Distribution: Electronic Only Initiated By: AFS

- 900 

# NOTICE **U.S. DEPA RTMENT OF TRA**  **NSPORTA TION** 

FEDERAL AVIATION ADMINISTRATION N 8900. 281

National Policy Effective Date: 1 / 8 / 15 Cancellation Date: 1 / 8/16

**SUBJ:** Safety Management Systems (SMS)

– Approval of P art 121 Certificate Holders’ SMS Implementation Plans
**1. Purpose of This Notice**  **.** This notice provides guidance for Federal Av iation Administration (F AA) Flight Standards Service (AFS) personnel on the approval o f Ti tle 14 of the Code of Federal Regulations (14 CFR) part 121 certificate holders’Safety Management Sy stem (SMS) implementation plans, as required b y 14 CFR part 5, § 5.1(b) and (c). **2. Audience**  **.** The primary audience for this notice is F AA AFS personnel in headquarters (HQ) branches, divisions, regions, and field of fices. This notice will af

fect of fices with direct responsibilities for oversight of certificate holders authorized to conduct operations in accordance with the requirements of part 121. The seco ndary audience includes Flight Standards branches and divisions in the regions and in HQ. **3. Where You Can Find This Notice**  **.** Yo u can find this notice on the MyFAA employee Web site at https://employees.faa.gov/tools_resources/orders_notices. Inspectors can access this notice through the Flight Standards Information Management S ys tem (FSIMS) at http://fsims.avs.faa.gov. Operator s can find this notice on the Federal Av iation Administration’ s (F AA) W eb site at http://fsims.faa.gov. This notice is available to the public at http://www.faa.gov/regulations_policies/orders_notices. **4. Regulatory Requirement**  **.** Inaccordance with part 5, a c ertificate holder must submit an implementation plan to the F AA A dministrator for review no later than September 9, 2015. The implementation plan must be approved no later than March 9, 2016. **5. References**  **.** During evaluation of the certificate holder ’s implem entation plan, Certificate Management Team (CMT) inspectors may have occasion to work with an y, all, or none of the following documents/tools, in addition to part 5, when evaluating the certificate holder ’s implementation plan.

**a. Related Publication.**  The cur rent edition of AC 120

- 92, Safety Management Systems for Av iation Service Providers.1/8 /15 N 8900. 281

2 **b. To**  **ols.** (1) The Air T

ransportation Oversight S ys tem (A TOS) SMS Design Assessment Supplement (DAS) Constructed Dy namic Observation Report (ConDOR) and/or the SMS Performance Ass essment Supplement (P AS) ConDOR Data Collection T ools (DCT). (2) The AT OS SMS Safety A ttribute Inspection (SAI) DCTs for Element 8.1.1, Safety Policy (OPS/A WS); Element 8.2.1, Safety Risk Management (OPS/A WS); Element 8.3.1, Safety Assurance (OPS/A

WS); and Ele ment 8.4.1, Safety Promotion (OPS/A

WS). 1 (3) The 14 CFR Part 5 Gap Analy sis To ol for any certificate holder that chooses to use it for their part 5 implementati o n p lan development. (4) The W

eb

- Based Application To ol (WBA T), SMS Implementation Plan Manager Module. **Note:** Certificate holders may develop their implementation plans in any manner and/or medium that meets their needs and is acceptable to the CMT. The above tools/documents are only suggestions. Certificate holders in the SMS Pilot Project ( SMSPP ) 2 may

continue t o develop their SMSs with the Detailed Gap Anal ysis Tool (or the Part 5 Gap Analy sis Tool). The gap anal ys is tools, combined with Appendix A, will ensure part 5 compliance. **6. General Guidance**  **.** The following resources are available to a CMT during a certific ate holder ’s SMS implementation plan development and approval process.

