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### Chapter 5 

## Internal Evaluation Program

CHAPTER TITLE PAGE #
Chapter 5 Internal Evaluation Program (IEP) ............................................................................................. 5-3

5.0 Internal Evaluation Program (IEP) ............................................................................... 5-3 5.1 General ...................................................................................................................... 5-3 5.2 Objectives .................................................................................................................. 5-3 5.3 Scope ......................................................................................................................... 5-3 5.4 Evaluations Standards ................................................................................................ 5-3 5.5 IEP Data Management ................................................................................................ 5-3 5.6 Responsibilities and Authorities ................................................................................... 5-4 5.7 Procedures for Conducting Planned Evaluations .......................................................... 5-4 5.8 Special Evaluations .................................................................................................... 5-14 5.9 Communications and Reports .................................................................................... 5-14 5.10 Record Management ................................................................................................. 5-14 5.11 Program Evaluation ................................................................................................... 5-15 5.12 Evaluation Preparation Checklist ................................................................................ 5-15 Figures: 5-1 SMS FM 17 – IEP Evaluation Preparation .............................................................. 5-5 5-2 SMS FM 28 – PEAR Form .................................................................................... 5-9 5-3 IEP Correction Action Phase Flow Chart ............................................................... 5-13 Tables: 5-1 Instruction to fill out IEP Evaluation Preparation Form – SMS FM 17 ...................... 5-6 5-2 Instruction to fill out PEAR Form – SMS FM 18 ..................................................... 5-105-2 Safety Management System Manual

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### Chapter 5 

## Internal Evaluation Program

5.0 Internal Evaluation Program (IEP): 14CFR AC 120-59A (used as a guide) 5.1 General: 5.1.1 The Internal Evaluation Program is a central part of the SAAS’s Safety Management System (SMS). It provides the SAAS with an independent, systems-oriented evaluation process that focuses on: 5.1.1.1 Evaluating the SAAS’s compliance with external regulatory requirements. 5.1.1.2 Identifying areas of nonconformance to internal policies and procedures. 5.1.1.3 Identifying opportunities to improve the SAAS’s policies, procedures, and processes. 5.1.1.4 Evaluating corrective actions to ensure effectiveness and eliminate reoccurrences of non-compliance. 5.2 Objectives: 5.2.1 The IEP has the following strategic objectives: 5.2.1.1 Determine if Safety Management System attributes are incorporated within divisional policies and procedures. 5.2.1.2 Evaluate the effectiveness of ongoing audit structures within Airport Operations and Ground Operations. 5.2.1.3 Coordinate disclosures of apparent violations with division managers. 5.2.1.4 Verify that divisions are tailored to current business operations and future plans. 5.2.1.5 Determine if the resources available to divisions are adequate for current business operations. 5.2.1.6 Ensure that technical issues receive the attention and support of senior management. 5.3 Scope: 5.3.1 Authorized personnel conduct evaluations in the areas listed below: 5.3.1.1 Records and Reporting systems 5.3.1.2 Maintenance Organization 5.3.1.3 Manual Management 5.3.1.4 SAAS Programs and Procedures 5.3.1.5 Operational Release 5.3.1.6 Maintenance Personnel Qualifications 5.3.1.7 Training Programs 5.3.1.8 Mechanics and Repairmen Certification 5.3.1.9 Maintenance Personnel 5.3.1.10 Other Programs (Safety Program) 5.4 Evaluation Standards: 5.4.1 The authorized personnel will conduct evaluations using the following standards. 5.4.1.1 Federal regulations using the Safety Attribute Inspection data collection tool from the FAA’s Air Transportation Oversight System where possible. 5.4.1.2 Internal SAAS procedures. 5.5 IEP Data Management: 5.5.1 The IEP uses a database to create checklists and reports as well as to track the progress of ongoing evaluations and corrective actions. The IEP database generates all checklists and reports described in this section. The Safety5-4 Safety Management System Manual

