U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
Flight Standards Service Oversight
This order provides guidance
for Flight Standards Service (AFS) staff and offices in meeting the requirements
specified in the current edition of Federal Aviation Administration (FAA) Order
revised), Safety Management System Guidance and Order
VS 8000.367 (as
revised) Aviation Safety (AVS) Safety Management System Requirements. It
describes AFS statutory responsibilities with respect to aviation safety oversight
and evolving system safety and Safety Management System (SMS) based initiatives.
These initiatives contribute to enhanced methodologies for managing risk and
improving safety in aviation. Additionally, this order discusses the incorporation
of system safety and is inclusive of SMS concepts into the future AFS oversight approach.
John M. Allen
Director, Flight Standards Service
1. Purpose of This Order. This order describes how the Flight
Standards Service (AFS) complies with the current editions of FAA Order
8000.369, Safety Management
System Guidance, and Associate Administrator for Aviation Safety (AVS-1) Federal Aviation Administration (FAA) Order
VS 8000.367, Aviation
Safety (AVS) Safety Management System Requirements. Order
8000.369 requires Aviation
Safety (AVS) services to incorporate safety management principles into FAA oversight of the U.S. aviation industry. Order
VS 8000.367 provides
specific requirements to apply these principles in AVS lines of business. In support of the AVS Safety Management System (AVSSMS)
guidance, this order does the following:
· Provides information for AFS divisions and offices in support
of the development of implementation plans and guidance based upon and consistent with Order
AFS divisions and offices will issue supplementary guidance, both internally and externally,
to implement the principles and provide direction to aviation product/service providers.
· Explains the principles
and requirements to guide the evolution of AFS oversight processes in a Safety Management System (SMS) environment.
· Standardizes terminology
for AFS oversight activity consistent with AVS guidance and appropriate to each of the constituent industry segments
and aviation activities under the oversight jurisdiction of AFS.
· Defines roles of AFS and the
industry, specifically with respect to the responsibility for managing risk and determining acceptable levels of safety.
2. Audience. The audience for this order is principally FAA AFS
personnel, including AFS divisions and branches at headquarters (HQ) and in
the regions. This order will have a more significant impact on those offices
that have direct responsibilities for developing policies and practices related
to the oversight of the aviation industry. This order will also provide useful
information for the U.S. aviation industry.
4. What This Order Cancels. This order cancels Order
8000.368, Flight Standards Service Oversight, dated July 11, 2008.
5. Authority to Change This Order. AFS-1 has the authority to issue and modify Order
8000.368, Flight Standards Service Oversight.
a. Process-Oriented Framework. This order establishes a process-oriented
framework that will assist in adapting AFS oversight to SMS principles. This
includes a foundation for industry and the FAA to analyze and determine acceptable
levels of risk. This order defines roles, responsibilities, and relationships
of AFS elements with the industry and emphasizes the continuing importance of
a strong safety culture within AFS and the industry.
b. Guidance. This order provides guidance on the following:
· The development of an AFS AVSSMS implementation plan in accordance
with the direction of
Orders 8000.369 and
Aviation Safety (AVS) Safety Management System Requirements, current edition;
· The use of standardized terminology for AFS oversight activity
consistent with AVS guidance;
· The conduct of AFS oversight activities under an efficient and
integrated system, consistent with other AVS services/offices, sharing information and minimizing duplication;
· A basis for analyzing and determining acceptable levels of risk
in different segments of the aviation industry;
· A risk management (RM) approach detailing the role of FAA oversight
in relation to that of the aviation industry, recognizing the responsibilities of each; and
· The means by which AFS will support the aviation safety goals
and objectives outlined in the Destination 2025.
Note: Since the beginning in FY 2012, Destination 2025 replaced
the Flight Plan as the FAA’s strategic plan. Destination 2025 outlines the long-term,
strategic vision for the agency, addressing the transformation of our nation’s
aviation system and the FAA itself over the next 15 years.
7. Suggestions for Improvement. Forward any deficiencies found,
clarifications needed, or suggested improvements regarding the content of this
order to the Organizational Resources and Program Management Division (AFS-100),
800 Independence Avenue S.W., Washington, DC 20591; your suggestions are welcome.
FAA Form 1320-19, Directive Feedback Information, is located on the last page
of this order for your convenience. If you urgently need an interpretation, you may contact the Flight Standard SMS Program Office, Flight Standards National
Field Office, AFS-900, at 703-661-0565, but also submit Form 1320-19 to document the conversation.
1. Overview. The current edition of FAA Orders
provide guidance for AVS services/offices in implementing
a common AVSSMS. The overall goal of these orders is to further the practice
of managing safety by moving to a more process-oriented system safety approach
that stresses not only dissemination and application of technical standards,
but an increased emphasis on the management systems that ensure Safety Risk
Management (SRM) and Safety Assurance (SA).
a. AFS Actions. Specifically, with respect to AVS services/offices, Orders
(1) Set forth basic principles to guide AVS services/offices in their safety management and
safety oversight activities. It requires them to adopt a common approach to implementing an integrated SMS.
(2) Require each AVS service/office to develop and implement a plan for its
functions under the AVSSMS, including, where appropriate, the structure of its
safety oversight relationship with that segment of industry for which it holds
safety oversight responsibility. Each AVS service/office should provide SMS
guidance to its regulated entities, where appropriate.
(3) Require each AVS service/office to regularly report on its AVSSMS implementation
progress, including performance measures.
b. Basis for AFS SMS Action. This order is one of two bases for
AFS SMS action. The second one is the AFS AVSSMS implementation plan. These two documents will meet the requirements of Orders
and implement the AFS elements of the AVSSMS. Per this order, the Director of Flight Standards Service (AFS-1) expects AFS
divisions and offices to develop oversight methodologies that apply principles of safety management and quality systems.
These methodologies will contribute to improving the effectiveness of AFS oversight functions and support the implementation of the AVSSMS.
c. Implementation Plan. AFS will develop a specific SMS implementation
plan, to include AFS division and office level input, which should evolve AFS
oversight activity so that it is consistent with the AVSSMS. This plan will
have a phase-in schedule and address specific personnel competencies and training
requirements, as well as an approach to achieve and maintain those competencies.
