8/13/19

 

8900.1 CHG 615

VOLUME 17  SAFETY MANAGEMENT SYSTEM

CHAPTER 3  SAFETY MANAGEMENT SYSTEM VOLUNTARY PROGRAM

Section 2  SMS Voluntary Program Validation Process

17-3-2-1    PREPARATION PHASE.

A.    Safety Management System Voluntary Program (SMSVP) Acceptance. The certificate holder or Certificate Management Team (CMT) will contact the Safety Management System Program Office (SMSPO), either by email or by calling the SMSPO, to begin the application process. Specific requirements which must be in the request are located in Volume 17, Chapter 3, Section 1, subparagraph 17-3-1-11A, Requesting Entry into the SMSVP.

B.    Certificate Holder and CMT Commitment. In order to continue the application process, the certificate holder and CMT must commit to providing sufficient resources to ensure successful Safety Management System (SMS) implementation. The SMSPO will provide information describing the SMSVP validation process and respective roles, responsibilities, and expectations.

1)    Once the certificate holder and CMT completely review the SMSVP information, they must commit to supporting the SMS implementation process. Without a firm commitment from both parties, SMSPO communications will be limited to promotional materials. An email or letter from CMT management and the certificate holder’s executive management to the SMSPO is considered a documented commitment.
Email: 9-NATL-SMS-ProgramOffice@faa.gov
Letter: Attn: SMS Program Office
Safety Analysis and Promotion Division
13873 Park Center Road, Suite 165
Herndon, VA 20171
2)    The SMSPO will designate the certificate holder as an “Active Applicant” once it receives the respective CMT and certificate holder commitments. This permits the allocation of resources to support activities related to SMS implementation.

C.    SMSVP Initial Workshop. The SMSPO will identify an SMS Implementation Support Team (IST) to conduct an initial workshop with the certificate holder and CMT. Before the workshop, the IST will provide copies of all applicable documents and information expected to be referenced at the workshop.

D.    SMSVP Initial Workshop Agenda. The IST will conduct a multiday workshop. Part of the workshop is just for the CMT to address “Federal Aviation Administration (FAA) only” issues. Topics include documentation in the Program Tracking and Reporting Subsystem (PTRS) and Safety Assurance System (SAS), Data Collection Tools (DCT), best practices and lessons learned, and communication with the SMSPO. The remaining workshop time is for the certificate holder and CMT to address the following items together:

1)    Organizational concepts and considerations;
2)    Description of the SMSVP Standard;
3)    Description of service provider SMS tools;
4)    The SMSVP implementation and validation processes;
5)    SMS “Active Participant” acknowledgement;and
6)    Continued Operational Safety (COS) oversight expectations.

E.    Certificate Holder SMS Implementation Plan Design. The certificate holder may develop its SMS implementation plan in a form, manner, and medium that meets its needs and is agreeable to its CMT.

1)    The certificate holder’s implementation plan is a roadmap describing actions needed to conform to the SMSVP Standard. The implementation plan should detail a realistic timeline. The certificate holder should examine its organizational structure and manuals to identify individuals responsible for process designs and who have authority and technical expertise to apply those designs.
2)    It is incumbent upon the certificate holder to identify individuals responsible for developing, implementing, and maintaining SMS processes within their respective areas of responsibility. Process manager responsibilities shall include:

    Hazard identification, Safety Risk Assessment (SRA), and risk acceptance;

    Evaluation of the effectiveness of safety risk controls;

    Promotion of safety; and

    Submission of reports to the accountable executive on SMS processes functioning according to their design.

3)    Implementation plan outlines should include:
a)    A listing of the relevant sections of the SMSVP Standard and associated reference sources;
b)    A brief narrative describing where processes conform to the SMSVP Standard, or what actions the certificate holder will take to comply;
Indicates new/changed information.
c)    Identification of specific employees, by title, (Director of Safety (DOS), Chief Pilot, process owner, etc.) in the organization that will be responsible for implementing required actions;
d)    Estimated target dates when each expectation will be ready for CMT design validation assessment; and
e)    Estimated target dates when each expectation will be ready for CMT design demonstration assessment.
4)    The certificate holder’s implementation plan is the result of a thorough, system-wide gap analysis of existing processes and procedures currently in operation. A gap analysis is a way to compare existing processes, procedures, programs, and activities to the SMSVP Standard. Completing a gap analysis aids the certificate holder in determining what existing programs, processes, and practices comply with the SMSVP Standard and those that do not. Those that do not meet the SMSVP Standard, once identified, will need to have processes developed that bring them into conformance. Certificate holders should refrain from developing processes for identified gaps in their programs until after their implementation plan has been submitted and approved.