**a. Flight Standards National Field Office (AFS** 
**- 900).**  (1) SMS Program Office (SMSPO). The SMSPO is the national point of contact (POC) for F AA HQ and field divisions in development of SMS policies, procedures, and work instructions. The of

fice is responsible for AFS SMS standardization, training, and guidance

. (2) Implementation Support Te am ( IST )

. The SMSPO manages an IS T. Part of the SMSPO, the I STis the primary interface between the SMSPO and principal inspectors (PI), CMTpersonnel, field offices, and divisional SMS specialists. The IST provides briefings, orientation sessions, meetings, and/or seminars, as required. SMS I STmembers will provide guidance, facilitation, and suggestions on SMS issues to both the CMTand the certificate holder

. This service is expected to be available to existing certificate holders and their respective CMT s throughout the part 5 SMS implementation period. (3) SMSP O assistance can be obtained b y emailing the SMSPO National Coordination at 9

-NA TL

- SMS

- ProgramOf

fice@faa.gov

.

1 As ATOS is replaced by the Safety Assurance System (SAS), equivalent SAS tools and processes will be utilized in place of ATO S. 2 The SMS Pilot Project was replaced in August 2014 with the SMS Voluntary Program (SMSVP) . The SMSVP is based on part 5.1/8 /15 N 8900. 281

3 **b. Regional Point of Contact (RPOC).**  Most F AA r egional Flight Standards division (RFSD) o ffices have an SMS RPOC. RPOCs are part of the regional staf f and, with the assistance of the SMSPO, stay abreast of the latest SMS developments and information. **7. Implementation Plan Review and Analysis Process**  **.** Procedures for review and anal ys is of the certificate holder ’s implementation plan should follow guidance contained in F AA Order 8900.1, V olume 3, Chapter 1, The General Process for Approval or Acceptance.

**a. What is an Implementation Plan?**  (1) The implementation plan is simply a roadmap describing how the certificate holder intends to implement processes that meet the requirements of part 5. Therefore, the implementation plan should be a realistic strategy for managing SMS implementation. (2) The implementation plan need not be complex. However , there should be suf

ficient detail to ensure that the certificate holder wil l meet the overall objective stated in part 5 : “to develop and implement a safety management s ys tem (SMS) to improve the safety of aviation

- related activities” by March 9, 2018. **b. Receipt of a Certificate Holder’**  **s Implementation Plan.** When the CMTreceives an SMS implementation plan from the certificate holder (per Order 8900.1 , V olume 3 , Chapter 1 , Section 1 , paragraph 3

- 3, Phase T wo), the CMTwill: (1) Review the implementation plan to verify that it has been submitted on time (no later than September 9, 2015 and is complete ( see subparagraphs 7c and d) )

. (2) Analyze and evaluate (per Order 8900.1 , V olume 3 , Chapter 1 , Section 1 , Paragraph 3

- 4, Phase Three), the certificate holder ’s intended plans to develop or bring nonconforming safety

management processes into c ompliance with part 5 by March 9, 2018 and determine whether the plan is realistic.

**c. What the Implementation Plan Should Cover**  **.** The certificate holder ’s implementation plan should include: (1) Organization

- wide SMS development and implementation across all aviation safety - related operational functions (i.e., include all activities or s ystems that directly aff ect aviation safety). (2) Any existing programs, policies, or procedures the certificate holder intends to include in their SMS. 3 (3) SMS components and processes that are designed appropriatel y to the size, scope, and complexity

of the certificate holder ’s operation. Simply stated, small, medium, and large service

3 For example, the certificate holder’s im plementation plan should show , if applicable, how their Continuing Analysis and Surveillance Systems (CASS), aspects of an Internal Evaluation Program (IEP), aspects of Q uality M anagement S ystems (QMS) , and elements of employee reporting programs such as an Aviation Safety Action Program (ASAP) meet specific part 5 SMS requirements.1/8 /15 N 8900. 281

4 provider implementation plans will not look the same. For example, though the Safety Risk Management (S RM) processes are identical regardless of the organization’ s size, scope, or complexity

, a small carrier might have onl y one SRM team for the entire company while a large carrier might have multiple SRM teams at the department, division, and/or corporate l evel. 4
**d. What to Look for** 