The plan will provide for developing internal and external guidance on the future
AFS oversight processes and on FAA expectations for the various industry segments
for application of SMS at the aviation product/service provider level.
a. Regulations and Authority. The statutory basis of this order
is derived from the authority specified in Title 49 of the United States Code
(49 U.S.C.) and Title 14 of the Code of Federal Regulations (14 CFR). Title 49 U.S.C.,
Chapter 447, Safety Regulation, specifically directs the FAA Administrator
to promote the safe flight of civil aircraft in air commerce by prescribing
regulations and minimum standards for safety and security in air commerce. In
adherence to this regulatory and policy basis, AFS is responsible for implementing
specific elements of the AVSSMS associated with the safety oversight of aviation
certificate holders in the United States. Refer to the current edition of FAA Order
Flight Standards Service Organizational Handbook, for additional
details on specific AFS roles and responsibilities and the basis for its authority.
b. AFS Mission. Within the FAA Office of Aviation Safety (AVS),
AFS is responsible for the safety and regulatory oversight of aviation certificate holders and
service providers in the United States. The AFS Mission Statement defines functions as follows:
(1) AVS sets certification standards for air carriers, air agencies, and
airmen to provide the safest, most efficient aerospace system in the world. AVS continually strives
to improve the safety and efficiency of flight in the US.
(2) Directing, managing, and executing certification by inspection and surveillance
activities. This ensures the adequacy of flight procedures, operating methods, airmen qualification and
proficiency, and continued airworthiness of maintenance programs.
(3) Exercising oversight authority over all service providers (governmental and
non-governmental) performing Instrument Flight Procedure (IFP) development, including flight inspection/flight validation services.
(4) Under the broad umbrella of safety and efficiency, AVS has several major roles:
· Regulating civil aviation to promote safety;
· Encouraging and developing civil aeronautics
(including new aviation technology);
· Developing and operating a system of air traffic control (ATC)
and navigation for both civil and military aircraft;
· Researching and developing the National Airspace System (NAS)
and civil aeronautics;
· Developing and carrying out programs to control aircraft noise
and other environmental effects of civil aviation; and
· Regulating US Commercial space transportation.
c. ICAO Interface.
(1) AFS fulfills its mission, in large part, through safety oversight activities.
The International Civil Aviation Organization (ICAO), of which the U.S. is a
member state, defines these activities. ICAO sets standards and recommended
practices across the entire spectrum of international aviation activity and
provides direction and guidance for member states.
(2) With respect to safety oversight, ICAO has defined eight critical oversight
elements. AFS has direct or indirect responsibilities related to all of them
(refer to ICAO Safety Oversight Manual, Doc 9734-AN/959, Part A, The Establishment
and Management of a State’s Safety Oversight System):
(a) Primary aviation legislation consists of “comprehensive and effective
aviation law” that provides the statutory basis for aviation activity in a member
state. This is primarily 49 U.S.C., which establishes the roles and responsibilities
for the Department of Transportation (DOT), FAA, U.S. aviation certificate holders,
and other aviation entities.
(b) Specific operating regulations are the national-level policy,
rules, regulations and other guidance standardizing aviation-related operational
procedures, equipment and infrastructure, primarily 14 CFR. ICAO Doc 9859-AN/474,
Safety Management Manual (SMM), describes regulations in terms of their role
as risk controls, as does Order
(c) State civil aviation system and safety oversight functions refer
to the establishment of a government authority with adequate financial resources,
staffed with appropriate technical and non-technical staff, and with stated
safety regulatory functions, objectives, and safety policies.
(d) Technical personnel qualification and training provides assurance
that the technical personnel performing safety oversight have adequate knowledge
and experience as well as the training necessary to maintain their competence
at the desired level.
(e) Technical guidance, tools, and the provision of safety critical information,
describes the provision of processes and procedures, facilities and equipment,
and information to the technical personnel to enable them to perform their oversight
function in accordance with established requirements and in a standardized manner.
(f) Licensing, certification, authorization, and approval obligations
are the processes and procedures ensuring that personnel and organizations performing
an aviation activity (i.e., an aviation-related product or service) meet established
requirements before they can exercise the privileges of a license, certificate,
or other approval/authorization.
(g) Surveillance obligations are the processes, such as inspections
and audits, to ensure that aviation license and certificate holders continue to meet established
requirements and function at a prescribed level of competency and safety.
(h) Resolution of safety concerns refers to processes and procedures
to address identified deficiencies impacting aviation safety.
d. Requirement Fulfillment. As a member state of the ICAO, the
United States, through the FAA and AVS/AFS, must demonstrate that it fulfills
the requirements of a safety oversight system as summarized above.
e. Comprehensive Safety Oversight. The critical safety oversight
elements discussed in paragraph 2c (2), define what constitutes comprehensive
safety oversight; they are the basic building blocks of the FAA’s oversight
activities. However, these elements do not specify how the FAA implements these
functions. For example, the requirement to develop specific operating regulations
(refer to subparagraph 2c(2)(b) above) does not require that these regulations
address wholly or in part any specific hazard or risk, nor does it require that
the FAA review these regulations periodically to ensure that they continue to
meet their original intent.
f. SRM. In order to meet system safety precepts, AFS will carry
out the functions associated with the critical safety oversight elements within the structure of an overall
safety program. This safety program, for example, characterizes regulations as safety risk controls. AFS
develops regulations to address specific hazards identified in the aviation system. Through the processes
of the internal SRM component, AFS establishes new regulations or amends existing regulations. In addition,
using the processes of the internal SA component, AFS continuously monitors the effectiveness and
efficiency of these regulations as safety risk controls.
a. Safe Operations. Title 49 U.S.C and 14 CFR specify the relationship
between AFS and certificate holders. As the oversight authority, AFS is responsible for developing the
policy, regulations, and other guidance to ensure that both the FAA and certificate holders establish
and maintain an environment conducive to safe and efficient aviation activities. One key aspect of this
relationship is that individual certificate holders, not AFS, are responsible for ensuring operational
safety, properly managing hazards and the risk associated with their operations.
b. Concept of Safety. AFS recognizes that it is impossible to
eliminate with certainty all possibility of injury, harm, or damage from aviation operations.