F.    Implementation Plan Submission. Once the certificate holder has developed its implementation plan, it will be submitted to the responsible Flight Standards office for review. The time between the initial SMS workshop and the certificate holder’s implementation plan approval can be as long as 12 months, but may be completed in less time. Once the plan is agreeable to the CMT and the SMSPO has completed its quality review and approved the plan, the certificate holder and CMT are ready to start the implementation and design validation phase.

17-3-2-3    CMT IMPLEMENTATION PLAN REVIEW PHASE.

A.    CMT Receipt of Implementation Plan. The certificate holder will submit its SMS implementation plan to the CMT following normal Flight Standards (FS) office protocols.

B.    CMT Implementation Plan Review. The CMT will perform a review of the certificate holder’s implementation plan using these general guidelines:

1)    The CMT concurs that the implementation plan has properly identified the primary process areas/departments/subdepartments that constitute the organization’s system. This requires that a copy of the certificate holder’s organizational chart be provided and reviewed to ensure all appropriate areas of the organization are considered during the gap analysis and implementation plan development.
2)    The CMT concurs that the implementation plan addresses all sections of, and is in conformance with, the SMSVP Standard.
3)    The CMT concurs that the organization has adequately identified where their documentation shows conformance to the SMSVP Standard.

NOTE:  The SMSVP Standard is located in Volume 17, Chapter 3, Section 3, Figure 17-3-3A, Safety Management System Voluntary Program Standard.

4)    The CMT, based on its overall knowledge of the certificate holder, does not find any processes that appear too simplistic or too complex for the size, scope, and complexity of the organization.
5)    The CMT can identify the certificate holder’s process points of contact (POC) to coordinate its validation activities.
6)    The CMT must develop a viable Validation Project Plan (VPP) from the certificate holder’s implementation target dates (earliest dates that process areas will be ready for CMT design validation or design demonstration).

NOTE:  The target dates on the certificate holder’s implementation plan are not necessarily the dates on which the CMT will perform validation work, but helps the CMT forecast resources for validation activities that will occur after the certificate holder has completed its implementation actions.

7)    Certificate holder and CMT activities are sufficient to validate compliance with the SMSVP Standard in accordance with the timeline in subparagraph 17-3-2-3J.
8)    There are sufficient designated personnel resources to accomplish the implementation activities defined in the plan.

C.    Acceptable Certificate Holder Implementation Plans. If an implementation plan is agreeable to the CMT, it should start CMT validation project planning (see subparagraph 17-3-2-3E).

D.    Unacceptable Certificate Holder Implementation Plans. If the CMT finds the implementation plan unacceptable, the CMT will return it to the certificate holder according to Volume 3, Chapter 1, Section 1, subparagraph 3-3B, Incomplete or Unacceptable Proposal, and/or CMT office policy.

1)    The CMT, in writing, must notify the certificate holder of the unacceptable submission(s) and a written explanation of the deficiencies requiring correction before it will conduct further reviews.
2)    The CMT may request a meeting with the certificate holder’s implementation plan POCs to discuss identified deficiencies, if required.
3)    After the CMT evaluates the certificate holder’s corrections, if acceptable, it will resume its review as required in subparagraph 17-3-2-3B.

NOTE:  Disagreements over implementation plan suitability between the CMT and certificate holder may be referred to the SMS Office of Safety Standards POCs, Office of Air Carrier Safety Assurance and Office of General Aviation Safety Assurance, within the Office of Foundational Business, for clarification and assistance. However, the SMSPO is the final authority on the SMSVP Standard and is available to address technical questions regarding policy and best practices.

E.    CMT VPP. The objective of a good VPP is forecasting the resources needed to perform appropriate validation activities on the certificate holder’s safety management processes. To those ends, during the implementation plan review, the CMT will consider how to manage its validation work.

