JACKSONVILLE AVIATION AUTHORITY

Safety Management System (SMS) Gap Analysis

Version 1.0

08 November 2007

presented to

Roger Studenski, Risk Manager Administrator

Jacksonville Aviation Authority (JAA)

Jacksonville International Airport (JAX)

INTERNATIONAL SAFETY

RESEARCH
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INTERNATIONAL SAFETY RESEACRH

TABLE OF CONTENTS

1. Introduction.......................................................................................................................1

2. Summary of gaps...............................................................................................................2

Annex A. Gap Analysis data sources ................................................................................3

Annex B. JAX Gap Analysis tables....................................................................................5
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1. INTRODUCTION

The Jacksonville Aviation Authority (JAA) selected Applied Research Associates (ARA) and

International Safety Research (ISR) to conduct a Safety Management System (SMS) Gap

Analysis and develop an implementation plan as part of the FAA SMS Pilot Project. The Gap

Analysis team was on-site at JAX from 06 to 08 November 2007. This report presents the

observations collected during this assessment

1.1 Scope

The scope of this Gap Analysis includes identification of existing safety programs and processes

in operations and organizational documentation from the following areas:

 Operations

 Emergency Response (ARFF)

 Security (JAAPD)

 Infrastructure and Technology

 Marketing and Business Development

 Human Resources

 External interfaces (FAA, FBOs, Tenants, Etc)

The GA does not target:

 Assessment of facilities or processes within the airport that are not directly related to the

safety of aircraft operations (i.e.: Parking, Groundside operations, etc);

 Assessment of safety practices of companies or organizations other than JAA operating at

Jacksonville International Airport; and

 Assessment of any other applicable Health and Safety requirements, such as those that might

be required by state, or federal regulations.

1.2 Gap Analysis process

During the Gap Analysis, information on existing safety processes and practices was collected

through document review, site visits, observations and interviews with a cross-section of JAX and

JAA employees and external organizations. A list of documents reviewed, persons interviewed

and other activities pertinent to this exercise are presented in Annex A. As the FAA SMS

regulations are not yet in place for Airport Operators, this information was assessed against the

evaluation criteria published by international standards organizations, FAA AC150/5200-371, and

aviation SMS best practice.

1.3 SMS implementation planning

The team will use the information collected during the Gap Analysis to develop an SMS Manual

outline that will meet JAX-specific needs. Based on this outline, the specific SMS processes will

be developed in close coordination with JAX staff. These processes will serve as the basis for an

implementation plan that will support realization of SMS at JAX.

1

Introduction to Safety Management Systems (SMS) for Airport Operators, Federal Aviation Authority, 28

February, 2007
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2. SUMMARY OF GAPS

The Gap Analysis revealed that JAA /JAX management is committed to SMS implementation.

There is a positive attitude and belief that safety is important across the organization. In addition,

the Aviation Authority has demonstrated a commitment to safety by taking initiative and starting

the SMS development process in advance of the SMS regulation through participation in the FAA

SMS Pilot Project. The assessment team also found that the building blocks for many of the

required SMS elements already exist in some form; however, in general, many existing processes

are not formalized.

The main gaps are as follows:

 Safety policies do not specifically address airside safety and some key elements are absent;

including a statement reassuring employees that they can report safety concerns and errors

without fear of punishment.

 There is no process for establishing and measuring comprehensive safety goals and

objectives.

 Safety roles and responsibilities for employees at all levels and across all departments are not

thoroughly defined, including a designated Accountable Executive.

 Processes for communication, including feedback and sharing of lessons learned between

groups, are not formalized (defined and documented) or used consistently throughout the

organization and with external service providers.

 Procedures to develop, approve, distribute, periodically review and update all safety and

operational documentation and records, including version control and disposal, are scare and

where they do exist, are not formalized.

 Except for isolated examples, there is no defined process for the proactive identification of

safety hazards or analysis of associated risk (associated with either conventional airside

safety hazards or organizational change). The event investigation process does not

systematically include the identification of potential contributing factors. Affected personnel

and groups are not systematically informed of the results of investigations or corrective

actions.

 The process to determine training needs is not comprehensive; and there is no formal process

to evaluate the effectiveness of training received.

 There is no internal mechanism to assure that the programs, processes and procedures used by

JAX/JAA are effective and meet the needs of the organization (i.e. quality assurance).