ICAO’s Safety Management Manual (SMM) further clarifies this precept and defines safety as
“the state in which the risk 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 identification
and risk management” (refer to ICAO SMM, Doc 9859-AN/460). The goal, therefore, is to manage
inherent risk to an acceptable level commensurate with the operations and environment of the operator.
c. SRM. Risk is a function of the relative severity of hazard-related
consequences and their likelihood to occur. Certificate holders maintain operational
safety by managing risk with properly designed and implemented systems. Certificate
holders measure success in safety management and the “level of safety” achieved
in terms of how well they eliminate or control the factors that influence the
likelihood or severity of injurious or loss-producing events.
d. System Safety. The FAA adopted the system safety approach.
When properly designed and implemented, this approach proactively identifies
hazards and mitigates associated risks before they result in incidents or accidents.
This approach guides and improves traditional methods of equating direct product
inspection and strict regulatory compliance with safe operations.
(1) Safety Management Principles and Systems. ICAO, which promotes the safe
and orderly growth of international civil aviation, supports modern safety management
principles and systems as a means of continuing to improve aviation safety through
more proactive SRM. ICAO’s SMM describes the following two concepts in detail.
(a) The State Safety Program (SSP). This is an integrated set of regulations,
directives, and activities that integrate its multi-disciplinary safety activities
into a coherent whole. The safety program addresses both internal FAA responsibilities
as well as the responsibilities of the aviation industry it regulates, including
the requirement for operators to implement SMSs.
(b) SMS. This is an organized approach to managing safety, which includes
organizational structures, accountability, policies, and procedures. This includes
a process to identify safety hazards, to implement remedial actions that mitigate
risk, and to provide for continuous monitoring and regular assessment of the
safety level achieved. ICAO describes the SMS as the function of an aviation
(2) ICAO Operation of Aircraft. ICAO requires these concepts (paragraphs
4a(a) & (b), above) for its Annex 6 - Operation of Aircraft – Part 1 – International
Commercial Air Transport – Aeroplanes (paragraph 3.2 and appendix 2).
(3) Safety Oversight Perspective. The ICAO SMM states that safety oversight
is evolving through experience beyond the traditional perspective. The traditional
perspective emphasizes compliance with regulations and is largely reactive.
The evolved perspective is more comprehensive, proactive, and complements and
expands the approach embodied in the eight critical elements summarized in paragraph
2c (2) above. This evolved perspective assumes the presence of such factors as:
· Use of scientifically-based SRM methods,
· Safety culture,
· Sharing of safety data,
· Integrated safety training, and
· Systematic safety oversight and performance monitoring aimed at
assessing safety performance and reducing or eliminating problem areas.
(a) Another aspect of oversight perspectives relates to the function of regulations.
In the traditional oversight environment, the oversight authority develops regulations
primarily as administrative controls that do not necessarily serve as risk controls.
The oversight authority and certificate holders/service providers should employ
regulations, processes, and/or procedures as safety risk controls contributing
directly to the reduction of risk in the environment. Product/Service Providers
will utilize operator specific mitigations that will be evaluated by AFS along
with regulatory controls.
(b) The FAA has introduced its oversight approach with system safety principles,
and with the adoption of the modern approach to aviation safety described in
the ICAO SSP concept (which equates to the FAA’s AVSSMS), will further transition
oversight to this proactive mode.
(4) State Safety Program Development and Implementation. The SMM describes
the ICAO expectation for states to establish a State Safety Program that is
broad in scope. The safety program includes provisions for diverse activities,
such as developing regulations based upon risk, hazard reporting, safety investigations,
safety audits, and safety promotion.
(a) For the State to implement an integrated safety program, service providers
need to possess a coherent SMS. For that reason, ICAO has established requirements
for states to require each operator, Maintenance Organization, Air Traffic Service
Provider, and certificated airport operator to implement an SMS.
(b) AOA-1 issued Order
enable the FAA to manage safety risk (among other actions) in
this changing environment by furthering the practice of managing safety. AVS-1 issued Order
VS 8000.367 to
provide more definitive internal and external SMS
requirements to AVS lines of business. Development of the SMS concept for aviation
product/service providers for which AFS has oversight responsibility will have
an impact on how AFS accomplishes its oversight. The FAA will do this by moving
to a more process-oriented system safety approach that stresses not only dissemination
and application of technical standards, but also an increased emphasis on the
management systems that ensure SRM and SA.
b. U.S. and FAA Initiatives. A number of initiatives are in development
both within the FAA and in support of other government aviation organizations
to encourage system safety and SMS as applied to aviation safety.
(1) Joint Planning and Development Office (JPDO). Section 709 of the Century
of Aviation Reauthorization Act (Public Law 108-176) created the JPDO to manage
the work related to the Next Generation Air Transportation System (NGATS), a
national vision for air transportation in 2025.1
(2) Air Transportation Oversight System (ATOS). The Flight Standards National
Field Office (AFS-900) implemented the ATOS surveillance process in October
1998 for safety oversight of 10 major 14 CFR part
carriers. AFS-900 has since expanded ATOS to all part
carriers. Under ATOS, the FAA assesses the design and performance of the air carrier’s systems based on:
· System safety principles,
· Safety attributes,
· SRM, and
· Structured system engineering practices.
(3) System Approach for Safety Oversight (SASO). The SASO Program Office
(AFS-900) is responsible for bringing into alignment AFS programs with oversight
elements related to certification, surveillance, investigation, and enforcement. Order
FS 1100.1 specifically
describes one of the functions of SASO as moving AFS to a proactive system safety approach of oversight.
c. Safety Management Principles. SRM is a shared enterprise,
with the responsibility for operational safety resting with the certificate
holders. The FAA will implement a comprehensive, risk-based, and data-supported,
systems approach in conducting oversight to ensure certificate holders and service
providers manage risk at the expected levels to achieve safety objectives.
(1) The fundamental goal is to allow AFS to address the highest risk concerns
through a system of integrated risk controls, facilitating efficient application
of FAA resources. This approach permits the leveraging of resources through
SRM, which focuses on safety oversight of systems and processes, so that AFS
can apply its resources where they will be the most effective.
(2) AFS has oversight responsibility for a wide range of aviation activity,
from individual pilots flying in the National Airspace System (NAS) to large
air carriers with sophisticated equipment and management systems. To comply
with statutory requirements, AFS must make sufficient use of industry and FAA
resources. The relative risk of operations will vary from one segment of the
industry to another and from one organization to another. AFS risk management
processes (RMP) must properly account for these variations.
d. SMS Components. The AVSSMS describes four essential components
of an SMS. It directs that AFS restructure its oversight activities to align with these components.
