMS pilot study and are implementing SMS within the SMS implementation study (14 airports); 2. Airports that participated in the first, second, or third SMS pilot study and are implementing SMS outside of the SMS implementation study (five airports); and 3. Airports that participated in the first, second, or third SMS pilot studies and are not implementing SMS (seven airports). Groups 1 and 2 are collectively referred to as “implemen- tation airports” and Group 3 is presented throughout this document as “nonimplementation airports.” All implementation SMS pilot study participants (with the exception of one nonfunded airport that had a preexist- ing SMS program in place) conducted a gap analysis and developed a SMS manual; therefore, the questions relating to the gap analysis and SMS manual and program plan develop- ment reflect both the implementation and nonimplementa- tion airport responses. Because the Synthesis study questions focused on implementation efforts, nonimplementation airports (seven) were unable to provide responses. In these cases, the Synthesis survey results focus solely on implemen- tation airports as defined previously. TABLE 3 (continued) No. SMS Documents/Resources/References Organization/Agency Link or ISBN 19. Safety Management Manual (SMM) Document 9859 ICAO http://www.icao.int/anb/safetymanagement/Docu ments.html 20. Managing the Risks of Organizational Accidents Human Error James Reason Various book vendors 21. Corporate Safety Plan Nav Canada http://www.navcanada.ca/ContentDefinitionFiles/ Publications/CorpPublications/AdditionalPublicat ions/SafetyPlan2010_2011_en.pdf 22. Fault Tree Handbook (NUREG-0492) (Chapter 1) Nuclear Regulatory Agency’s http://www.nrc.gov/reading-rm/doc- collections/nuregs/staff/sr0492/ 23. Voluntary Protection Program (VPP) Occupational Safety & Health Administration http://www.osha.gov/dcsp/vpp/ 24. SMS for Airports Web Site Transport Canada http://www.tc.gc.ca/eng/civilaviation/standards/s ms-menu-618.htm 25. The Army Safety Program—Regulation 385–10 U.S. Department of the Army http://www.apd.army.mil/pdffiles/r385_10.pdf 26. SMS Training Courses and Associated Manual University of Southern California Viterbi School of Engineering http://viterbi.usc.edu/aviation/courses/sms- mgr.htm 15. FAA Notice of Proposed Rulemaking, 14 CFR Parts 139 Safety Management Systems for Certificated Airports FAA http://www.gpo.gov/fdsys/pkg/FR-2010-10-07/pdf/2010-25338.pdf 16. AC No 120-92 Introduction to Safety Management Systems for Air Operators FAA http://rgl.faa.gov/Regulatory_and_Guidance_Libr ary/rgAdvisoryCircular.nsf/0/6485143d5ec81aae 8625719b0055c9e5/$FILE/AC%20120-92.pdf 17. Digest November-December 2005 Unlocking the Potential of a Safety Management System Flight Safety Foundation http://flightsafety.org/fsd/fsd_nov-dec05.pdf 18. International Air Transportation Association (IATA) Safety Training Courses IATA http://www.iata.org/training/pages/safety.aspx

12 Airport State Service Level Class Study Documents Provided by Airport Austin– Bergstrom International TX Medium Hub Class I Study 1 SMS Statement of Work Gap Analysis Draft SMS Manual SMS Manual Safety Risk Management Training Presentation Safety Risk Management Decision report template Baltimore– Washington International MD Large Hub Class I Study 1 SMS Manual Boeing Field WA Non- Hub Class II Study 2 SMS Manual Cheyenne Regional WY Non- Hub Class II Study 2 Study 4 Draft Risk Matrix Definition Draft Risk Analysis and Assessment Guidance Safety Risk Management Process Concord Regional NC Reliever Class IV Study 1 Study 3 SMS Implementation Plan Gap Analysis Draft SMS Manual SMS Manual Management Commitment (Safety Policy) Dallas/Fort Worth International TX Large Hub Class I Study 1 Study 4 SMS Statement of Work Detroit Metro– Wayne County MI Large Hub Class I Study 1 Gap Analysis SMS Manual Dubuque Regional IA Non- Hub Class I Study 1 Study 4 SMS Manual Volume 1 SMS Manual Volume 2 Fort Worth Alliance TX Reliever Class IV Study 2 SMS Gap Analysis Jacksonville International FL Medium Hub Class I Study 1 Study 4 Gap Analysis SMS Implementation Study SMS Manual Kona International at Keahole HI Small Hub Class I Study 1 Gap Analysis SMS Management Plan SMS Manual Sacramento International CA Medium Hub Class I Study 1 Gap Analysis Gap Analysis Matrix Injury and Illness Prevention Plan San Antonio International TX Medium Hub Class I Study 1 Study 4 Draft SMS Manual Santa Maria Public CA Non- Hub Class I Study 1 Gap Analysis SMS Draft Management Plan SMS Manual Seattle–Tacoma International WA Large Hub Class I Study 1 Study 3 Study 4 SMS Assurance Plan SMS Data Collection and System Review SMS Minimum Standards Nonpunitive Program and Legal Authority SMS Roles and Responsibilities Safety Policy Guide SMS Self-Inspection Program SMS Training and Orientation South Bend Regional IN Non- Hub Class I Study 1 Study 3 Study 4 SMS Monthly Progress Reports Safety Risk Assessment Report Safety Risk Assessment Documentation Southern Illinois IL General Aviation Class IV Study 1 Study 4 Gap Analysis SMS Risk Matrix SMS Manual Safety Risk Assessment Talladega Municipal AL General Aviation NA Study 2 Gap Analysis SMS Manual Source: http://www.faa.gov/airports/airport_safety/safety_management_systems/external/pilot_studies/documentation/, Extracted 04-01-2012. SMS Pilot Study Key Study 1—All Class Size Gap, Program Plan, and SMS Manual Study 3—Follow-on/Proof-of- Concept Study 2—Limited to Class II, III, and IV Gap, Program Plan, and SMS Manual Study 4—Implementation TABLE 4 AIRPORTS’ CONTRIBUTION OF SMS DOCUMENTATION TO FAA