 There is no mechanism used to support the integration of JAX safety processes with those of

tenants and operators on the airside.

The observations against each SMS requirement are detailed in Annex B JAX Gap Analysis

tables.
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ANNEX A. GAP ANALYSIS DATA SOURCES

A.1 DOCUMENTS REVIEWED

o ACM -Airport Certification Manual Section 1-22

o ACM -Airport Certification Manual Section 23

o ACM -Airport Certification Manual Appendix A; B and C

o ACM -Airport Certification Manual Section 24 Exhibits A-G

o Approved Safety Equipment

o Asbestos and Lead

o Confined Spaces

o Employee Safety Manual

o Environmental Compliance review Program

o Facility Safety Audit Program

o GASP Form –Final July 2007 General Aeronautical Services Permit

o Analysis Procedures for Injuries, illness and near-miss incidents.

o Hazard Comm. Program

o HAZCOMM Program as required in above document

o Hazardous waste contingency

o Hearing Conservation

o Industrial Waste

o AOCC Handbook

o Movement Area Training Program and Records

o Ground side and movement area incident reports

o Strategic Agenda 2005/2010

o Daily Airfield Inspection Form

o NOTAM Forms

o Airport Rules and Regulations – including SOP manual (draft)

o Tenant inspection checklist (Leasehold Compliance Inspection)

o Minutes of Operations and Safety Meetings

o Job Description for Duty Managers

o Job Description for Supervisor of Operations

o JQR – list of min. requirements of what a person needs to know to do their job. (must be

completed within 30 days of issuance)

o Daily Construction Inspection checklist
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A.2 INTERVIEWS PERFORMED

During the site visit the team met with a cross-section of JAX employees representing key

departments involved in daily airport operation. The team also met with tenants, FBOs and airline

operators. More than 30 interviews were conducted with representatives from the following

departments:

o Risk Management

o Airport Operations Control Centre

o TSA Operations representative

o FAA/ACTC

o Director of Aviation Management

o Facilities & Maintenance

o JAAPD

o Employee Relations / Customer Service

o Planning & Engineering

o ARFF

o Signature

o Sheltair

o Delta Airways

o U.S. Airways

A.3 OTHER ACTIVITIES

A site tour including the JAX apron, FAA ACTC, Fuel farms, FBOs, FireHall, Cargo Facilities,

Mail Processing Facility, was conducted on the first day of the gap Analysis as part of the team’s

familiarization with JAX operations.
.

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ANNEX B. JAX GAP ANALYSIS TABLES

1. SAFETY POLICY AND OBJECTIVES

Expectations

(Specific expectation and best practice)

Organization reference REMARKS

1.1 Management commitment and responsibility

1.1.1 Policy Strategic Agenda 2005/2006,

JAA

Corporate objective to be at the leading edge of airport

developments – this includes pursuing safety

management and a risk management plan

1.1.1.1 A safety policy is in place (documented). Employee Safety Handbook There is a policy in place which could be expanded to

address SMS

1.1.1.2 The safety policy is approved by top

management.

“ No signature and outdated (printed version)

1.1.1.3 The safety policy is promoted by top

management.

Verbal commitment to safety as part of business

improvement program

1.1.1.4 The safety policy is reviewed periodically. No evidence of review process or procedures

1.1.1.5 There is a policy in place that ensures that

employees are free to report safety deficiencies, hazards

or occurrences without being subject to unjust discipline.

No evidence

1.1.1.6 The policy includes a commitment to

continual improvement.

Strategic Agenda 2005/2006,

JAA

Verbal commitment to business improvement

1.1.1.7 The policy includes a commitment to comply

with applicable legislation and other requirements to

which the organization subscribes.

No evidence

1.1.1.8 The safety policy is effectively

communicated within the organization. Employees are

aware of the policy, and their SMS obligations.

Employee Safety Handbook No evidence, other than OSH

1.1.1.9 The safety policy is effectively

communicated to external parties, including contractors

and visitors.

Employee Safety Handbook No evidence, other than OSH

1.1.1.10 The policy is generally reflected in the safety

practices.

Employee Safety Handbook No evidence, other than OSH
.