1)    VPP development is based on the certificate holder’s implementation plan submission. The submitted plan guides the CMT to identify its corresponding subject matter resources needed to validate specific areas of the certificate holder’s management system. Once appropriate CMT resources are identified, the VPP can be drafted. The CMT manager may adjust office resources to address VPP requirements.
2)    To develop a viable VPP, the CMT must understand the purpose and use of the design validation and design demonstration job aids provided in Volume 17, Chapter 3, Section 3. These job aids correspond to the Custom Data Collection Tools (C DCT) in SAS. Validation activities must be accomplished in sufficient detail to ensure conformance with the SMSVP Standard. The SMSPO recommends the number of design validation and design demonstration C DCTs in SAS or PTRS activities be based on the size and complexity of the certificate holder. The actual number will vary, but they should be completed multiple times for multiple process areas/departments. As scheduled validations should not detract from the CMT’s regular certificate management responsibilities, the SMSPO can assist the CMT in determining effective and efficient ways to manage its validation work.

F.    VPP Considerations.

1)    The CMT and certificate holder should agree on the VPP Schedule of Events (SOE). The CMT should design its validation activities to allow for “assessment-correction-reassessment,” as planned CMT design validation and design demonstration validation dates may become unreliable if the proposed implementation plan timelines are not being met. The CMT and certificate holder POCs should collaborate throughout the validation process and revise the VPP SOE as necessary to ensure completion within the 3-year timeframe.
a)    Depending on the proposed validation activity there may not be a need to conduct independent validations for processes uniformly applied throughout the organization. These processes may require only a one-time sampling to validate an entire system-wide application.
b)    Some validation work can be accomplished remotely, while others require onsite and, sometimes, multiple site visits.
c)    The SMSVP phased approach requires that, in collaboration with the SMSPO, two design demonstration activities be scheduled at the very end of the CMT validation process (see subparagraph 17‑3‑2‑7E):

    The SMS Accountable Executive Review Design Demonstration; and

    The SMS Safety Risk Management (SRM) (Organizational) Design Demonstration.

2)    Once the VPP is drafted, a validation planning meeting is scheduled between the CMT and certificate holder to review the plan.

G.    CMT and Certificate Holder Validation Planning Meeting. The CMT SMS POC will organize an SMS validation planning meeting with the certificate holder to agree on the proposed VPP timelines. Appropriate CMT and certificate holder implementation teams must attend to agree or revise the VPP schedule.

1)    The CMT POC will present its SMS VPP to the certificate holder and discuss planned activities. The certificate holder and CMT agreement of the SMS VPP represents mutual acceptance of the plan’s timeline for completion of CMT validation activities. The certificate holder should also commit to aggressively work toward meeting the proposed target completion dates (i.e., design review readiness dates and design demonstration readiness dates) defined in their implementation plan submission.
2)    The certificate holder and CMT should discuss how implementation plan changes might affect VPP activities.
3)    The CMT will notify the certificate holder of the design validation and design demonstration job aids being used to validate its SMS and how they will be used. The CMT will remind the certificate holder that it must provide evidence of its own internal assessments and corrections, if applicable, before the CMT validates those processes.
4)    During the validation planning meeting, CMT and certificate holder concerns are addressed. Both will agree that all the planning requirements are complete and the certificate holder is ready to be acknowledged as an “Active Participant” in the SMSVP. The CMT will forward the following to the SMSPO:

    Its acknowledgement recommendation;

    The certificate holder’s SMS implementation plan;

Indicates new/changed information.

    The certificate holder’s organizational chart; and

    The CMT’s VPP.

NOTE:  The CMT may forward its acknowledgement recommendation and attachments in an email to the SMSPO (9-NATL-SMS-ProgramOffice@faa.gov).

5)    When the CMT agrees that the certificate holder’s implementation plan is satisfactory, the CMT manager will submit the implementation plan, along with the CMT VPP to the SMSPO for approval. If the CMT rejects the implementation plan, follow existing office policies for returning materials to a certificate holder.