DRAFT 10 Jul 2009 Operating Instructions (SOI) contains specific data entry procedures for creating and completing these checklists and reports. 5.5.1.1 The Safety Operating Instructions (SOI) will be maintained by the Safety Management System Manager as an uncontrolled manual within the Safety division, and will be used strictly by Safety Division personnel for guidance when accessing the division database. 5.6 Responsibilities and Authorities: 5.6.1 The SMSMG has the authority to modify this process and is responsible for its quality. 5.6.2 Responsibilities and authorities for this process are presented in Chapter 3 of this manual. 5.6.3 Procedures for Developing the Master IEP Schedule. 5.6.3.1 The Master Schedule is developed to allow for planned, periodic review of the different divisions within SAAS. Because of the dynamic nature of this program, the Master Schedule will remain flexible to allow for special, or follow-up evaluations as needed. 5.6.3.2 The SMSMGor designee will lead division personnel in developing the schedule for the upcoming year during the last month of each calendar year, and will consider the following factors: 5.6.3.2.1 Previous evaluation findings 5.6.3.2.2 FAA surveillance and inspection findings 5.6.3.2.3 Industry identified trends or problem areas 5.6.3.2.4 Areas of emphasis identified by the Airport Director, Assistant Directors or SMSMG

. 5.6.3.2.5 Requests or concerns raised by Aviation Department and divisions within the department 5.6.3.2.6 Trends identified through the Safety Program 5.6.3.2.7 Trends identified through data collected from all Safety Inputs 5.6.3.2.8 Unaccomplished evaluations from the previous year 5.6.3.2.9 Follow-up evaluations, special evaluations, and scheduled training, etc. 5.6.3.3 Scheduling priorities are determined on a case-by-case basis. 5.7 Procedures for Conducting Planned Evaluations: 5.7.1 The lead evaluator (LE) will initiate the evaluation process by completing the IEP Evaluation Preparation Form (EPF) prior to the scheduled evaluation. 5.7.1.1 Planning Phase: 5.7.1.1.1 The LE will guide the team in accomplishing the following tasks and documenting information on the Evaluation Preparation Form (SMS FM 17) (Reference Figure 5-1).

5.7.1.1.1.1 Review previous evaluations for any finding, if there are, document them in the remarks section of the Evaluation Preparation Form (SMS FM 17). 5.7.1.1.1.2 Develop the Evaluation Notification letter, which includes:

5.7.1.1.1.2.1 Facility requirements. 5.7.1.1.1.2.2 Names of evaluation team members. 5.7.1.1.1.2.3 Evaluation agenda and tentative schedules. 5.7.1.1.1.2.4 Safety concerns. 5.7.1.1.1.2.5 Confidentiality agreements or union contract issues, if applicable. 5.7.1.1.2 The LE will send an Evaluation Notification letter via e-mail to the division manager scheduled for an evaluation (minimum of 5 business days.)

5.7.1.1.2.1 Upon receipt of the Evaluation Notification, the division manager will contact the LE via E-mail to confirm receipt and to resolve any scheduling issues.Safety Management System Manual 5-5

DRAFT 10 Jul 2009 Figure 5-1 – SMS FM 17 – IEP Evaluation Preparation)5-6 Safety Management System Manual

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Table 5 – 1 - IEP Evaluation Preparation Form Instructions – SMS FM 17:

Block Title Lead Evaluator (or Designee) Complete Form by Entering:
1 Evaluation Number Enter number assigned by the IEP Data Base 2 Airport Select the Appropriate box 3 Date Scheduled Date when the forms is being filled out 4 Evaluation Number IEP represent the office, 2010 represent the year the report was conducted; 0001 represent the numerical sequence of the report being conducted. 5 Evaluation Schedule date Enter the date evaluation is scheduled to begin 6 IEP Group / Division Check the applicable box for the IEP group performing the evaluation
7 Name of Lead Evaluator Enter the name of the Lead evaluator for this audit
8 Name of Assistant Evaluator Enter the name of the assistant evaluator for this audit 9 Evaluation Type Check the applicable box for: SAI – 1. Enter the number of the applicable ATOS System / Sub system / Element as

provided by the ATOS chart e.g., 1.1.1 2. Enter the title, e.g.Aircraft Airworthiness EPI – 1 Enter the number of the applicable ATOS System / Sub system/Element as

provided by the ATOS chart, e.g. 1.1.1 2. Enter the title, e.g.Aircraft Airworthiness Special – 1. Enter the Department