**in an Implementation Plan.** (1) The certificate holder should list specific part 5 requirements applicable to their operation (e.g., § 5.23(a)(2)(ii)). (2) For each specific part 5 requirement, the certificate holder ’s planning information s hould contain the following minimum information:

(a) Documentation (e.g., reference to a manual or document) that they comply with the specific regulatory

requirement (SRR); or (b) Their plan to compl y with the SRR. Their plan should include:

 A brief narrative des cribing what actions the certificate holder intends to use to comply

with the SRR;
 The responsible organization/group and/or individual(s) who will ensure that those actions are completed; and
 The estimated completion date (ECD) (timelines) for compliance with the SRR. (3) Prior to approval, the implementation plan must be reviewed b y the AFS

- 900 SMS PO

. (a) Implementation reviews conducted b y the AFS

- 900 PO will consider the following elements:

 Designation of an appropriate accountable executive in accordance with § 5.25(a).
 Completeness of the plan to implement all of the SMS processes required by part 5.
 Certificate Holder and CMT activities sufficient to validate compliance with part 5 in accordance with the timelines in § 5.1

.  Sufficient designated personnel res ources to accomplish the implementation activities defined in the plan. (b) Satisfactory

reviews will be signed by the AFS

- 900 SMS PO m anager or his or her designee.

4 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, and cabin services) against part 5 requirements. The CMT m ust also ensure that the carrier’s i mp lementation 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 part 5 requirement.1/8 /15 N 8900. 281

5 (c) Unsatisfactory

items resulting from the review will be referred to the m anager of the certificate holding of

fice. (d) Engagement of the SMSP O at an earl y stage of the process is recommended to ensure timel y review, feedback, and approval ; however, the SMSPO may be contacted for consultation at any

time. (4) When the CMTagrees that the certificate holder ’s implementation plan is satisfactory , the CMTmanager will approve the plan per subparagraph 8a. If the plan must be rejected, follow subparagraph 8b.

**e. Functional Considerations.**  (1) Because an SMS cannot be a substitute for any other regulatory requirements, during the certificate holder ’s SMS implementation plan development, the CMT will continue all of its normal oversight and certificate management duties. Once the certificate holder ’s SMS implementation plan is approved, CMToversight will include monitoring changes to the approved plan and conformance to the plan’ s schedule for development and implementation of the certificate holder ’s SMS. (2) The first of two part 5 F AA responsibilities is approval of the certificate holder ’s implementation plan. The second is to accept the certificate holder ’s SMS. The implementation plan approval process should consider the CMTworkload 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. 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 CMTshould periodicall y review the plan and include informal feedback on adequacy , timeliness of the proposed implementation schedule, and completeness. Communication be tween the certificate holder and the CMT allows time for the CMTto make suggestions, permit course corrections, and provide feedback on the adequacy of the plan. **f. Implementation Plan Changes.**  Any changes made by

the certificate holder to an approved implem entation plan must be documented by the certificate holder and submitted to the CMTfor approval. Use caution when implementation plan changes are approved that all estimated completion dates are not moved back to the end of the 3

- year implementation perio d. Approval of a revised implementation plan implies that the CMThas available resources to evaluate submitted SMS components for acceptance in a timely manner (see Order 8900.1 , Vo lume 16 , Chapter 1 , Section 1 , subparagraph 16

- 1

- 1

- 3B). **8. Implementation Pla**  **n Approval Process .**  Procedures for approval of the certificate holder ’s implementation plan should follow guidance contained in Order 8900.1, V olume 3, Chapter 1.

