A Regulator`s Perspective - Flight Safety Foundation

Report
Building and Implementing a Robust
Safety Management Framework
- A Regulator's Perspective
FAA
August 2013
Michael Daniel, PMP
Senior Manager (Retired)
Proud Member Flight Safety Foundation
Overview
◢
What SMS is to Regulators
◢
What Regulators Are Applying
◢
What Service Providers Should Do
◢
FAA & EASA on SMS
◢
Recommendations
Risk Uncertainty Premises
1. There are known knowns; there are things
we know that we know
2. There are known unknowns; meaning, there
are things that we now know we don’t know
3. There are also unknown unknowns; there
are thing we do not know we don’t know
2
Raising The Bar
ICAO Safety Management Framework
Annex 19 reinforces the role played by States in managing aviation
safety, stressing the concept of overall safety performance in all domains
in coordination with service providers.
Policy
WHAT IS
REQUIRED
Principles
Gravitas
Procedures
ACTIONS TO
BE TAKEN
Accountabilities
WHO IS
RESPONSIBLE
HOW IS IT
ACHIEVED
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The Evolving Annex 19
 Recommendations for Amendment to Annex 19
- Due 4 Quarter 2014
 Guidance material due in 2014 and 2016
 States need to file differences by October 2013
4
Safety Management Manual (Doc 9859 3rd Ed)
Restructured according to the SSP and SMS frameworks. Its
Objective is to provide States and Product/Service providers
with:
• An overview of accepted safety management fundamentals.
• A summary of ICAO SARPs.
• Guidance on the ICAO harmonized State Safety Programme
(SSP) framework and its implementation and operation.
• Guidance for product and service providers on Safety
Management System (SMS) framework and its implementation
and operation. (i.e. SMS Policy, SMS Manager Position,
Sample PD’s, Gap Analysis)
5
The Regulator: Change in Role and Position
State Safety Plan (SSP):
 Responsible for regulations
 Responsible for periodic or special on-site audits of the SMS
including verification of procedures
Basic Role of the Regulator:




To agree key safety standards and principles
To ensure national standards meet international
To resist unacceptable shortcuts to safety
To ensure service providers have appropriate
safety measures in place (including SMS)
 To monitor overall safety performance
 To ensure implementation of remedial actions
6
Regulator Basic Expectations of Safety Management
•A structured means of safety risk management decision
making
•A means of demonstrating safety management capability
before system failures occur
•Increased confidence in risk controls though structured
safety assurance processes
•An effective interface for knowledge sharing between
regulator and certificate holder
•A safety promotion framework to support a sound safety
culture
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The Regulator(s) Can Present Several Challenges to The Service Provider
Examples of Different Regulator Applications:
 Requiring Two Accountable Managers
 Not Designating an SMS Manager for Large
Organizations
 Performing SMS Audits (On-Site)
 Not Performing Audits
 Approving SMS Manuals
 Accepting SMS Manuals
 Accepting Manuals Approved by Other Authorities
 Requiring SMS as part of QMS
 Not Requiring or Enforcing SMS
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The Regulator’s Enforcement Policy – Disclosure of
Safety Data
Does the SSP enforcement policy
include provision to protect the sources
of information obtained from voluntary
incident reporting systems? [3.4.8(d);
App 3; App 11]
And De-conflict Enforcement Policies with Accident/Incident Policies!
9
Role of the Safety Manager: What are the Regulators Requiring?
Is it Safety or Quality? At What Level?
Quality and Safety Management Key Points
 QMS and SMS – Common Methods and Techniques, but different Objectives:
• QMS Objective is Customer Satisfaction
• SMS Objective is Aviation Safety Focused
 Not required to have a QMS, but if an entity does have one, it cannot conflict
with SMS
"It is how the tools and techniques are used, along with a focus on
investigation of events, which makes the quality and safety
management systems different. The quality systems do not investigate
incidents or accidents for risk assessment. Quality systems audit
output of a process only for variance, and makes adjustments. SMS
investigates events, looking for contributing factors from all influencing
sources."
Source: "Flight Safety Information February 12, 2010 No.034
10
What Service Providers Should Do ?
Service providers should demonstrate a proactive and
systematic approach to its stakeholders
Provide comments suggestions to ICAO, Regulators,
Associations The use by industry of SMS is an increasingly
necessary basis for fulfilling service-providers’ safety
responsibilities.
Service Provider:
 Responsible for ensuring safety
 Responsible for complying with SARPS
 Responsible for showing to the Regulators that
they are managing safety
 Group Consensus Collaboration
 Use Industry Tools (i.e. CAST – Safety
Enhancements
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What the FAA is doing