(1) Safety policy sets forth AFS’s commitments for its safety management
processes (the foundation for establishing the SMS) and outlines responsibilities,
authority and accountability for safety.
(2) SRM focuses on the identification of hazards, the analysis and assessment
of the associated risk, and the development and implementation of appropriate
risk controls. For AFS, these risk controls consist principally of the national-level
dissemination of rules, regulations, technical standards, and other guidance.
(3) SA is a continuous activity that evaluates the effectiveness of the prescribed
risk control measures and ensures that the assumptions underlying the SRM effort remain valid and applicable.
SA covers not only assurance of the risk controls for which AFS is responsible (internal SMS) but also assurance
that these risk controls are being applied effectively by certificate holders. These SA activities include
auditing the application and use of these risk controls, assessing their effectiveness, and identifying new
hazards requiring the development of additional risk controls. SA of AAFS internal activities is closely tied
to the Quality Management System (QMS), a process-oriented, internal evaluation and assurance system covering
all major AVS processes. AFS will direct its safety management processes through the AVS International
Organization for Standardization (ISO) 9000 QMS.
(4) Safety promotion consists of actions that create an environment where
AFS can achieve its safety objectives. A key objective of this activity is the
establishment and maintenance of a positive safety culture across an organization.
a. Concepts of Quality and Safety. The concepts of quality and
safety are closely related, with the principal difference being one of focus. The AVSSMS has a
primary focus on assuring the safety of the aviation industry and certificate holders, in the
United States. In contrast, Federal Aviation Administration (FAA) AVS organization uses the AVS
QMS (which meets the ISO 9001:2008 standard) to assure that the AVSSMS processes and their associated
objectives are defined and managed consistently across the AVS organization. Accordingly, the
QMS provides the basic management structure for AVSSMS functions.
b. The Role of a QMS. The QMS processes assure continual improvement,
value employee contributions, and respond to changes in the industry. With respect
to the SMS, the QMS assures the establishment of internal safety policy and
objectives, the development, documentation, and proper application of efficient,
effective, and safety critical processes/procedures used by AFS in oversight.
QMS is not a substitute for the SMS Safely Assurance (SA) function. Rather,
it complements the SA process and ensures product consistency.
a. Primary Basis. In alignment with the requirements of Orders
and following ICAO guidelines, AFS will implement
an enhanced oversight structure/approach based upon SMS principles. AFS will
not implement a stand-alone SMS, but serve as an essential component of the
integrated AVSSMS. This chapter summarizes this approach, and correlates the
approach with the eight critical oversight elements prescribed by ICAO (Doc
9734, Part A, Chapter 3) and the four components of an SMS and SSP (Doc 9859,
Chapters 8 and 11). The approach is based on a SRM foundation to achieve an
acceptable level of safety. AFS strives for effective safety oversight consistent
with AFS discretionary authority, resources, and practical constraints.
b. Oversight Structure. The primary structure of AFS oversight
activities is the three-level model of the U.S. Air Transportation System described in Order
These levels are not rigidly determined but provide a general
foundation and basis to illustrate the application of SMS principles to the
AFS oversight process. The three levels are:
(1) Aviation System Level. The Aviation System Level, begins with the overall
NAS, encompasses all types of aviation activity, including aircraft operations, maintenance, airports,
and air traffic management (ATM). The Aviation System Level includes national level AVS/AFS oversight
activities, such as the development of policy, guidance, and regulations.
(2) Organizational Level. The Organizational Level addresses organizations
that hold certificates, for example air carriers, aircraft and engine manufacturers,
and maintenance organizations. This level includes certification and continued
operational oversight of certificate holders. Because this level includes certificate
holders providing common carriage (i.e., services to the general public) the
FAA has a well-defined statutory interest and regulatory responsibility in oversight.
The Organizational Level also includes recently established authorizations in
the area of IFP development and flight inspection/flight validation activities.
(3) Individual Level. The Individual Level relates to activities of certificated
individuals, for example pilots and mechanics. The reduced degree of interaction with the general public at
this level lessens the requirement for a large FAA investment in continued operational oversight.
Note: The Three Levels of AFS Oversight, and the relationship to
the four components of SMS, is discussed in detail in paragraphs 2 through 5.
(4) Interactions Between the Levels. There are also interactions between
the levels. For example, pilots or mechanics who work for an air carrier must first achieve their
basic certification as individual practitioners. Then, when they go to work for an air carrier,
they are also subject to the carrier’s training program as well as performing duties on behalf of
the air carrier for which there are regulatory requirements.
c. FAA/Industry Interaction. The roles, responsibilities, and
relationships of and between the industry and the FAA, in terms of safety management
functions, will vary depending on the oversight level involved.
(1) In level one, the FAA applies its SRM process to identify hazards that
affect large segments of the public. If the risks presented by these hazards
are unacceptable, the FAA controls them through the rulemaking process (regulations).
(2) In level two, certificate holders apply FAA regulations. Certificate
holders are responsible for applying regulations and their own risk controls in a manner that meets
the risk control intent in the design of their operational processes. This makes use of the SRM
component of their SMS. The FAA analyzes these designs and, if found satisfactory, will then
approve, accept, or certify the process or product.
(3) This makes use of the FAA’s SA process. This level one and level two
oversight cycle is ongoing. Much of SMS is simply efficient management of aviation operations. Thus,
SMS functions to bolster effective safety management practices that lead to improvements where needed.
d. Management of Risk. A key objective of this approach is to
ensure that AFS elements have a common definition and understanding of risk and employ a consistent
process for analyzing and assessing risk associated with a hazard. This includes:
· The use of common SRM techniques;
· A set of consistent, continual, closed-loop SA procedures; and
· A common approach to establishing acceptable levels of safety and risk.
Figure 3-1. The Three Levels of AFS Oversight
a. At the Aviation System Level, AVS and AFS oversee activities
in the NAS and major components or classes within that system, such as:
· Air carrier and commercial aviation,
· General Aviation (GA),
· The pilot training system,
· IFP service providers, or
· Maintenance, repair, and overhaul.