**a. Recording**  **Appr oval of the Implementation Plan.**  If the certificate holder has submitted an acceptable implementation plan, the manager (of fice, unit, frontline, etc.) who is1/8 /15 N 8900. 281

6 the approving entity

for all collective decisions of the team will approve (per Order 8900.1, Vo lume 3, Chapter 1, Section 1, Para graph 3

- 6, Phase Five), the implementation plan by March 9, 2016 and ensure that implementation plan approval information is entered into the Program T

racking and Reporting Subs ys tem (PTRS) as follows: (1) Activity

number: 1045. (2) Enter “SMS IP APPROV AL” in the “National Use” box. **b. CMT Rejection of the Certificate Holder**  **’s Implementation Plan.**  Rejection notification and comments will be returned to the certificate holder according to Order 8900.1 , Vo lume 3 , Chapter 1 , Section 1 , subparagraphs 3

- 3 B and 3

- 6 and/or C MToffice policy . Failure of the certificate holder to submit an acceptable implementation plan by March 9, 2016 should be addressed in the same way as a noncompliance with any other 14 CFR requirement s
. Appropriate records of submissions and discrepancy f indings by

the CMTshould be maintained, as well as evidence of evaluation timeliness on the part of the CMT. Dif ferences of opinions between the certificate holder and the CMTas to the acceptability of the SMS implementation plan should be referred to th e normal chain of authority through respective F AA regional and national of

fices. **9. Certificate Holders Participating in the**  **SMS Vo**  **luntary Pr ogram (**  **SMS V**  **P )**  **.**
**a. SMS Implementation under**  **A C**  **120**
**- 92A.**  Many

certificate holders have begun or completed SMS implementati on through the F AA SMSPP utilizing the framework contained in AC 120

- 92A. Their SMS implementation plan s, or some or all components of their SMSs, have been validated b y the F

AA if they have exited level 1 or above. T o compl y with the implementation plan requirements of § 5.1(b), these certificate holders will need to conduct a comparison (gap anal ys is) of the sy stems currently in place under their SMS components/processes and the requirements of part 5. This comparison should identify any gaps that need to be addressed to bring their existing SMS into compliance with part 5. However, they may not have to repeat the entire gap anal ys is and planning process in areas where there are no dif ferences between the final rule and AC 120

- 92A guidance. **b. Revising Implem**  **entation Plans .**  Certificate holders may use the bridging tool attached to this notice (Appendix A) to assist in conducting a comparison (gap anal ysis ) between part 5 requirement s, their current implementation plan, and those SMS processes already completed

. (1) If gaps are found, their current implementation plan will be amended (or a new , abridged implementation plan will be created) 5 to address the gaps identified and the amended plan will be submitted to the CMTfor review

. (2) If no gaps are found, a current implementation plan (or revised plan) will be submitted to the CMTfor review

.

5 Certificate holders that have exited SMSPP level 3 (their implementation plan completed) may conduct a gap analysis of those areas of their SMS identified in the bridging document attached to this n otice. A new , abridged implementation plan (addressing only the bridging document) will be submitted to their CMT for review.1/8 /15 N 8900. 281

7 **10. SMSs**  **and Applicants for Air Carrier Certification .**  SMS implementation for a certificate applicant is dif

ferent than that for a certificate holder . The implementation plan requirement and the specific deadline for full SMS implementation are dependent on when an organization submits its formal application for a part 121 certificate and when that organization completes all of the pertinent certification requirements.

**a. Applican**  **ts Completing Formal Application**  **After Mar**  **ch 9, 2015 .**  According to 14 CFR part 11 9, § 11 9.8, applicants that have not completed formal application prior to March 9, 2015 must demonstrate that they meet the full requirements of part 5 prior to being issued a certificate. The application process can be found in Order 8900.1, Vo lume 10 (A TOS) , Chapter 6, Section 2 , Certification Process Document , or V olume 2, Chapter 3 for Safety Assurance Sy stem (SAS)

. **b. Applicants Completing Formal**  **Application Prior to**  **Mar ch 9, 2015.**  Applicants that have completed formal application prior to March 9, 2015 may be issued certificates; however, they are still responsible fo r meeting the dates listed in §§ 5.1 and 11 9.8. (1) Applicants Completing All Other Certification Requirements Prior to September 9, 2015. These applicants can be certificated without an SMS implementation plan. However, they

must submit an SMS implementation plan prior to September 9, 2015 for approval b y the F

AA. (2) Applicants Completing All Other Certification Requirements Prior to March 9, 2016. These applicants must submit an SMS implementation plan for review by the F AA prior to being issued a certificate. They

must have an approved implementation plan prior to March 9, 2016. (3) Applicants Completing All Other Certification Requirements After March 9, 2016