2. Enter the title Follow-Up evaluation – Enter the Evaluation number 10 Process Owner(s) 10A Name Enter the name of the process owner
10B Division Enter the division
10C Email address Enter the email address 10D Phone Number Enter the current phone number of the Process Owner 11 Initial Notification Enter the date the initial notification was sent to the process owner 12 Remarks Enter any remarks 13 Signature of all parties involved Name of Lead Evaluator Enter the name of the Lead Evaluator completing this form Signature Lead Evaluator will sign once printed Employee Number Enter the employee number of the Lead Evaluator Date Signed Enter the date signed Name of SMS Manager Enter the name of the SMS Manager Signature SMS Manager will sign once printed Employee Number Enter the employee number of the SMS Manager Date Signed Enter the date signed

5.7.1.1.3 The LE will complete the Preparation/Planning Review portion of the EPF (SMS FM 17) to make sure all necessary preparation/planning steps have been accomplished. 5.7.1.1.4 The LE will prepare an agenda for review by the Safety Management System Manager. 5.7.1.2 Opening Meeting:Safety Management System Manual 5-7

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5.7.1.2.1 The LE will open the meeting by reviewing the Agenda. 5.7.1.3 Conducting the Evaluation: 5.7.1.3.1 The evaluator will use the evaluation checklist produced from the IEP database or use SMS GAP analysis / audit tool in Appendix – A to document:

5.7.1.3.1.1 The evaluation trail, the path the evaluator took during the evaluation. 5.7.1.3.1.2 Exactly what was found as nonconforming (findings), and what requirements were not met. 5.7.1.3.1.3 The objective evidence, documented in such a manner that the finding could be reproduced. This will allow appropriate action to be taken. 5.7.1.3.2 While conducting the evaluation, the LE will monitor the performance of the evaluation team to ensure team members.

5.7.1.3.2.1 Perform assignments as described in the evaluation agenda. 5.7.1.3.2.2 Collect, analyze, and verify information and evidence through:

5.7.1.3.2.2.1 Interviews of personnel. 5.7.1.3.2.2.2 Observations of activities and surrounding work environment. 5.7.1.3.2.2.3 Review of policies, procedures, plans, objectives, standards, regulations, drawings, specifications, contracts, records, data summaries, analyses, performance indicators, reports, feedback records, databases, and other relevant information from internal or external sources. 5.7.1.3.2.3 Collect both Audit and Objective evidence.

5.7.1.3.2.3.1 Audit Evidence - data found in records, statements of fact, or other information that is relevant to the evaluation criteria and verifiable. Audit evidence can be qualitative or quantitative. 5.7.1.3.2.3.2 Objective Evidence - data that supports the existence or verity (quality of being true or in accordance with fact or reality) of the standard. Objective evidence may be obtained through observation, measurement, test, or other means. 5.7.1.3.3 If necessary, the LE will identify discrepancies with the team’s performance to ensure the evaluation procedures are followed. 5.7.1.4 Conducting Evaluation Meetings: 5.7.1.4.1 The LE will organize team members to discuss possible findings and modify the evaluation as needed.5.7.1.4.1.1 The LE monitors the progress of the evaluation and may adjust the

evaluation agenda. 5.7.1.4.1.2 The team discusses evaluation findings and observations and minor trends may be discovered.

5.7.1.4.1.2.1 Evaluators will review audit evidence. 5.7.1.4.1.2.2 Evaluators will discuss potential findings to determine if they are just and accurate. 5.7.1.4.2 The LE will hold daily wrap up meetings with the division manager to:

5.7.1.4.2.1 Review findings and observations. 5.7.1.4.2.2 Monitor relations between the evaluation team and the division. 5.7.1.4.2.3 Monitor evaluation progress by reviewing the evaluation agenda to verify the evaluation team is on time. 5.7.1.4.2.4 Make any necessary adjustments to the schedule. 5.7.1.4.2.5 Address any questions or concerns. 5.7.1.5 Documenting Findings and Concerns:5-8 Safety Management System Manual

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5.7.1.5.1 General Documentation Procedures:

5.7.1.5.1.1 State what non-conforming issue has been found (pertinent information, location, document, form, quantity, etc.) and explain why it is considered a finding. Evaluators will provide detailed audit evidence that supports the finding and not dwell on the finding type. 5.7.1.5.1.2 Reference and quote the requirement from the standard and/or procedure.

5.7.1.5.1.2.1 Make copies of any evidence if possible. 5.7.1.5.2 Classifying Evaluation Findings:

5.7.1.5.2.1 Evaluators will classify all findings within the three categories of Major, Minor, and Concern. Evaluators will use the following procedures to classify a finding.