(1) Oversight at the Aviation System Level involves both SRM and SA functions.
SRM includes the development of national level risk controls—primarily policy, regulations, and standards.
SA involves continuous assessment of the effectiveness of the prescribed risk controls and identifying
new/evolving hazards that may require the development of additional risk controls.
(2) An important element of these activities is the establishment of procedures
for specifying acceptable levels of safety for the various segments of the aviation industry. As shown, the
FAA/AVS/AFS safety policy provides overall direction and guidance for AFS SRM, SA, and safety promotion functions.
b. Correlation to the ICAO Critical Oversight Elements. At this level, the
FAA’s primary focus is the development and enacting of legislation and regulations, as well as the collection
and provision of safety critical information. These correspond to the ICAO critical elements:
· Primary aviation legislation;
· Specific operating regulations;
· State civil aviation system and safety oversight functions;
· Technical personnel qualification and training;
· Technical guidance, tools, and the provision of safety critical information; and
· Resolution of safety concerns.
c. Relationship to the AVSSMS. AFS HQ staff and divisions are
responsible for SMS efforts at the aviation system level. These efforts support all four SMS components.
(1) Safety Policy. At this level, AFS is responsible for establishing the
safety policy and basic structure that underlie and support all of its safety
oversight efforts. The AVS Management Team develops this safety policy, which
all major AVS and AFS directives and implementation plans reflect.
(2) SRM. AFS is responsible for SRM at the Aviation System Level. Specifically,
AFS identifies hazards and implements safety risk controls to address these hazards. AFS develops and
issues risk controls primarily in the form of policy, guidance, regulations, and standards applicable to
particular industry segments or components, as well as to individual certificate holders such as pilots,
dispatchers, and mechanics. AFS regulates individuals through the establishment of national competency
standards and related requirements such as practical test standards. This guidance and regulation
addresses identifiable hazards and, in turn, specifies boundaries for industry compliance in meeting
the intent of the regulation. AFS coordinates its SRM efforts with other AVS services and offices to
ensure seamless, comprehensive, and fully integrated AVS-wide efforts.
(3) Safety Assurance. At the National Level, AFS will continually evaluate
the effectiveness of its risk control measures. Based principally on data collected at the Organizational
Level, AFS will assess how well, both quantitatively and qualitatively, certificate holders are
implementing prescribed regulations, standards, orders, and directives; and if these risk controls, as
implemented, have their intended effects. This will identify weak or obsolete risk controls, and will
facilitate refining, eliminating, or replacing ineffective risk controls. In addition, SA efforts will
focus on identifying changes in the aviation environment presenting additional hazards requiring
analysis and assessment and the possible development of new risk controls. At the local level, AFS
field organizations assure the safety performance of certificate holders safety management activities.
Information from these activities is fed back to the national level to assure continuous improvement
of regulations, directives, and programs for which AFS is responsible.
(4) Safety Promotion. At the Aviation System Level, safety promotion focuses
on providing AFS employees with the training and communication of safety critical information. This
enables AFS processes and personnel to support system safety and SMSs in the aviation community.
(5) AVSSMS Core. AFS SRM and SA efforts are at the very core of the AVSSMS,
and the products of the SRM effort (regulations and guidance) are the most visible manifestation of
the SMS to the aviation community. AFS will fully integrate its SRM activities into the AVSSMS. This
integration will ensure that AFS-developed risk controls work together with risk controls that other
AVS services and offices have developed.
3. Organizational Level. The Organizational
Level addresses FAA oversight of certificate holders, such as air carriers, repair stations, and flight
schools, as well as other aviation organizations such as IFP service providers. Figure 3-1 shows the
three levels of oversight.
a. AFS Objective. The primary objective of AFS efforts at this
level is SA. Specifically, this means to assure that the certificate holders are properly
implementing the safety risk controls that AFS has developed and promulgated at the national
level, and that these risk controls are also effective. This includes both certification
activities and ongoing operational oversight. In addition, SA efforts at the organization level
identify changes in the environment that could result in additional hazards not previously examined.
b. Correlation to the ICAO Critical Oversight Elements. At the
Organizational Level, SRM is primarily the responsibility of the certificate holder. AFS is
responsible for the SA function, directed at ensuring the certificate holder adequately performs
its SRM role. The AFS activity corresponds to the ICAO oversight elements:
· Licensing, certification, authorization, and approval obligations;
· Surveillance obligations; and
· Resolution of safety concerns.
c. Relationship to the AVSSMS. As noted above, the primary AFS
role at the Organizational Level is SA, the overall function of the AFS Safety
Assurance System (SAS). Order
Chapter 5, addresses SA of aviation service providers - certificate holders. There are two basic
types of SA; design assurance and performance assurance. AFS personnel perform a variety of data
collection, analysis, and assessment activities to assure that certificate holders’ systems meet
regulatory and safety management requirements and objectives.
(1) The AFS SAS provides a comprehensive, standardized approach to the oversight
of aviation certificate holders. This system provides a set of business processes to meet AFS safety
responsibilities for both design and performance assurance. The SAS is a decision support system based on
system safety principles and reflects the evolution of oversight to a more proactive approach. This system
not only allows aviation safety inspectors (ASI) to make independent assessments, but also supports data
sharing, collaboration, and open communication. The three primary SAS functions, listed below, use a common
toolset structured in accordance with safety attributes derived from system engineering and quality concepts.
(a) Design Assurance. The ASI accomplishes assessments of the design of an
applicant’s systems during the initial certification of an organization and during program approvals
or acceptance. The ASI also conducts Design Assessments (DA) of operational systems to assess their
effectiveness. The intent is to determine whether the organization’s systems’ design will enable the
organization to meet applicable regulatory requirements and safety standards, and provide an acceptable level of safety.
(b) Performance Assurance. The ASI accomplishes assessments of the performance
of the certificate holder’s systems through such surveillance activities as systems evaluations, program
reviews, inspections and safety audits, and evaluations of environmental changes. The intent is to
determine whether the certificate holder is using its systems as designed, and if they are effective in
enabling the organization to meet applicable regulatory requirements and safety standards.