H.    SMSVP Quality Review.

1)    Document Review. Once the SMSPO has received the certificate holder’s implementation plan, the CMT’s VPP, and CMT acknowledgement recommendation, the SMSPO performs a quality review of the documents. The SMSPO will contact the CMT POC if there are any questions or open issues from its review. Any subsequent corrections of identified deficiencies will be coordinated with the impacted parties, as applicable.
2)    Receipt of a Certificate Holder’s Implementation Plan. When the SMSPO receives an SMS implementation plan from the CMT, the SMSPO will analyze and evaluate the certificate holder’s intended plans to develop or bring nonconforming safety management processes into compliance with the SMSVP Standard and determine whether the plan is realistic. They will also review the CMT’s VPP to ensure the number of activities is appropriate for the size and complexity of the certificate holder.
3)    Differences in Implementation Plans. Implementation plans submitted by different certificate holders may not look the same. For example, though the SRM processes are identical regardless of the organization’s size, scope, or complexity, a small certificate holder might have only one SRM team for the entire company, while a large certificate holder might have multiple SRM teams at the department, division, and/or corporate level. During the SMS acceptance process (the next step after implementation plan approval), the CMT must evaluate conformance of each pertinent process (e.g., flight operations, maintenance operations, or cabin services) against the SMSVP Standard. The CMT must also ensure that the certificate holder’s implementation plan addresses each level (e.g., corporate or division) and functional operation that directly affects aviation safety (e.g., dispatch, ground, and cargo) against each SMSVP Standard requirement. Prior to approval by the SMSPO, the following elements will be reviewed:

    A listing of the relevant sections of the SMSVP Standard and associated reference sources;

    A brief narrative describing where processes conform to the SMSVP Standard, or what actions the certificate holder will take to comply;

    Identification of specific employees that will be responsible for implementing required actions;

    Estimated target dates when each expectation will be ready for CMT design validation assessment; and

    Estimated target dates when each expectation will be ready for CMT design demonstration assessment.

NOTE:  Satisfactory reviews will be signed by the Safety Analysis and Promotion Division SMSPO manager or his or her designee. Unsatisfactory items resulting from the review will be referred to the manager of the responsible Flight Standards office.

NOTE:  Engagement of the SMSPO at an early stage of the process is recommended to ensure timely review, feedback, and approval. However, the SMSPO may be contacted for consultation at any time.

I.    Functional Considerations.

1)    During SMS implementation, the CMT will continue all of its certificate management duties. Once the certificate holder’s SMS implementation plan is approved, CMT oversight will include monitoring changes to the approved plan and conformance to the plan’s schedule.
2)    The first of two SMSVP FAA responsibilities is approval of the certificate holder’s implementation plan. The implementation plan approval process should consider the CMT workload and the resource requirements of the SMS acceptance process. For example, once the certificate holder’s implementation plan is approved, they will follow that plan and begin to design, develop, modify, or align SMS processes to fit their business model and unique operational environment. It is only after the implementation plan has been approved when the second FAA SMSVP responsibility begins: validation of the certificate holder implementation plan activities to ensure conformance with the SMSVP Standard. Therefore, an implementation plan that has all SMS components due for evaluation the month prior to the deadline would place unrealistic expectations on the CMT.
3)    During implementation plan development, the CMT should periodically review the plan and include informal feedback on adequacy, timeliness of the proposed implementation schedule, and completeness. Communication between the certificate holder and the CMT allows time for the CMT to make suggestions, permit course corrections, and provide feedback on the adequacy of the plan.

J.    Implementation Plan Changes. Any changes made by the certificate holder to an approved implementation plan must be documented by the certificate holder and submitted to the CMT for review and acceptance. CMTs should use caution when implementation plan changes are accepted so that estimated completion dates are not moved back to the end of the 3-year implementation period. Approval of a revised implementation plan implies that the CMT has available resources to evaluate submitted SMS components for acceptance in a timely manner in accordance with office policy.

Indicates new/changed information.

K.    Recording Approval of the Implementation Plan (SAS users only; for certificate holders managed using PTRS, see paragraph 17-3-2-9). The acceptance and approval processes in the SMS development are similar to the Phased Certification Process of Volume 3, Chapter 1, Section 1, paragraph 3-6, Phase Five. If the certificate holder has submitted an acceptable implementation plan, the manager (e.g., office, unit, frontline, etc.) who is the approving entity for all collective decisions of the team will approve the implementation plan and ensure that implementation plan approval information is entered into PTRS as follows:

1)    Enter activity code: 1045, 3045, or 5045.
2)    Enter “SMSIPAP” in the “National Use” field.