5.7.1.5.2.1.1 Review definitions of Major, Minor, and Concern. 5.7.1.5.2.1.2 Based on the definitions, assess all evidence supporting the finding. 5.7.1.6 Closing the Meeting: 5.7.1.6.1 The LE chairs the Closing Meeting and will use the Agenda to guide the meeting discussion. Attendees will include:

5.7.1.6.1.1 The evaluation team. 5.7.1.6.1.2 Evaluated division managers and/or process owners or designees. 5.7.1.6.1.3 Representatives of the evaluated divisions as determined by the division manager and/or process owner. 5.7.1.6.2 The LE will document attendance of the meeting in the minutes of the meeting. 5.7.1.7 Writing the Evaluation Report: 5.7.1.7.1 The LE will refer to the Safety Division Operating Instructions and follow the instructions on generating the evaluation report within the IEP database. 5.7.1.7.2 Process Evaluation and Action Request (PEAR) forms (SMS FM 18), (Reference Figure 5- 2) are attached to the report with an identified time frame for the manager, and/or process owner to respond (minimum of 10 business days.)

5.7.1.7.2.1 The PEAR form is used to document and communicate a nonconformance to an evaluation standard and to monitor and track corrective actions and/or corrections. 5.7.1.7.2.2 Evaluators will:

5.7.1.7.2.2.1 Complete the upper portion of the Process Evaluation and Action Request (PEAR) form for each finding and attach the PEAR forms to the evaluation report. 5.7.1.7.2.2.2 Avoid suggesting corrective actions when completing the form. 5.7.1.7.2.2.3 Explain what requirements were violated and how the audited activity failed to conform to the requirements. 5.7.1.7.2.2.4 Include all appropriate audit and objective evidence. 5.7.1.7.2.2.5 Document the nonconformity in a way that the problem can be recreated by the process owner.Safety Management System Manual 5-9

DRAFT 10 Jul 2009 Figure 5-2 – SMS FM 18 – PEAR Form5-10 Safety Management System Manual

DRAFT 10 Jul 2009 Table 5-2 – Instructions to fill out SMS FM 18 – PEAR Form Block Number

. Title Instructions

1 To (Division Manager or Process Owner Name) Enter the name of the Division Manager or Process owner

2 Airport SSF SAT Select the appropriate airport for which the audit is being accomplished 3 Date Enter the date of the evaluation

4 Evaluation Number Enter the Evaluation number IEP-10-NNNN (IEP-10-0001 – IEP 10 = year of the evaluation – 0001 is the consecutive number based on the number of the last report that was accomplished in 2010.

5 PEAR Number Enter the PEAR number “PEAR-10-NNNN” (PEAR-10-0001 – PEAR 10 = year of the evaluation – 0001 is the consecutive number based on the number of the last report that was accomplished in 2010.

6 IEP GROUP:

Airport OPS Parking Garages Facilities Facilities MX ARFF P & D Finance Environmental Airfield MX Building MXAirport Police Security Properties Fiscal Planning Communications IT Check the appropriate box – for the division that is being audited

7 Name of Lead evaluator Enter the name of the Lead evaluator 8 Name of Asst Enter the name of the Assistant evaluator

9 Findings: (Major Deviation: None Compliance / Minor Deviation: Complying with minor deviation / Concern: issues that need to be addressed) Major Deviation Minor Deviation Concern Follow-up Check the Appropriated box base on your knowledge of the importance of your findings Requirement of Standard Documents Enter the Requirement or Standard Document number or nomenclature Reference (Chapter and Paragraph / Clause) Enter the Reference the Chapter and Paragraph / clause from within the Requirement or Standard Document Statement of Requirements: Enter the specific requirement per the appropriate document as to what is to be accomplished or complied with Date Response Due Enter the date that was agreed to have response back to Safety/IEP Observations: Enter the your observations which should describe the cause and the details such as non-compliance frequency, etc 10 PEAR Finding by Lead Evaluator Print the name of the Lead Evaluator 10A Lead Evaluator Signature The Lead Evaluator will sign the form 10B Employee Number Enter the Employee number of the Lead Evaluator 10C Date Signed Enter the Date the Lead Evaluator Signed this form 11 PEAR Approved by SMS Manager Print the name of the SMS Manager 11A SMS Manager Signature The SMS Manager will sign the form after reviewing 11B Employee Number Enter the SMS Manager employee number 11C Date Signed Enter the Date the SMS Manager Signed this form 12 PEAR Accepted by Division Manager Print the name of the SMS ManagerSafety Management System Manual 5-11