(c) SRM. Controlling risk in its operations and environment is the specific
responsibility of each certificate holder, but AFS uses internal processes to
identify certificate holder hazards and analyze risk as part of its responsibility
to assess and verify effectiveness of operator’s SMS. AFS field staff provide
assistance to certificate holders in assessing risk and developing appropriate
risk control measures. If necessary, and generally as a last resort, AFS has
a set of options available to manage certificate holder risk, including enforcement
action and certificate amendment (modification, suspension, revocation). In
addition, AFS uses its SRM function to assess risk and target internal resources
in accordance with risk-based priorities. However, as previously discussed,
the primary responsibility for SRM rests with the certificate holder.
(2) As SMS experience in industry and the FAA progresses, the AFS SA role
will increasingly expand from ensuring the certificated organization performs
SRM to ensuring the organization performs its own SA.
d. Organizations with Limited Resources. Experience will show
how small certificated organizations with limited resources for such activities
as risk analysis, independent auditing, and data collection and analysis should
approach SMS, including their own SRM and SA functions.
e. Organizations Not Holding FAA Certificates. The industry also
contains many organizations that do not hold FAA certificates. These include
corporate flight departments, certain flight schools, maintenance facilities
that do not hold certificates under 14 CFR part
and IFP service providers. These operations come in all sizes, from single‑person
operations to large and complex organizations, but the AFS relationship with
them primarily occurs through the certification of their individual employees.
While ongoing surveillance of individuals within noncertificated organizations
is limited, appropriate application of safety management principles by both
AFS and these organizations offers important safety enhancement potential.
(1) Figure 3-2, Evolution of FAA and Organization Certificate Holders Roles,
depicts the evolution of FAA oversight activity in relation to organizational
certificate holders as a function of the maturation of the organization’s SMS.
The maturity of the organization’s SMS will affect how AFS plans and accomplishes
system DA and system Performance Assessment (PA).
(2) Figure 3-2 provides a notional depiction of the maturation of a certificate
holder’s SMS and the changing relationship between the certificate holder and the FAA along this progression.
f. Evolution of SMS Function. As illustrated in Figure 3-2, as
the SMS becomes more established, FAA oversight concentrates less on traditional
surveillance and regulatory compliance inspections, such as directly examining
certificate holder products and services, and more on assessing and evaluating
the certificate holder’s SMS; which plays an ever-increasing role in the organization’s
safety capability. Direct observation/surveillance changes from a goal in itself
to a quality assurance verification of a certificate holder’s SMS functions.
Figure 3-2. Evolution of FAA and Organization Certificate Holder’s Roles
a. Acceptable Levels of Safety. The third level addresses oversight
of individual certificate holders, most of whom are pilots and mechanics. Some
of these individuals work within the realm of certificated organizations, while
others operate independently. Establishment of acceptable levels of safety for
this level consists primarily of the establishment of national safety goals
and objectives. The management of acceptable levels of safety at the individual
level is the responsibility of each individual.
b. Elements of SRM and SA. While AFS realizes that organizations
with the resources necessary to identify hazards, analyze risks, and collect and analyze data can
more readily apply the elements of SRM and SA, AFS does promote the application of SRM principles
at the individual level. This process will contribute to the assessment of applying SMS at the
small organizational level.
c. Issuance of Individual Certificates. Occasionally, in conjunction
with other duties, FAA ASIs provide oversight of individual airmen. Normally
though, ongoing operational oversight at the individual level consists primarily
of the initial issuance of individual certificates (i.e., pilot, mechanic, dispatcher,
etc.) in accordance with guidance and standards developed at the national level.
AFS commonly issues certificates through a designee, a third party authorized
by the administrator. Individuals at this level are responsible for their own
personal SRM, and initially AFS does not expect these individuals to conduct
SA activities as envisioned in an SMS. As the use of SMS principles increases
among individuals, AFS does expect that these individuals will implement more
d. Ongoing Operational Oversight. Ongoing operational oversight
of individuals concentrates primarily on safety promotion efforts, with increasing
respect to education on SMS basics and SRM techniques in particular.
e. Correlation to the ICAO Critical Oversight Elements. The activities
at this level are identical to those at the organizational level:
· Licensing, certification, authorization, and approval obligations;
· Surveillance obligations; and
· Resolution of safety concerns.
f. Relationship to the AVSSMS. At the individual level, efforts
connected to two of the four SMS pillars apply.
(1) Safety Assurance. AFS accomplishes SA at the individual level primarily via surveillance and enforcement.
(2) Safety Promotion. Safety promotion through various education and safety
outreach programs, such as currently conducted by the FAA Safety Team (FAASTeam),
constitutes the primary means of endorsing system safety and furthering safe
practices at this level. This information assists airmen by educating them on
the hazards and risk factors associated with their operations and environment
and equipping them with the skills and knowledge to manage risk properly.
a. Inter-Related Levels. The system, organization, and individual
levels of FAA oversight are inter-related. One important linkage is that AFS
sets certification standards and training and qualification requirements for
individuals who work for certificated organizations. This example of a linkage
among the three levels involves prescribing requirements for airmen at the aviation
system level, issuing certificates at the individual level, often through designees,
and then conducting SA at the organizational level to ensure the individuals
continue to meet the standards.
b. SRM and SA Activities. Once the certificate holder, such as
an air carrier, hires the eligible personnel, the operator must continuously
accomplish the appropriate SRM and SA activities to ensure it continuously meets
its training, qualification, and operational requirements, with respect to its
airmen employees. At this point, the AFS SA role is not only concerned with
the air carrier’s SRM function but also with the air carrier’s accomplishment
of SA. The air carrier should ensure it complies with the applicable regulations
and has the systems in place to ensure compliance occurs reliably.
a. Quantifying Levels of Risk. ICAO requires that states establish
a safety program to achieve an acceptable level of safety in aviation operations.
ICAO leaves it to each state to determine what level is acceptable.2
(1) AFS takes the position that safety is managed though the management of
risk. In other words, you cannot directly manage safety but you can manage risk.
The AFS approach to satisfying this requirement is therefore based on a comprehensive
RMP, and both AFS and aviation product/service providers will use the concept
of acceptable level of risk to express safety goals or expectations.
(2) AFS uses two factors to define acceptable levels of safety:
· Safety performance indicators, and
· Safety performance targets.
(a) Safety performance indicators are qualitative and quantitative parameters
by which AFS can measure the overall level of safety of an organization or industry.