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1. SAFETY POLICY AND OBJECTIVES

Expectations

(Specific expectation and best practice)

Organization reference REMARKS

1.1.2 Objectives Strategic Agenda 2005/2006

Employee Safety Manual

AOCC Objectives and mission

Set of strategic business objectives, published and

occupational safety objectives, AOCC mission and

vision posted outside door but no safety-specific

targets

1.1.2.1 Safety objectives are established and

documented for each relevant function within the

organization

No evidence

1.1.2.2 Safety objectives are publicized and

distributed.

Strategic Agenda 2005/2006 Safety appears in strategic objectives but there are no

safety focused objectives

1.1.2.3 A coherent set of safety goals are developed

based on objectives.

No evidence

1.1.2.4 The results of hazard identification and risk

assessments are considered while setting SMS objectives

(see 2.1).

No evidence

1.1.2.5 Objectives are established consistent with the

commitment to continual improvement.

No evidence with respect to aviation safety

1.2 Safety accountabilities of managers

1.2.1 A top manager is assigned, with responsibility

and accountability for ensuring that the SMS is properly

implemented and performing to requirements in all areas

of the organization.

JAX is in the early stages of SMS development. The

Director of Aviation Management is assuming this role

at this time

1.2.2 The top manager accountable for SMS has

control of the financial and human resources required for

the proper execution of their SMS responsibilities.

Based on the information collected the Director of

Aviation Management seems to fulfill the requirement

1.3 Appointment of key safety personnel

1.3.1 A qualified person has been appointed to oversee

the implementation and operation of the SMS.

Job descriptions currently under

review

The Risk Management Administrator has been

appointed to oversee SMS
.

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1. SAFETY POLICY AND OBJECTIVES

Expectations

(Specific expectation and best practice)

Organization reference REMARKS

1.3.2 The safety authorities, responsibilities and

accountabilities of personnel at all levels of the

organization are defined and documented.

Not directly in line with SMS, however the OSH

program considers these requirements.

1.3.3 The organizational structure facilitates

communication between the SMS manager, the top

accountable manager and line managers.

Yes

1.3.4 All those with management responsibility

demonstrate their commitment to continual improvement

of SMS performance.

There is a positive attitude and belief that safety is

important amongst those individuals with management

responsibilities interviewed.

1.3.5 All personnel understand their authorities,

responsibilities and accountabilities in regards to all safety

management processes, decisions and actions.

Not clearly communicated as there is no airside safety

program at this time.

1.4 SMS implementation and management

1.4.1 There is a strategic SMS implementation (or

management) plan including assignment of roles and

responsibilities, means and timelines for completion.

A strategic approach for SMS implementation will be

the output of the SMS Pilot Project – The

implementation plan will be developed in the final

phase of this project.

1.4.2 The planning process is conducted at regular,

planned intervals, by an SMS planning group, including

the SMS coordinator/facilitator.

See 1.4.1
.

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1. SAFETY POLICY AND OBJECTIVES

Expectations

(Specific expectation and best practice)

Organization reference REMARKS

1.5 Documentation

1.5.1 Legal and other requirements

1.5.1.1 Relevant information on legal and other

requirements is communicated to employees and other

interested parties.

Passive process relies on notification from FAA

inspectors for AOCC requirements.

Facilities maintenance has an informal process for

annual updates to electrical requirements and building

codes.

1.5.1.2 License and permit requirements are in place,

and legal requirements implemented.

Yes. Passed FAA inspection in 2007.

1.5.2 SMS Documentation

1.5.2.1 There is consolidated documentation that

describes the SMS and the interrelationships between all

its components.

See 1.4.1. Refer to the objectives of this project.

1.5.3 Documentation and data control

1.5.3.1 Procedures for document control are

established.

Classification, retention and disposal processes are in

place at JAA. Process needs further development
.

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1. SAFETY POLICY AND OBJECTIVES

Expectations

(Specific expectation and best practice)

Organization reference REMARKS

1.5.3.2 Documents are periodically reviewed,

revised as necessary, and approved by authorized

personnel.

ACM

AEP

ARR

There is a process for revision of the ACM by AOCC

staff on an annual basis. However other documents,

including “Rules & Regulations” have been drafted

but not approved.

It is not clear who is authorized to issue documentation

related to JAX operations, including the ones posted in

the JAA Intranet.

JAX system is not linked to the JAA system for

documentation development and approval.