L.    CMT Rejection of the Certificate Holder’s Implementation Plan. Rejection notification and comments will be returned to the certificate holder according to Volume 3, Chapter 1, Section 1, subparagraph 3-3B and/or CMT office policy. Failure of the certificate holder to submit an acceptable implementation plan within 12 months after the SMS initial workshop should be addressed as a failure to meet the SMSVP Standard requirements. Appropriate records of submissions and discrepancy findings by the CMT should be maintained, as well as evidence of evaluation timeliness on the part of the CMT. Differences of opinions between the certificate holder and the CMT as to the acceptability of the SMS implementation plan should be referred to the normal chain of authority through the respective FAA offices.

NOTE:  When the SMSPO determines the certificate holder has a complete implementation plan that meets the SMSVP Standard, the SMSPO will issue a letter approving the implementation plan and acknowledging the certificate holder’s participation in the SMSVP and show their status as “Active Participant” on the SMSVP Status Roster.

M.    PTRS Procedures.

1)    For certificate holders managed and tracked in PTRS, the CMT POC will complete a PTRS activity record in accordance with the procedure in paragraph 17-3-2-9 and Table 17-3-2B.

NOTE:  Certificate holders managed and tracked in SAS should use guidance located in Volume 17, Chapter 1, Section 2, paragraph 17-1-2-5, Loading SMS Custom Data Tools (C DCT) to an Existing Certificate in SAS.

2)    The CMT POC will open a PTRS record to document completion of the following preparation activities:
a)    Implementation plan review,
b)    VPP completion, and
c)    CMT recommendation of acknowledgment to the SMSPO.
3)    These milestones will be recorded in the “Comments” section of the PTRS record. The CMT may add additional preparation activities using this same convention.
a)    Enter activity number 1045, 3045, or 5045, as appropriate.
b)    Enter “SMSPREP” (SMS Preparation) (without quotations) in the “National Use” field.
c)    In the “Comments” section, record any specific activity (e.g., implementation plan review, validation planning meeting activity, or return of implementation plan). If you have a “No” answer in any questions from the job aids, you must explain the reason for this answer and trigger a followup activity to mitigate thedeficiency.
4)    Documentation of activities conducted by the CMT may be recorded in SAS by initiating/managing an Action Item Tracking Tool (AITT) in accordance with Volume 10, Chapter 6, Section 2, subparagraph 10-6-2-9B, Initiate/Manage AITT. However, this does not remove the requirement to perform a PTRS entry as required by this section.

17-3-2-5    DOCUMENTATION VALIDATION PHASE.

A.    Evaluating a Certificate Holder’s SMS Design. This paragraph provides guidance for determining if a certificate holder has an adequately designed SMS that includes required safety management activities and processes in their organizational system.

B.    Recording Design Assessments (DA). A CMT must have documented evidence that the planned activities from the VPP have been accomplished.

C.    The SMSVP Design Validation Job Aids. The design validation job aids should be used to evaluate the certificate holder’s documentation describing its SMS processes and procedures. The inspector’s formal record of observations and evaluations will be recorded using C DCTs, which are available as a national template in SAS. For certificate holders managed and tracked in the PTRS, use the SMSVP job aids and document completion in the PTRS using the codes and procedures located in Table 17-3-2B.

1)    Certificate holders are not required to use these job aids or C DCTs for their internal validation activities; however, certificate holders are required to complete their own internal assessments before CMT design validation assessments begin. Evidence of the certificate holder’s internal assessments must be made available to the CMT upon request.
2)    Even though design validations may occur at different times and on different certificate holder process areas/departments, they cannot be considered complete until there are enough validation records to demonstrate conformance with the SMSVP Standard.

NOTE:  It is important that responsibilities and authorities are defined in a certificate holder’s process procedure and are preferably assigned to a position, not a person (e.g., “The Director of Maintenance (DOM) will send records to the dispatch supervisor”). Passive language is not acceptable (e.g., “The maintenance department would send records to someone in the dispatch department”).

NOTE:  The CMT will validate that the certificate holder’s process design conforms to the SMSVP Standard.

D.    SMS Design Validation Job Aid Frequency of Use. The number of design validation job aids to be completed will be identified in the CMT VPP.

1)    While some job aids may be completed just once, others may be completed multiple times for multiple process areas/departments.
2)    Certificate holder processes that generally apply across the entire organization require only one design validation.
3)    Certificate holder processes that apply to specific process areas/departments require design validations for each process area.
4)    When the design validation job aid questions are all answered affirmatively for a process area(s), the CMT can prepare for its design demonstration validations on that process area(s).

E.    Job Aid References. See Volume 17, Chapter 3, Section 3:

    Figure 17-3-3B, SMS—Safety Policy Design Validation.