. Prior to receiving a part 121 certificate, these applicants will be required to have an approved SMS imple mentation plan for completion of all part 5 requirements prior to March 9, 2018. (4) Applicants that are Unable to Complete All Certification Requirements Prior to March 9, 2018. These applicants will be required to demonstrate compliance with all requirements for SMSs prior to being issued a certificate. **11. Disposition**  **.** This guidance will not be included in Order 8900.1, as the need for this guidance expires 12 months after the ef fective date of part 5. Direct questions concerning this notice to the SMSPO National Coordinator at 9

- NA TL

- SMS

- ProgramOffice@faa.gov

.

John S. Duncan Director, Flight Standards Service1/ 8 /15 N 8900. 281 Appendix A

A

- 1 **Ap pendix A**  **. Safety**

**Management Sy stem Pilot Project Participant Bridging**  **To ol**  This appendix is provided for certificate holders who have existing plans or documents that were developed through the former Safety M anagement Sy stem Pilot Project (SMSPP). The t able below lists the dif

ferences between Advisory Circular (AC) 120

- 92A, Safety Management Sy stems for Av iation Service Providers, and Title 14 of the Code of Federal Regulations (14 CFR) part 5 as the SMS Program Of fice (SMSPO) has identified them. Each c ertificate holder in the SMS Vo luntary Program ( SMS VP ) has implemented a Safety Management S ys tem (SMS) according to their own needs; therefore, a close review of their SMSs, this document, and part 5 is required. This attachment is advisory ; Federal Av iation Administration (F AA) Certificate Management Te ams (CMT) are under no obligation to accept or reject an SMS component, element, or process based upon this document; the CMTwill evaluate a certificate holder ’s S MS against 14 CFR part 5 and determine compliance. This bridging tool may be utilized in the same manner as a gap anal ys is tool in that objective evidence may be documented for differences already complied with and planning information may be documented fo r actions needed for compliance.

**SMSPP Process Part 5 Reference**  **Differences**
**If a certificate holder**  **has implemented or is implementing an SMS**  **per AC 120** 
**- 92A,**  **Appendix 1, these are**  **the processes they have developed or are**  **developing: This is the part**  **5**

**reference for the specific process:**  **Here are the noted differences between**

**AC 120** 
**- 92A and part**  **5. You should pay close attention to the processes identified to ensure** 

**part 5 compliance.**  Words in **bold** are key words to focus on.

**Component 1.0 Safety Policy**  **and Objectives.** §§ 5.3(a)(1) and 5.21

– 5.27 • Ensure that the company designates an Accountable

Executive and replaces the term **“ Top Management**  **”** with the term **“ Accountable Executive**  **”** in their manuals and documentation. [Wording and management concept change] **Element 1.1 Safety Policy.**  §§ 5.21 and 5.23 • Ensure that the company’s Safety Policy contains a **commitment to fulfill** the organization’s **saf ety**  **objectives**

. [Bold text not addressed in AC 120

- 92A] • Ensure that the company’s Safety Policy defines **requirements** ( **vice “encourages”** ) for employee reporting of safety hazards or issues. [Wording and process change, review existing process for part 5 compliance.] • Ensure that the company’s safety policy defines **unacceptable behavior** and **conditions for dis**  **ciplinary action**

.1/ 8 /15 N 8900. 281 Appendix A

A

- 2 **SMSPP Process Part 5 Reference**  **Differences** [Change from AC 120

- 92A (Element 1.1b(2)(f)] • Ensure that the company’s Safety Policy contains an “ emergency response plan which provides for the **safe transition** from normal to emergency operations in accordance with the requirements of § 5.27. ” (ref er to § 5.21(a)(6)) [Bold text not addressed in AC 120