1.5.3.3 Obsolete documents are protected against

unintended use and retained documents are identified.

No evidence

1.5.3.4 Current versions are available at all relevant

locations.

Up to date documentation is available on the intranet

but not widely used.

Documentation control is not evident.
.

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1. SAFETY POLICY AND OBJECTIVES

Expectations

(Specific expectation and best practice)

Organization reference REMARKS

1.5.4 Record and records management

1.5.4.1 The organization has a records system that

ensures the generation and retention of all records

necessary to document and support operational

requirements, in accordance with applicable regulatory

requirements and industry best practices.

AOCC Handbook

Movement Area Training

Program and Records

Processes are informal. However, AOCC has a records

system that is working well for mandatory reportable

incidents and training records for the Movement Area

training program.

There is a work order system and PM system for

facilities maintenance. (CMMS)

Training records are also kept and evident in the

AOCC

Jet Bridge training records not kept by JAX

1.5.4.2 The system provides the control processes

necessary to ensure appropriate identification, legibility,

storage, protection, archiving, retrieval, retention time,

and disposition of records.

Records appear to be in good order and are retained in

accordance with legal requirements.

No formal or standardized processes.
.

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2. SAFETY RISK MANAGEMENT

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

2.1 Hazard identification

2.1.1 Hazard identification process

2.1.1.1 A procedure for the identification of hazards

and assessment of risks is established and the

methodology is defined.

Daily Construction Inspection

checklist

Mostly checklist approach

Daily runway and airside checks, multiple reporting

systems and surveillance which serves as reactive

reporting.

Construction daily inspection.

No formalized proactive hazard id.

2.1.2 Reporting systems

2.1.2.1 There is a reporting process, which is simple

and accessible.

Ground side and movement area

incident reports

No formal process for hazard reporting, but 2020/2040

exists for incident reporting.

Informal reporting but no supported by documentation

(e.g. facilities maintenance keeping track of

contractors dropping FOD on the runway or

inappropriate storage, weekly meetings with foremen).

There is a widely used and accessible maintenance

reporting and tracking system (DataStream).

2.1.2.2 Reports are reviewed at the appropriate level

of management.

See 2.1.2.1 no hazard reports generated. Mandatory

incidents are reviewed for liability. There is an OSH

process in the safety handbook – but no evidence that

it is used.

2.1.2.3 There is a feed back process to notify

contributors that their reports have been received and to

share the results of the analysis.

No – this is only done through initiatives of

individuals (e.g. maintenance)

Closest thing to a feedback process is the customer

improvement program and survey feedback.

2.1.2.4 All identified hazard data are systematically

recorded, stored and analyzed.

No evidence
.

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2. SAFETY RISK MANAGEMENT

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

2.1.2.5 There is a system to share significant safety

event information with other similar organizations, subject

to reasonable restriction on proprietary and confidential

information.

No evidence

2.2 Risk assessment and mitigation processes

2.2.1 Risk assessment

2.2.1.1 There is a structured process for the

assessment of risk associated with identified hazards,

expressed in terms of severity and probability of

occurrence. (see also 1.5)

No evidence.

2.2.1.2 Risk assessment procedures cover all

facilities, routine-non routine activities, and personnel

having access to the workplace (including visitors,

subcontractors, etc).

No evidence other than security risk and access control

working group, and OSH

2.2.1.3 Criteria are established for evaluating risk

and the level of risk the organization is willing to accept.

This concept is being applied to financial liability and

associated risk.

2.2.1.4 The results of the risk assessment are taken

into account in the development of facilities, equipments,

procedures, training, etc. (see 4.1) (see 2.2.1)

No evidence

2.2.1.5 Results of hazard identification and risk

assessments are considered while setting SMS objectives.

(see 1.1.2)

See 1.4.1
.

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2. SAFETY RISK MANAGEMENT

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

2.2.2 Operating procedures

2.2.2.1 Operations and activities associated with

identified risks, where control measures need to be

applied, are identified. (see 2.1. and 2.2)

Airport Certification Manual,

AEP, ESM

There is specific evidence that SOPs are implemented

and used, sometimes going beyond regulatory

requirements. (AOCC)

2.2.2.2 Operating procedures requirements cover all

activities and facilities, especially in activities where their

absence could lead to deviations from the policy, safety

objectives and / or regulatory requirements.

