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

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29 BACKGROUND The ACRP Guidebook defines safety policy as, “the funda- mental approach to managing safety that is to be adopted within an organization. Safety policy further defines the orga- nization’s commitment to safety and overall safety vision” (Ayers et al. 2009). The FAA states that “Safety Policy pro- vides 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). At the heart of a SMS is the safety policy component that guides and commits the organization, its staff, and tenants to safe operations. Safety policy includes numerous elements and functions including development of a safety policy statement, which is often comprised of a mission, a vision, core values, and is backed by quantifiable SMS objectives or goals. Addition- ally, the safety policy component works in conjunction with the identified roles and responsibilities of the assigned SMS staff to ensure accountability at all levels of the organization. The FAA NPRM further indicates that “This proposal [NPRM] would require a certificate holder to establish a safety policy that • Identifies the accountable executive; • Identifies and communicates the safety organizational structure; • Identifies the lines of safety responsibility and account- ability; • Establishes and maintains a safety policy statement; • Ensures the safety policy statement is available to all employees; • Establishes and maintains safety objectives; and • Establishes and maintains an acceptable level of safety for the organization” (FAA 2010). Because it guides and frames the entire SMS, safety policy was a critical component in each of the FAA SMS pilot studies and a safety policy statement was required for each partici- pating airport as part of the creation and revision of its SMS manual. Airports were interviewed and surveyed to under- stand the process and scope used in implementing the safety policy component (such as identifying and documenting staff roles and responsibilities within the SMS manual) as well as the contents, specificity, distribution, and publication of the safety policy statement and the extent to which it was or will be tied to other SMS components, such as safety assurance. CHAPTER CONTENTS This chapter presents findings related to the development and implementation of a safety policy statement and safety objectives at SMS pilot study airports. Survey findings for management commitment and responsibility and staffing and assignment of duties (also associated with the safety policy component) are presented in chapter two. FINDINGS AND ANALYSIS Airports were asked a number of questions relating to the approval, publication, and distribution of the safety policy statement as part of the four FAA SMS pilot studies. Policy Deployment and Approval Airports were asked whether an approved safety policy statement was in place at their airports (Figure 13). Sixteen airport respondents indicated “yes,” nine replied “no,” and one answered that the safety policy statement was “being developed.” Some airports commented that the term “policy” was not used because of local regulatory or governmental limitations. Terms such as “safety statement” and “safety commitment” were used in place of “safety policy” to comply. Also, safety policy statements were developed by various means and methods, including some that were developed by committees and boards and others by individuals such as safety managers and reviewed by top management. Most safety policy statements averaged approximately one page in length. The 16 airports with approved safety policy statements were asked who or what entity approved the policy. A broad array of responses included CEOs, boards, counties, direc- tors, and presidents. No significant trends were noted except that all approving agencies appear to be at the highest level of authority within the organization. A list of approving agen- cies or individuals is presented in Table 20. Policy Staff and Tenants For many airports the approved safety policy statement has been shared only with internal staff. As presented in Figure 14, airports were asked whether the safety policy statement had been shared with staff and/or tenants. Of the airports that have safety policies in place, seven airports responded to chapter three SAFETY MANAGEMENT SYSTEM AND SAFETY POLICY

30 that a safety policy statement was shared with both staff and tenants, six airports responded that the safety policy state- ment was shared internally, and three airports indicated that the safety policy statement was not published. Nine airports responded that there is currently no safety policy statement in place. Comments regarding internal versus external pub- lication of the policy included that airports had initiated the SMS program internally first (staff only) and were planning to include tenants in the future as the external program was rolled out. Routes or distribution means to share the policy included all-hands meetings, safety meetings, e-mails, training sessions, and formal posting of the safety policy statement in staff and tenant areas. Policy and Objectives Included in many safety policy statements are associated program objectives; typically these objectives are measured as part of the SMS safety assurance program through perfor- mance metrics to ensure the program is on track. The airports participating in the SMS studies were asked whether pro- gram objectives were set as part of the safety policy statement development process. As presented in Figure 15, eight airports reported safety objectives were included in the safety policy statement, nine replied that objectives were not included in the safety policy statement, and nine indicated that they did not have a safety policy statement in place. Correlating this information with the number of airports with approved safety policy statements (16), the survey results indicate that only eight of the 16 airports included safety objectives in their safety policy statements, and the remaining eight had not. Because the airports were not asked why the safety policy statement did not include objectives, it is unclear as to whether the airport has no SMS safety objectives or the objectives are identified and tracked in another document or program than the safety policy statement. Additional questions regarding safety policy objectives were discussed as part of the SMS safety assurance component presented in chapter five. LESSONS LEARNED Safety Policy Statement Development Because of the diverse city, county, authority, and state air- port management structures, safety policy statements were developed and approved through various official processes and functions. Lesson Learned: The method to develop and deploy a safety policy statement requires various approval processes depend- ing on the airport management structure. Airport safety pol- icy development includes investigating the proper route and FIGURE 13 Approved safety policy statement in place. Class Approving Agency/Person Class I Written by the county and approved by the county council Class I Airport Commission Class I Chief Executive Officer (CEO) Class I Senior staff Class I Executive Director/CEO Class I Deputy Administrator of Airports will approve policy Class I Airport Board Class I Board and CEO at a public meeting Class I Accountable Executive/Responsible Executive Class I Airport Authority Board Class I Deputy Director of Operations Class I Airport Director Class II Airport Director Class II Airport Manager Class IV President Class IV Aviation Director Class IV Airport Board Class IV Speedway Organization TABLE 20 APPROVERS OF SAFETY POLICY STATEMENTS

31 approval function early in the SMS program to ensure that adequate time is allocated. Safety Policy Statement Deployment Various means to publish and distribute the safety policy state- ment were discussed during the interview process, including rolling out the policy during all-hands and tenant meetings. Some airports posted the policy in both staff and tenant areas as a reference; other airports published the policy on the airport or city websites. Lesson Learned: Deployment of the safety policy is unique to each airport’s internal and external communication paths. Some airports develop a communication plan to roll out the safety policy statement in conjunction with the SMS program. Safety Policy and Objectives Safety policy objectives were not included in every imple- mentation’s safety policy statement or documentation. Some airports may have separated the objectives into other SMS program documentation. Lesson Learned: Linking safety policy objectives to mea- surable goals and metrics provides management the ability to report on SMS program activities and progress. FIGURE 14 Safety policy statement published to staff and/or tenants. FIGURE 15 Policy mapped to objectives.