12
1 State Safety Program (SSP) Overview
2 FAA SMS Overview
3 FAA SMS and the Aviation Industry
4 International Collaboration
What the FAA is doing
13
USA SSP
The US FAA responsibilities include most of SSP
requirements.
Other US government organizations, such as
National Transportation Safety Board (NTSB), will
also need to be included in the US SSP
USA meets the intent of most of ICAO SSP
requirements (i.e. ATOS, VDRP, FOQA)
 Differences Filed!
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Additional SSP Activities
USA elected to further enhance SSP by
incorporating SMS concepts into:
 Joint Planning and Development Office (JPDO)
SMS Standard
 Department of Transportation (DOT) SMS
Guidance
 FAA SMS Policy and Guidance
 Office of Aviation Safety (AVS) SMS
Requirements Order
 Office of Rule Making SMS Order
 FAA AVS and Airports SMS rulemaking
activities
15
FAA SMS Overview
16
17
FAA SMS Order
18
FAA Risk Management
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How the FAA Regulators Will Approach Safety Oversight
20
21
Pilot Projects
New FAA Part 5 Pending Issuance In executive coordination at this point and
with Office of Management & Budget OMB
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23
Safety Management International Collaboration Group (SM ICG)
• Purpose: to promote a common understanding of safety management principles and
requirements, facilitating their application across the international aviation
community
– Collaborate on common SMS/SSP topics of interest
– Share lessons learned
– Encourage the progression of a harmonized SMS
– Share products with the aviation community
– Collaboration with international organizations such as ICAO and civil aviation
authorities
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25
SM ICG Products and Outputs
• Harmonized SMS requirements and safety oversight
processes and measures
• Guidance material for regulatory authorities and industry
• Standard terminology and hazard taxonomy
• Knowledge sharing between authorities
SM ICG Areas of Focus
Documentation Best practices
Guidance and tools for industry and other authorities
Safety behaviour assessment tools
Training and promotion material
Measurements Safety performance measurement framework
Methodology for setting safety performance expectations (SMS and SSP)
Process for identifying risk acceptance/thresholds within safety risk management
(SRM)
Standardization Common taxonomy for hazards
Data analysis and sharing processes
Comparison and alignment of international SMS and SSP terminology
Others Data sharing
State Safety Programme
Cost and benefits
Manufacturer requirements (challenges/questions regarding Annex 8)
26
FAA & EASA SMS Requirements for Foreign Operators?
 FAA can only apply SMS provisions to Foreign Operators under
FAR Part 129.
 SMS requirements can only applied to the level of FAA compliance
to ICAO SARPs.
 Currently Not in FAA IASA Program
Regulation (EC) No 216/2008 and Part-TCO
EASA Third Country Evaluation Phase
For operators in category A, the process will consist of a straight-forward
desktop file review. Operators who have been grouped into categories B and C
are required to provide additional information online including at least:
- compliance statements with a set of selected ICAO SARPS, including
references to the applicant’s operations manual;
- additional information that will enable the Agency to prepare for the
assessment in the areas airworthiness, operations and safety management;
- a statement of the competent authority of the applicant confirming that all
information is true and correct
Basic Viewpoint “Equivalent Level of Safety”
27
12/JUL/2013: EASA Committee votes favourably on the EASA TCO
proposal. The meeting of The EASA Committee took place in
Brussels from Wednesday 10 to Friday 12 July, during which the
proposal for a Commission Regulation on Third Country Operators
(TCO) was adopted. The proposal will now undergo European
Parliament and European Council scrutiny, and its final adoption
and publication by the European Commission is expected before
the end of 2013.
And Other Authorities?
- It may vary from requiring IATA IOSA
Registration to having an Authority Approved
Safety Management Program
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With Reference to EASA SSP
29
Some Recommendations
◢ 1st Conform with Home Authority’s SMS Reqmts.
◢
Have strong policy statement driven (ICAO template)
◢
Perform Continual Gap and SWOT Analysis
◢
Provide comments suggestions to ICAO, Regulators,
Associations, SM ICG
◢
Have strong internal SMS audit program
◢
Third party audits on occasion
and
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Structure in SMS Vertical Alignment
International
Standards
Corporate
Policy
Department
Alignment
Head of Section
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• ICAO International Standards (Annex 19)
• Regulatory Safety Requirements
• Corporate Policy
• Aligned CEO/Accountable Manager Statement
• Organization Department Safety/Position Description Alignment
• Processes-Procedures Alignment
• Head of Section Safety/Position Description Alignment
• Procedures/Forms-Template/Task Alignment
SMS Effectiveness Realization
E
f
f
e
c
t
i
v
e
n
e
s
s
Expected Effective Implementation
2009
SMS ICAO Standard
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New Annex 19
Useful Links
http://www.skybrary.aero/index.php/Main_Page
http://www.aviation-insight.aero
Michael Daniel, PMP
FAA
Senior Manager (Retired)
[email protected]
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