ARR Informal procedures for operations, not centrally

stored other than ACM – which does not seem to be

used outside the AOCC.

The Rules and Regulations manual contain most of the

procedures that will satisfy these requirements,

however it has not been approved.

2.2.2.3 The SMS specifically addresses the

coordination of SMS interfaces with external

organizations, including service providers, suppliers, subcontractors, etc.

See 1.4.1

2.2.2.4 Operating criteria are stipulated in the

procedures.

Refer to 2.2.2.2

2.2.3 Corrective action plans

2.2.3.1 Corrective and preventive actions are

generated in response to risk assessment or event analysis.

No evidence

2.2.3.2 The organization evaluates the effectiveness

of the corrective / preventive measures that have been

developed.

No evidence

2.3 Internal safety investigations
.

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2. SAFETY RISK MANAGEMENT

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

2.3.1 There is a process to ensure that all reported

occurrences and deficiencies are investigated.

Mostly liability related and for OSH have a process–

Not applied with the objective of identifying safety

hazards and root causes.

There are limited informal processes looking for root

causes

2.3.2 Investigations are targeted towards identification

of the root-cause, and consider human and organizational

factors in the analysis.

No evidence

2.3.3 There is a process to identify lessons learned

from safety-significant events from other organizations.

No evidence
.

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3. SAFETY ASSURANCE

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

3.1 Safety performance monitoring and

measurement

3.1.1 Performance monitoring and measurement

3.1.1.1 There are safety performance indicators and

safety performance targets directly related to safety

objectives (see 1.1.2).

No evidence

3.1.1.2 There is a process for reviewing the

adequacy / appropriateness of safety performance

indicators.

No evidence

3.1.1.3 Procedures to monitor and measure SMS

performance on regular basis are established.

See 1.4.1 - Trend analysis is done with respect to

OSH

3.1.1.4 There is a process and / or procedures to

ensure calibration and maintenance of monitoring

equipment.

Applies to third parties operating within the airport.

No evidence of JAX process in place to monitor

results.

3.1.2 Audit

3.1.2.1 The organization conducts reviews and audits

of its processes, its procedures, analyses, inspections and

training.

Strategic Plan 2005/2010 Evidence that there are processes for OSH and the

Environment. But not related to aviation safety other

than Part 139 – SEE PG10 OF THE STRATEGIC

PLAN

AOCC does training review.

3.1.2.2 There is an operationally independent audit

function with the authority required to carry out an

effective internal evaluation program.

No evidence

3.1.2.3 Audits address all functions, activities and

groups within the organization.

No evidence
.

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3. SAFETY ASSURANCE

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

3.1.2.4 There are defined audit scope, criteria,

frequency and methods.

No evidence - annual inspection of tenants to ensure

that lease agreements are complied with

3.1.2.5 Audits take into account identified risks and

previous audit results.

No evidence

3.1.2.6 Audits are carried out based on an approved

and recognized SMS set of requirements.

See 1.4.1

3.1.2.7 SMS evaluators / auditors are trained and

qualified.

No evidence

3.1.2.8 Audit results are acted upon. No evidence

3.2 The management of change

3.2.1 There is a process in place for analyzing changes

to operations or key personnel for risks.

No evidence (example elimination of Airport

Manager). There evidence that some informal

processes take place but they do not follow a

systematic approach.

3.2.2 Proposed corrective and preventive actions are

reviewed through risk assessment.

See above.

3.2.3 There is a procedure to record verification of

action(s) taken and the reporting of verification results.

No evidence

3.3 Continuous improvement of the safety system

3.3.1 Continuous improvement is an inherent part of

the safety objectives at all levels of the organization.

Evident in business improvement objectives and

strategic plan as well as actions taken by managers –

for example the pursuance of this Pilot Project

3.3.2 Regular and periodic, planned reviews are

conducted regarding organization safety processes and

performance, with the objective of identifying

opportunities for improvement.

No evidence
.

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3. SAFETY ASSURANCE

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

3.3.3 Major decisions and actions aimed at improving

safety are monitored for their effectiveness and further

action is taken when the expected risk benefit is not met.

No evidence

3.3.4 Managers are kept informed of the internal safety

reviews, planned and implemented corrective actions.

No evidence

3.3.5 There is an annual management review of the

entire SMS.