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. Title Instructions

12A Division Manager Signature The Division Manager will sign the form after reviewing 12B Employee Number Enter the Division Manager employee number 12C Date Signed Enter the Date the Division Manager Signed this form 13 Corrective / Preventive Action Agreed Completion date Enter the date that was agreed to have corrective action completed by

Corrective Action Describe the steps to correct the observations as stated in Block 10 above. Agreed Completion date Enter the date that was agreed to have preventive action completed by

14 Action Approved by Division Manager Enter the medical treatment received (e.g. stitches, x-rays, medication cast, etc.) This information is needed for OSHA.

14A Division Manager Signature Division Manager will sign PEAR form once he has agreed to the corrective action 14B Employee Number Enter the division manager employee number 14C Date Signed Enter the date the Division Manager signed this form 15 Agrees with Action Lead Evaluator Enter the name of the doctor who is providing treatment

15A Lead Evaluator Signature Lead Evaluator will sign PEAR form one he has agreed to the corrective action submitted by the division manager 15B Employee Number Enter the Lead Evaluator employee number 15C Date Signed Enter the date the Lead Evaluator signed this form 16 Action Approved by SMS Manager Enter the name of the SMS manager

16A SMS Manager Signature SMS Manager will sign PEAR form once he has agreed to the corrective action submitted by the SMS Manager 16B Employee Number Enter the SMS Manager employee number 16C Date Signed Enter the date the SMS Manager signed this form

17 Notes (Enter any extension dates and pertinent comments) Enter any notes that are important to the process

18 Corrective / Preventive action implementation and effectiveness verified and PEAR Closed by: The SMS Manager will verified the accuracy of the implementation and effectiveness of the PEAR document and if in agreement close the report by entering a date here 19 PEAR closed by Name of SMS Manager Enter the name of the SMS manager

19A SMS Manager Signature SMS Manager will sign PEAR form once he has agreed to close the PEAR 19B Employee Number Enter the SMS Manager employee number 19C Date Signed Enter the date the SMS Manager signed this form

5.7.1.8 Management Review and Evaluation Report Distribution: 5.7.1.8.1 The LE will distribute the report to the evaluation team members and SMSMGfor review. 5.7.1.8.2 If the report is rejected by the SMSMG, the LE and possibly division managers or process owners are contacted for further clarification. The report will be revised and resubmitted to the SMSMG, and IEP for final approval. 5.7.1.8.3 Once the SMSMG, approves the report, it will be distributed to process owners or division managers. 5.7.1.9 Developing Corrective Action Plans: 5.7.1.9.1 Division Manager or Process Owner’s Response to Corrective Action Request:5-12 Safety Management System Manual

DRAFT 10 Jul 2009 5.7.1.9.1.1 The team issued, pre-defined and agreed upon time frame in the evaluation report for the process owner to review and respond to the corrective action requests identified in the PEAR form(s) (minimum of 10 business days.) 5.7.1.9.1.2 The division manager or process owner will submit the PEAR form(s) to the LE once the corrective action section of the PEAR form(s) is complete, If additional time is needed, the division manager or process owner will contact the LE to discuss and identify a revised completion date. 5.7.1.10 IEP Response to Corrective Action Plans: 5.7.1.10.1 Once the LE receives the completed PEAR forms from the process owner, he will assign them to the evaluation team to review. Evaluators will consider the following guidelines when reviewing corrective action plans:

5.7.1.10.1.1 A corrective action should eliminate the cause of the nonconformity, and should identify and change the source of the problem to prevent reoccurrence. 5.7.1.10.1.2 A corrective action is typically performed when the problem has an assignable cause that is economically feasible to research, or is required by regulations to be analyzed and fixed. 5.7.1.10.1.3 The nonconformance could be resolved with a correction, not a corrective action. For example, a single document found out of control can be resolved with a correction. 5.7.1.10.1.4 If the evaluator determines the corrective action plan is incomplete or inadequate, he will contact the process owner to discuss the plan. If the evaluator and process owner cannot agree on a corrective action plan, the evaluator will provide a copy of the PEAR form to the SMS Manager to review. 5.7.1.10.1.5 If the SMSMGand IEP LE determine the corrective action plan is inadequate, the LE will return the PEAR form to the process owner for rework. 5.7.1.10.1.6 If the SMSMGand IEP LE determine the corrective action plan is adequate, the LE will work with the process owner to establish completion dates for corrections and/or corrective actions. 5.7.1.10.2 The Corrective Action Phase (CAP) Flow Chart depicts the steps followed in developing CAPs (Reference Figure 5-3). 5.7.1.11 Follow-up Evaluation: 5.7.1.11.1 The follow-up evaluation is the final phase of the evaluation cycle and will be performed by Safety Division personnel to ensure the corrections and corrective actions are implemented and effective. 5.7.1.11.2 The LE will identify a date for the follow-up evaluation as soon as practical and document this in the IEP database. Ideally, the LE will try to schedule the follow-up evaluation no later than 30 days after the completion date for the corrections or corrective actions. Due to the dynamic nature of the Safety Division, the scheduling of follow-up evaluations may need to be adjusted. 5.7.1.11.3 The LE may decide to notify the process owner of the follow-up evaluation date or may conduct the evaluation unannounced. 5.7.1.11.4 The LE will ensure the follow-up evaluation objective is achieved by verifying that the corrections or corrective actions implemented by the division manager or process owner addressed the findings documented in the initial evaluation.

5.7.1.11.4.1 Once the LE determines that corrective action plans have been effectively implemented, he will update the IEP database.Safety Management System Manual 5-13

DRAFT 10 Jul 2009 Figure 5-3 – IEP Corrective Action Phase Flow Chart5-14 Safety Management System Manual

DRAFT 10 Jul 2009 5.8 Special Evaluations: 5.8.1.1 The SMSMGand IEP has the responsibility and authority to initiate special evaluations when safety concerns are identified or organizational priorities are shifted. Authorized personnel will consider the following factors when determining whether a special evaluation is needed: 5.8.1.2 FAA concerns: 5.8.1.2.1 Top management priorities or concerns 5.8.1.2.2 Middle management request 5.8.1.2.3 Industry identified trends 5.8.1.2.4 Apparent violations of regulations 5.8.1.2.5 Trends identified through the Company’s

5.8.1.2.5.1 Voluntary Safety Report 5.8.1.2.5.2 Confidential Reporting System 5.8.1.2.5.3 Accident / Incident investigations 5.8.1.3 Special evaluations will generally be unannounced and may take precedence over planned evaluations. Special evaluations will be performed utilizing the same methods and procedures as described in this manual. 5.8.1.4 The LE is responsible for scheduling special evaluations and will amend the Master Schedule to include special evaluations as necessary. 5.9 Communications and Reports: 5.9.1.1 The SMSMGand IEP are responsible to brief the Assistant Aviation Director Operations quarterly, or as requested, regarding the following IEP issues. 5.9.1.1.1 Results of comprehensive evaluations 5.9.1.1.2 Results of special evaluations 5.9.1.1.3 Systemic trends identified through ongoing evaluations 5.9.1.1.4 Status of follow-up actions taken in response to evaluation findings 5.9.1.1.5 Staffing, training, equipment, software and resource needs 5.9.1.1.6 Evaluation schedule 5.9.1.1.7 Any other information deemed pertinent 5.9.1.1.8 Quarters are based on a calendar year 5.10 Program Evaluation: 5.10.1 Every year the SMSMGwill locate and schedule an independent, external vendor to perform an IEP evaluation. 5.10.1.1 The SMSMGwill receive the evaluation report directly from the vendor and distribute it to top management. 5.10.1.2 All authorized personnel will review the report to determine time lines for responding to noted deficiencies/findings. 5.10.1.3 The SMSMGwill document findings and identify who is responsible to correct the deficiency. 5.10.1.4 The SMSMG must respond to the Assistant Aviation Director Operations and SMS Executive Committee concerning noted deficiencies/findings within agreed upon time lines.

5.11 Forms A. Evaluation Preparation Checklist (SPM FM 10) 1) Purpose a. IEP evaluators use this form to guide them while preparing for an evaluation ((Ref. Figure 5-2)). Refer to the Records Management Section 5.3 of this chapter for information regarding record retention 5.11.1Safety Management System Manual 5-15

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