    Figure 17-3-3C, SMS—Safety Risk Management Design Validation.

    Figure 17-3-3D, SMS—Safety Assurance Design Validation.

    Figure 17-3-3E, SMS—Safety Promotion Design Validation.

17-3-2-7    DESIGN DEMONSTRATION PHASE.

A.    Evaluating a Certificate Holder’s Ability to Execute Its Designed Processes. This paragraph provides guidance for determining whether the certificate holder’s process applications have been applied operationally and are working as designed. Once SMS process documentation is validated as conforming to the SMSVP Standard, the CMT is ready to validate certificate holder capability based on its documented processes.

B.    The SMSVP Design Demonstration Job Aids. The design demonstration SMSVP job aids and SMS C DCTs are used for the design demonstration validation activities. Certificate holders are not required to use these job aids or C DCTs for their internal validation activities; however, certificate holders are required to complete their own internal assessments before CMT design demonstration assessments begin. Evidence of the certificate holder’s internal assessments must be made available to the CMT upon request.

C.    Recording Design Demonstration Assessments. The design demonstration job aids will be used to evaluate the certificate holder’s safety management processes. Where actual field demonstration cannot be assessed (e.g., emergency response plans (ERP)), the CMT is permitted to use simulated processes (sometimes called “tabletop exercises”) allowing the CMT to evaluate the certificate holder’s capabilities without an actual demonstration.

NOTE:  The inspector’s formal record of observations and evaluations will be recorded using C DCTs, which are available as a national template in SAS. For certificate holders not managed in SAS, use the SMSVP job aids and document completion in PTRS using the codes and procedures located in Table 17-3-2A. Even though design demonstrations may occur at different times and on different certificate holder process areas/departments, they cannot be considered complete until there are enough observations to demonstrate system-wide conformance to the SMSVP Standard.

NOTE:  The CMT will validate, to the extent possible, that the certificate holder’s process applications actually function in day-to-day operations.

NOTE:  For certificate holders not managed in SAS, the CMT POC will complete a PTRS activity record in accordance with the procedure in paragraph 17-3-2-9 and Table 17-3-2B.

D.    Demonstration Job Aid Frequency of Use. The number of design demonstrations to be completed will be identified on the CMT VPP. However, the CMT may add additional design demonstrations at its discretion. While some demonstration activities may be completed one time, others may be completed multiple times for multiple process areas/departments (e.g., policy work, Safety Policy, or ERP):

1)    Processes that generally apply across the entire organization require only one design demonstration. Some examples of this are the SMS SRM (Organizational) Design Demonstration and SMS Emergency Preparedness/Response Design Demonstration.
2)    When all of the questions on the planned design demonstrations are answered affirmatively, the CMT can recommend the certificate holder’s SMS as being fully functional and in conformance with the SMSVP Standard.

E.    Combined CMT and SMSPO Design Demonstration Validation Activities.

1)    The CMT may independently accomplish all design demonstrations with the exception of two that must be completed in collaboration with the SMSPO:

    SMS Accountable Executive Review Design Demonstration.

    SMS SRM (Organizational) Design Demonstration.

2)    These demonstrations may be completed as tabletop exercises with appropriate representatives of the certificate holder, CMT, and SMSPO IST participating. The certificate holder’s accountable executive must participate (in person or virtually) for the SMS Accountable Executive Review Design Demonstration. Successful outcome of these two demonstrations is required to close out the CMT’s VPP.

F.    Job Aid References. See Volume 17, Chapter 3, Section 3:

    Figure 17-3-3F, SMS—Safety Policy Design Demonstration.

    Figure 17-3-3G, SMS—Emergency Preparedness/Response Design Demonstration.

    Figure 17-3-3H, SMS—SRM (Process/Department Owner) Design Demonstration.

    Figure 17-3-3J, SMS—SRM (Organizational) Design Demonstration.

    Figure 17-3-3K, SMS—Audit Process Design Demonstration.

    Figure 17-3-3L, SMS—Evaluation Process Design Demonstration.

    Figure 17-3-3M, SMS—Investigation Process Design Demonstration.

    Figure 17-3-3N, SMS—Continuous Improvement Process Design Demonstration.

    Figure 17-3-3P, SMS—Accountable Executive Review Design Demonstration.

    Figure 17-3-3Q, SMS—Records Retention Process Design Demonstration.