- 92A] • Ensure that the company’s Safety Policy requires regular reviews by the **accountable executive** ( **vice “organization/company/etc.”**  ) to ensure that it remains relevant and appropriate t o the certificate holder. [Wording and process change] • Ensure that the company’s Safety Policy defines **management’s accountability** for safety for SMS processes **within their area of responsibility** , including, but not limited to: (i) **Hazard identification** and safety risk assessment. (ii) **Assuring the effectiveness of safety risk controls** 

. [Bold text not addressed in AC 120

- 92A] **Element 1.2 Management**  **Commitment and Safety**  **Accountabilities.** §§ 5.23 and 5.25 • Ensure that the company defines accountabilities: for the following individuals: (1) Accountable executive, as described in § 5.25. (2) All members of management in regard to developing, implementing, and maintaining SMS processes within their area of resp onsibility, including, but not limited to: (i) Hazard identification and safety risk assessment. (ii) Assuring the effectiveness of safety risk controls. (iii) Promoting safety as required in subpart E of this part. (iv) Advising the accountable executive on the performance of the SMS and on any need for improvement. (3) Employees relative to the certificate holder ’ s safety performance. (b) The certificate holder must identify the levels of management with the authority to make decisions regarding safety ri sk acceptance. [Wording and process change]1/ 8 /15 N 8900. 281 Appendix A

A

- 3 **SMSPP Process Part 5 Reference**  **Differences**

• Ensure that the company requires the **accountable executive**  ( **vice “management”** ) to **assess the SMS performance**  , to review the **safety performance** and direct actions to **address substandard performance**

. [Wording and process change not addressed in AC 120

- 92A] **Element 1.3 Key Safety Personnel.**  § 5.25 • Ensure that the company designates an accountable executive who satisfies the following: (1) Is the final authority over operations authorized to be conducted under the certificate(s). (2) Controls the financial resources required for the operations to be conducted under the certificate(s). (3) Controls the human resources required for the operations authorized to be conducted under the certificate(s). (4) Retains ult imate responsibility for the safety performance of the operations conducted under the certificate.

• Ensure that the company defines the following responsibilities for the a ccountable e xecutive: (b) Responsibilities of the accountable executive. The accountable executive must accomplish the following: (1) Ensure that the SMS is properly implemented and performing in all areas of the certificate holder ’ s organization. (2) Develop and sign the safety policy of the certificate holder. (3) Communicate the safety policy throughout the certificate holder ’ s organization. (4) Regularly review the certificate holder ’ s safety policy to ensure it remains relevant and appropriate to the certificate holder. (5) Regularly review the safety performance of the certific ate holder ’ s organization and direct actions necessary to address substandard safety performance in accordance with § 5.75

.

• Ensure that the company requires the **accountable executive**  ( **vice “top management”** ) to designate **sufficient management personnel (v ice “a member**  **of management”)**  who must be responsible for the following:1/ 8 /15 N 8900. 281 Appendix A

A

- 4 **SMSPP Process Part 5 Reference**  **Differences** [Wording and process change] **(2) Facilitating hazard identifi cation and safety**  **risk analysis, and (3) Monitoring the effect** **iveness of safety risk controls.**  [Bold text not addressed in AC 120

- 92A] **Element 1.4 Emergency**  **Preparedness and Response.**  § 5.27 • Ensure that the company requires and the accountable executive approves as part of the Safety Policy, an emergency response plan that addresses at least the following: **(1)** Delegation of **emergency authority** throughout the organization, **(2)** Assignment of **employee responsibilities during the eme**  **rgency** , and (3 ) Coordination of the certificate holder ’ s emergency response plans with the emergency response plans of other organizations it must interface with during the provision of its services. [Bold text not addressed in AC 120

- 92A] **Element 1.5 SMS Documentation and**  **Records.** §§ 5.95 and 5.97 • Ensure that the company requires the following **record retention times** : **(1) Output of SRM must be retained a**  **s long as controls are relevant,**  **(2) Output of SA records must be retained for a minimum of**  **5 years,**  **(3) Training records must be retained for as**  **long as the individual is employed by the certificate holder**  **, and**  **(4) Records of all communications for a minimum of**  **24 consecutive calendar** 
**- months.**  [Bold text not addressed in AC 120