See 1.4.1

3.3.6 The results of the management review are

documented.

See 1.4.1
.

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4. SAFETY PROMOTION

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

4.1 Training and education

4.1.1 Training requirements are defined so that

personnel are competent to perform their duties.

JQR exists; not clear who writes them.

4.1.2 Appropriate training is provided. (see 2.2.1) This

includes specialized training to personnel involved in

safety-critical tasks, general SMS training to all personnel,

and SMS training for new employees as part of the

indoctrination training.

No centralized training records or responsibility to

ensure that training s taking place.

There is indoctrination & recurrent training for AOCC

and informal for other areas.

Safety training is seen to be the responsibility of Risk

Management. No SMS training in place. However

monthly safety trainings are run and made available

for all staff.

4.1.3 Training effectiveness is measured. (see 3.1.2) Formalized procedures for specific activities are in

place. Informal processes in other areas.

HR is moving in the direction of evaluating the

impact/effectiveness of professional development.

.

4.1.4 There is emergency preparedness and response

training for affected personnel (see 1.5).

Yes. Evidence based on regular exercises conducted

by Police, Ops, Police and ARF do maintain training

records.

4.1.5 Training records are maintained. (see also 1.6.4) Yes. Corporate training maintained at HR. Other

records are kept, but decentralized. Managers can pull

records from HR on request.
.

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4. SAFETY PROMOTION

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

4.2 Safety communication

4.2.1 The free exchange of safety information, across

all areas and through all levels, both vertically and

horizontally, is actively promoted by management and

facilitated by mechanism and processes.

o Monthly safety meeting /

training

o Monthly operations meetings

(run by Izzy, with Airlines,

tenants, etc)

o Quarterly Runway Safety

Meetings (Run by FAA)

o FAA ATCT Quarterly

Customer Forum (Sept 18,

2007)

o AOCC Weekly Managers

o Semi-annual Wildlife

workgroup meeting.

o Weekly Operations Staff.

Meeting (Izzy staff meeting)

Meeting Agenda (October

11, 2007)

o Terminal Expansion

meetings

o Tenant advisories (bulleting)

o Monthly JAA Managers

meeting

o Weekly foreman meeting

Existing processes: Monthly Operations meetings,

quarterly safety meetings with tenants and FAA.

Some meetings have no minutes either issued or

distributed.

No formalized corrective action or feedback process

4.2.2 Employees are involved / consulted in the

development and review of policies and procedures to

manage risks. (linked to 1.6.4)

No evidence for safety risk management procedures
.

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4. SAFETY PROMOTION

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

4.2.3 There are multi-disciplinary, multi-level safety

committees, or operational committees for which safety is

a standing agenda item, and where SMS-related issues are

critically assessed and objectively discussed.

No evidence, however verbally confirmed that in some

meetings safety is a standing item on the agenda

4.2.4 The results of safety coordination meetings are

communicated to all employees.

No evidence. No minutes are issued/transmitted

4.2.5 Safety information is disseminated throughout the

organization and the effectiveness of this process is

monitored.

Intranet is one tool used to disseminate ‘safety-grams’

and monthly safety meetings/training.

No evidence of evaluation for effectiveness
.

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5. EMERGENCY PLAN

Expectations

(Specific Expectation and best practice)

Organization reference REMARKS

5.1 Coordination of the emergency response plan

5.1.1 Potential emergency situations and incidents are

identified.

AEP Yes

5.1.2 The organization has emergency response

procedures appropriate to the size and scope of their

operations and identified potential emergency situations

and incidents (see 5.1.1).

AEP Yes.

5.1.3 The emergency response procedures are

documented, implemented and assigned to a responsible

manager.

AEP Yes

5.1.4 The organization has a process to coordinate

emergency planning, distribute the emergency response

plan and procedures and communicate the content to all

relevant personnel.

AEP Yes, including NIMS training

5.1.5 Emergency response teams are properly trained

(see 4.1).

Yes

5.1.6 The organization conducts drills and exercises

(where practicable) with all key personnel, at specified

intervals.

Yes

5.1.7 The emergency response procedures are

periodically reviewed as part of the management review

of the SMS, and after key changes, including

organizational and personnel changes.

Yes it is reviewed.
.

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JAA SMS Gap Analysis Report ARA ISR Report

INTERNATIONAL SAFETY RESEACRH