    Figure 17-3-3R, SMS—Safety Communications Design Demonstration.

17-3-2-9    PTRS DATA ENTRY PROCESS. For certificate holders managed and tracked via the PTRS, the following procedures will be utilized when documenting SMSVP activities. The CMT must complete the following boxes to ensure proper documentation of SMS activities and findings when recording activities in the PTRS.

Indicates new/changed information. Indicates new/changed information.

A.    Description. If the certificate holder is currently developing and implementing an SMS under the SMSVP, enter “SMSCERT” in the “National Use” field for the activities listed in Table 17-3-2A (except COS). For design and design demonstration activities use the “National Use Field Entry” codes listed in Table 17-3-2B. If the certificate holder has an accepted SMS and the activity is COS, enter the assessment using the appropriate COS tool job aid (SMS016–SMS019), as applicable in the “National Use” field listed in Table 17-3-2B.

B.    Activity Number. The first digit of the activity number denotes the specialty of the inspector recording the activity: “1” for Operations, “3” for Airworthiness, and “5” for Avionics. The second digit shall be a “9,” which identifies the task as General Technical Function. The third and fourth digits define the general activity being performed. For SMS activities, the following codes have been assigned:

17-3-2A.  SMSVP PTRS Codes

Activity

PTRS Code

SMSVP Initial Workshop Completed

X991

SMSVP Implementation Plan Submitted and Approved

X992

SMS Interim Calibration Completed (may be accomplished multiple times)

X993

SMS Accepted

X994

SMS COS Activity Accomplished

X995

NOTE:  A complete activity number might be 1991 if an Operations inspector is recording the completion of an SMSVP initial workshop, or 5994 if an Avionics inspector is recording that the certificate holder has an accepted SMS. COS activities will be recorded as X995.

Indicates new/changed information.

NOTE:  To prevent excessive administrative burden, SMS-integrated COS job aid (SMS016) completion must be recorded one time at the conclusion of a single or a group of scheduled surveillance activities occurring within the same time period. This activity will be recorded in a separate PTRS entry utilizing PTRS code X995 and putting SMS016 in the “National Use” field.

C.    Status. Select “O” for Open or “C” for Closed, as appropriate.

Indicates new/changed information.

D.    Start Date. Enter the date the activity was started. The start date of the technical process assessment using the appropriate job aid and COS tools (SMS016–SMS019), as applicable. The date of the COS tool (SMS016) must be the same as the date of the technical process being evaluated. These COS job aids are only to be used with certificate holder’s managed under the National Work Program Guidelines (NPG) and PTRS.

E.    Designator. Enter the designator for the certificate holder.

F.    “National Use” Field. Enter the appropriate activity code. A list of activity codes that must be used are located in Table 17-3-2B. Select the appropriate keyword from the “National Use” field column that reflects the job aid or activity conducted. Proper code selection is critical to ensure activity tracking.

G.    Comments. This block is for recording any information pertaining to the job aid or activity conducted that the principal inspector (PI) feels is important to retain (e.g., the number of company employees interviewed concerning the employee reporting system or tabletop exercises conducted).

NOTE:  When conducting COS questions (SMS016), if any question results in a “No” answer, an explanation MUST be entered and followup actions defined. A followup PTRS record must be triggered and linked to the original PTRS record.