AFS will also use these parameters as a measure of effectiveness to evaluate
the overall AFS RMP and to assess the effectiveness of existing risk controls.
Safety performance indicators include well-known measures such as fatal accidents
per 100,000 departures or accidents per 1,000,000 passenger miles.
(b) Safety performance targets are quantitative expressions of the safety
performance indicator goals. For example, the FAA introduced a new safety performance indicator,
fatalities per 100 million persons on board, in the 2008-2012 Flight Plan. The associated safety
performance target is to reduce the 2007 rate (8.8828 fatalities per 100 million persons on board)
by half, reaching a rate of 4.4414 by 2025.
b. Approach. In accordance with the provisions of 49 U.S.C. and
14 CFR, the individual certificate holder manages the risk associated with its
particular operations and environment. As the oversight authority, AFS assures
that each individual certificate holder manages its risk to an acceptable level
and that the aggregate risk across industry segments remains at acceptable levels.
(1) At the national level, AFS establishes an acceptable level of risk for
particular industry segments and types of operations, and continuously monitors
aggregate, industry level risk to ensure that it remains at an acceptable level.
This aggregate level is translated to a limit of acceptability for individual
certificate holders. At the organizational level, AFS evaluates the design and
performance of the operator’s systems to assure that these systems manage risks
in accordance with the full intent of the national guidance and that operators
manage risk to acceptable levels. Overall, AFS:
(a) Establishes national policy and standards for achieving and maintaining
an acceptable level of risk at the national, aggregate level;
(b) Establishes national policy and standards for achieving and maintaining
limits of acceptability for individual certificate holders’ risk;
(c) In collaboration with industry, specifies safety performance indicators
and safety performance targets for particular industry segments;
(d) Establishes regulations, policy, and guidance with respect to:
· The application of national policy and standards,
· The assessment of the application of national policy and standards, and
· The provision of feedback with respect to the effectiveness of
national policy and standards.
(e) Evaluates the process that underlies the industry assessment of risk
and the procedures for mitigating risk that has become unacceptable;
(f) Verifies that the level of acceptable risk established is consistent
with overall safety goals, taking into account the statutory obligation and the public’s interest
that certificate holders operate at the highest level of safety in the public interest; and
(g) Establishes applicable standards as the foundation for the certificate
holder’s determination of an acceptable level of risk; the certificate holder must meet or exceed such standards.
c. Consideration of Differences. The statutes that govern civil
aviation require the FAA Administrator to consider the duty of an air carrier to provide service
with the highest possible degree of safety in the public interest and to consider the differences
between air transportation and other air commerce. Within the non-air carrier portion of air
commerce, acceptable levels of risk will differ. As a result, aviation operations will have
different acceptable levels of risk.
7. Process Measurements. As part of AFS QMS functions, and consistent
with the system safety principles and ISO evaluation and audit processes, AFS will continuously measure its oversight activities.
SA uses system safety principles to ensure a sound design that fulfills its requirements. SA, for certificated organizations and
the FAA’s internal processes, has three principal elements: DA, PA, and effectiveness measurement. AFS uses traditional processes
of certification and certificate management to assess aviation product/service provider processes and organization designs. AFS
uses surveillance and investigation processes throughout all SA processes.
a. AFS Oversight Process Design. This assessment focuses on the
design of AFS oversight processes to ensure that they remain consistent with
AFS policies, are internally consistent within AFS and AVS, and remain coherent
with respect to the various industry segments.
b. AFS Oversight Performance. This assessment evaluates the degree
to which AFS applies the oversight processes in the field. The intent is to determine if there
are systemic weaknesses in the application of the AFS oversight approach.
c. AFS Oversight Effectiveness. This evaluation determines whether
AFS policies, procedures, controls, and corrective actions are achieving the
objectives of oversight-related SRM and system safety at the aviation system,
organization, and individual levels. The ICAO SMM describes this as safety performance
monitoring that validates the SMS, confirming not only that people are performing
the processes correctly, but also that their collective efforts have achieved
the organization’s safety objectives. Through regular review and evaluation,
management can pursue continuous improvements in safety management and ensure
that the SMS remains effective and relevant to the organization’s operation.
Note: ICAO uses the term “validate” to encompass both measuring
performance and measuring effectiveness.
a. Operational Safety Oversight-Related Elements. AFS, in accordance with Orders
will implement the operational safety oversight-related elements of the integrated AVSSMS.
The AFS oversight approach and processes will follow the principles of Order
8000.369, the requirements of Order
and other guidance, as appropriate. This ensures that AFS safety oversight activities complement the
operational SRM responsibilities of certificate holders and other operators,
and that AFS safety oversight directly and efficiently contributes to the enhancement
of safety in the U.S. aviation industry.
b. AVSSMS Implementation Plan. AFS will develop an AFS AVSSMS
Implementation Plan in accordance with the requirements of Order
chapter 5, paragraph 2b, implementation plans and the requirements of Order
This implementation plan will detail the tasks, activities,
schedules, and responsibilities associated with implementing the concepts documented in this order.
c. Approaches to Continuous Improvement. The AFS AVSSMS implementation
plan will address approaches to continuous improvement of the AFS safety culture
and methods of communication at all levels throughout the FAA.
d. Approaches for Industry Segments. AFS divisions and offices
will develop and implement a common approach to ensure that all industry segments
establish and maintain acceptable levels of risk. This will require AFS actions
to promote the implementation of SMS by aviation product/service providers through
appropriate standards or guidance. AFS divisions and offices will work with
the following individual industry segments in establishing levels of risk:
(1) Operators operating under 14 CFR parts,
(2) Repair facilities or certificated individuals operating under 14 CFR part
43 or part
(3) Repair stations operating under 14 CFR part
(4) Flight schools, training centers, and aviation maintenance technician schools operating under 14 CFR parts
(5) Representatives of the Administrator designated in accordance with 14 CFR part
(6) Individuals exercising the privileges granted in accordance with certification under 14 CFR parts
may overlap with operating regulations listed above).
(7) Appropriate entities addressing special considerations for operations in Alaska.
(8) Other segments or classes of aviation product/service providers as determined
by the appropriate division and office, such as high-end business aircraft operations, very light jets, or IFP service providers.
e. Interface with Other FAA Programs. The industry and the FAA
have in place many systems and programs that will comprise basic components of an SMS. As the
industry implements the use of SMSs, the industry and FAA will determine how best to integrate
those existing systems and programs into the aviation product/service provider’s SMS, if
applicable, and within the corresponding FAA oversight.
(1) These systems and programs include both mandatory and voluntary tools
and systems such as:
· The Air Transportation Oversight System (ATOS),
· The Advanced Qualification Program (AQP),
· The Aviation Safety Action Program (ASAP),
· Flight operations quality assurance (FOQA),
· The Internal Evaluation Program (IEP),
· Repair Station Assessment Tools (RSAT),
· The Continuing Analysis and Surveillance System (CASS), and
· The Voluntary Disclosure Reporting Program (VDRP).
(2) The FAA incorporates the handling and protection of data and information
generated under such systems and programs into SMSs and applicable risk analysis.
f. Voluntary Industry Programs. The FAA believes that aviation
safety is best served by providing incentives in order to correct regulatory
noncompliance and investing more resources in efforts to preclude recurrence
of noncompliance. The FAA recognizes the safety value of a cooperative relationship
with the industry, fostering compliance, safety, and the sharing of information
that will provide the widest possible safety benefits. A number of policy and
guidance documents and voluntary programs reflect this approach. FAA policy
will continue to encourage industry participation in these vital collaborative
programs. The FAA will continue to apply statutory and regulatory protections
from inappropriate disclosure of information supplied under these programs,
and will explore methods of integrating these programs and protections when
an aviation product/service provider implements an SMS that includes one or
more of these programs.
a. Organizational Integration. The key to success for the AVSSMS
and for AFS oversight is integration of the multiple disciplines involved in
producing an environment for safe aviation operations across the design, development,
and operational life cycles of aircraft. To accomplish this, AFS will focus on:
· Developing a strong and continuously improving
safety and learning culture,
· Ensuring AFS personnel have the knowledge,
skills, and abilities to support the AVSSMS, and
· Developing the appropriate communications
processes to facilitate continuous improvement.
b. Sharing Information. Order
8000.369 emphasizes that a support system for information collection, analysis,
and sharing is essential to the success of the FAA SMS.
(1) All SMSs rely heavily on the appropriate offices developing or receiving
timely and relevant data and information regarding hazard identification and
SRM. AFS recognizes that a myriad of sources for such data and information exists,
and that this information is not consistently available to the appropriate users
in a timely or opportune fashion.
(2) This is true for an air carrier or other aviation product/service providers
with multiple disciplines to coordinate, and it is true and particularly challenging
within the FAA. The AFS AVSSMS implementation plan will address issues of data
and information collection, analysis, and sharing throughout the FAA.
(3) AFS Responsibilities:
· Specify the outcomes of the AFS safety mission,
· Manage the AFS implementation of Orders
as described in this order,
· Coordinate development and implementation of the evolving AFS
· Oversee data and information systems integration and sharing,
· Produce meeting minutes and directives to AFS elements as necessary
to implement this order, and
· Verify and coordinate internal and external audits and evaluations
a. Implementation Schedule. This order is effective from the
date of approval. AFS recognizes that it will take a period of three to five
years for all personnel to become adequately trained to provide guidance to
the industry and to implement the enhanced RMPs within AFS. Therefore, the AFS
AVSSMS implementation plan should be realistic in terms of timetables, implementation
of data and information systems, and integration.
b. Evolution of Priority Areas. For many years, AFS has been
making progress in the priority areas of SRM principles, system safety, internal
and external coordination, information sharing, and integration. The evolution
of these processes in accordance with Order
further standardize many of these processes across the AFS organizations and ensure
the increasingly critical need for data-supported risk analysis on a systematic and
consistent basis. As technology and systems in the aviation industry grow increasingly
complex, the integration issues within the FAA also become more critical.
c. Identify Guidance. AFS elements should identify the SMS guidance
needed for various aviation industry segments. AFS will issue these guidance
documents to the industry appropriately.
4. AFS External Relationships. FAA and AFS
policy continues to promote a vibrant, safe, competitive, and efficient U.S.
aviation industry. In furtherance of this policy, AFS divisions and offices
should continuously examine how to conduct oversight activities in a manner
that supports the industry; especially as the development and implementation
of new technology improves the aviation environment. Over the years, there have
been numerous examples of technology enhancing safety, increasing system capacity,
and mitigating the environmental impact of aviation. It is incumbent upon AFS
to ensure that its oversight efforts fully support these developments.
1. Acronyms. The abbreviations/acronyms used in this order are
listed below as follows:
a. AFS. Flight Standards Service.
b. AFS-1. Director of Flight Standards Service.
c. ATC. Air Traffic Control.
d. ATOS. Air Transportation Oversight System.
e. AVS. Aviation Safety.
f. AVS-1. Associate Administrator for Aviation Safety.
g. AVSSMS. AVS Safety Management System.
h. CFR. Code of Federal Regulations.
i. DOT. Department of Transportation.
j. FAA. Federal Aviation Administration.
k. FSIMS. Flight Standards Information Management System.
l. HQ. Headquarters.
m. ICAO. International Civil Aviation Organization.
n. IFP. Instrument Flight Procedure.
o. JPDO. Joint Planning and Development Office.
p. NGATS. Next Generation Air Transport System.
q. SASO. System Approach for Safety Oversight.
r. SMM. Safety Management Manual.
s. SMS. Safety Management System.
t. SRM. Safety Risk Management.
u. SSP. State Safety Program.
v. U.S. United States.
w. U.S.C. United States Code.
FAA Form 1320-19, Directive Feedback Information
Please submit any written
comments or recommendations for improving this directive, or suggest new items or subjects to be added to it. Also, if
you find an error, please tell us about it.
Subject: Order 8000.368A
To: Directive Management
(Please check all appropriate line items)
An error (procedural or typographical) has been noted in
paragraph ____________________ on
page _________ .
Recommend paragraph _______ on page ___________ be changed as
follows: (attach separate sheet if necessary)
In a future change to this directive, please include coverage
on the following subject (briefly describe what you want added):
I would like to discuss the above. Please contact me.
by: ____________________________________________ Date: ________________
Telephone Number: _______________________ Routing Symbol: _____________________
FAA Form 1320-19 (8-89)