17-3-2B.  SMSVP Job Aids

SMSVP Job Aid Name

National Use Field Entry

Figure Number

SMS—Safety Policy Design Validation

SMS001

17-3-3B

SMS—Safety Risk Management Design Validation

SMS002

17-3-3C

SMS—Safety Assurance Design Validation

SMS003

17-3-3D

SMS—Safety Promotion Design Validation

SMS004

17-3-3E

SMS—Safety Policy Design Demonstration

SMS005

17-3-3F

SMS—Emergency Preparedness/Response Design Demonstration

SMS006

17-3-3G

SMS—SRM (Process/Department Owner) Design Demonstration

SMS007

17-3-3H

SMS—SRM (Organizational) Design Demonstration

SMS008

17-3-3J

SMS—Audit Process Design Demonstration

SMS009

17-3-3K

SMS—Evaluation Process Design Demonstration

SMS010

17-3-3L

SMS—Investigation Process Design Demonstration

SMS011

17-3-3M

SMS—Continuous Improvement Process Design Demonstration

SMS012

17-3-3N

SMS—Accountable Executive Review Design Demonstration

SMS013

17-3-3P

SMS—Records Retention Process Design Demonstration

SMS014

17-3-3Q

SMS—Safety Communications Design Demonstration

SMS015

17-3-3R

SMS—Integrated Continued Operational Safety Job Aid

SMS016*

17-3-3S

SMS—Accountable Executive Continued Operational Safety Job Aid

SMS017*

17-3-3T

SMS—Emergency Response Continued Operational Safety Job Aid

SMS018*

17-3-3U

SMS—Recordkeeping Continued Operational Safety Job Aid

SMS019*

17-3-3V

*For SMS016, SMS017, SMS018, and SMS019, use PTRS code X995.

NOTE:  For SMSVP design validation or design demonstration job aids, use PTRS code 1045, 3045, or 5045.

17-3-2-11    ADMINISTRATIVE PROCESS PHASE.

A.    CMT Administrative Process. Once all SMS CMT VPP activities are successfully completed, the CMT will close out the validation process by completing the following actions:

Indicates new/changed information.
1)    The CMT POC will ensure that all SMS C DCT records, or PTRS Job Aid records for PTRS users, have been completed and closed, as listed in the VPP.
2)    The CMT POC archives the final CMT VPP with the latest revision of the certificate holder’s implementation plan, following CMT office policy.
3)    The CMT POC will enter the following PTRS activity record:
a)    Enter activity number 1045, 3045, or 5045;
b)    Enter “SMSADMCPT” (SMS Administrative Activities Complete) (without quotations) in the “National Use” field; and
c)    In the “Comments” section, state that the CMT manager has recommended that the certificate holder’s SMS receive final recognition by the SMSPO.
4)    Documentation of activities conducted by the CMT may be recorded in SAS by initiating/managing an AITT in accordance with Volume 10, Chapter 6, Section 2, subparagraph 10-6-2-9B; however, this does not remove the requirement to perform a PTRS entry as required by this section.
5)    CMT management will, by email or letter, recommend that the SMSPO issue final recognition of the certificate holder’s SMS.
Email: 9-NATL-SMS-ProgramOffice@faa.gov
Letter: Attn: SMS Program Office
Safety Analysis and Promotion Division
13873 Park Center Road, Suite 165
Herndon, VA 20171

B.    SMSPO Administrative Process QualityReview.

1)    Once the SMSPO receives the CMT management’s recommendation for certificate holder SMS recognition, it will complete its administrative process review. This review ensures that all SMSVP-required administrative tasks have been completed. Any issues or required corrections will be coordinated with the CMT SMS POC.
2)    Upon satisfactory review, the SMSPO will change the certificate holder’s status from “Active Participant” to “Active Conformance” and issue the certificate holder a current status letter.
Indicates new/changed information.

17-3-2-13    COS for Certificate Holders Tracked in SAS. After the certificate holder has an accepted SMS and attained “Active Conformance” status, the PI shall check the “SMS VP – Safety Management System Voluntary Program” box in the Vitals Information tab in the SAS Configuration Module, to activate the SMS COS DCT questions. The CMT now begins using the SAS COS DCTs for continued oversight of the certificate holder’s SMS. CMT oversight of the certificate holder’s SMS will be conducted in conjunction with, or integral to, routine certificate management functions, as contained in Volume 10.

Indicates new/changed information.

17-3-2-15    COS for Certificate Holders Tracked in PTRS. After the certificate holder has an accepted SMS and attained “Active Conformance” status, the PI shall schedule the SMS COS Job Aids, SMS017, SMS018, and SMS019 into their work program. These job aids should be completed annually at a minimum and any other time the PI suspects a problem with the focus of the Job Aid. These three job aids focus on the following SMS specific areas:

    SMS—Accountable Executive Continued Operational Safety Job Aid.

    SMS—Emergency Response Continued Operational Safety Job Aid.

    SMS—Recordkeeping Continued Operational Safety Job Aid.

NOTE:  To prevent excessive administrative burden, SMS-integrated COS Job Aid (SMS016) completion must be recorded one time at the conclusion of a single or a group of scheduled surveillance activities occurring within the same time period. This activity will be recorded in a separate PTRS entry utilizing PTRS code X995 and putting SMS016 in the “National Use” field.

17-3-2-17 through 17-3-2-29 RESERVED.