- 92A] **Component 2.0 Safety Risk Management**  **(SRM).** Subpart C, Safety Risk Management, §§ 5.3(a)(2), 5.51, 5.53, and 5.55 **Element 2.1 Hazard**  **Identification and Analysis.**  **Process 2.1.1 System Description And Task**  **Analysis.** § 5.53(a) and (b), System Analysis and Hazard Identification • Ensure that procedures are in place, when

conducting the system analysis, to require consideration of: **(1) Function and purpose of the system.**1/ 8 /15 N 8900. 281 Appendix A

A

- 5 **SMSPP Process Part 5 Reference**  **Differences (2) The system’s operating environment.**  **(3) An outline of the system’s processes and procedures.**  **(4) The personnel, equipment, and facilities necessary for operation of the system.**  [Bold text not addressed in AC 120

- 92A] **Process 2.1.2 Identify Hazards.**  § 5.53(c), System Analysis and Hazard Identification No change noted.

**Element 2.2 Risk Assessment And**  **Control. Process 2.2.1 Analyze**  **Safety Risk.** § 5.55(a), Safety Risk Assessment and Control No change noted.

**Process 2.2.2 Assess Safety Risk.**  § 5.55(b), Safety Risk Assessment and Control No change noted.

**Process 2.2.3 Control/Mitigate**  **Safety Risk.** § 5.55(c), Safety Risk Assessment and Control No change noted.

**Component 3.0 Safety Assurance.**  Subpart D, Safety Assurance, §§ 5.3(a)(3), 5.71, 5.73, and 5.75 **Element 3.1 Safety Performance**  **Monitoring and Measurement.**  **Process 3.1.1 Continuous**  **Monitoring.** § 5.71(a)(1) and (2), Safety Performance Monitoring and Measurement • The company may consider replacing the term

“ **Continuous Monitoring** ”, with the term

“ **Monitoring** ” in their manuals and documentation. [Optional wording change, no change to the process, review existing process for part 5 compliance. No requirement to match part 5 wording if the proc ess is in compliance.] • The certificate holder must develop and maintain processes and systems to acquire data with respect to its operations, products, and services to monitor the safety performance of the organization. These1/ 8 /15 N 8900. 281 Appendix A

A

- 6 **SMSPP Process Part 5 Reference**  **Differences** processes and systems must i nclude, at a minimum, the **monitoring** of the **operational environment to detect changes** 

. [Bold text not addressed in AC 120

- 92A] **Process 3.1.2 Internal Audits by Operational**  **Departments.** § 5.71(a)(3), Safety Performance Monitoring and Measurement • The certificate holder must develop and maintain

processes and systems to acquire data with respect to its operations, products, and services to monitor the safety performance of the organization. These processes and systems must include, at a minimum, auditin g of operational processes **and systems.** [The term “Systems” is not addressed in AC 120

- 92A in reference to this process. This is an optional wording change as there are no functional differences in the processes. There is no requirement t o match part 5 wor ding if the process is in compliance.]
**Process 3.1.3 Internal Evaluation.**  § 5.71(a)(4), Safety Performance Monitoring and Measurement • The certificate holder must develop and maintain

processes and systems to acquire data with respect to its operations, products, and services to monitor the safety performance of the organization. These processes and systems must include, at a minimum, e valuations of the SMS and operational processes **and systems.** [The term “Systems” is not addressed in AC 120

- 92A in reference to this process. This is an optional wording change as there are no functional differences in the processes. There is no requirement to match part 5 wording if the process is in compliance.]
**Process 3.1.4 External Auditing of the SMS.**  § 5.71(a)(3), Safety Performance Monitoring and Measurement • This process has been included with § 5.71(a)(3)

[Combining of processes]

**Process 3.1.5 Investigation.**  § 5.71(a)(5) and (6), Safety Performance Monitoring and Measurement No change noted.

**Process 3.1.6 Employee Reporting And**  **Feedback System.** § 5.71(a)(7), Safety Performance Monitoring and Measurement • The company may consider replacing the term

**“ Employee Reporting and Feedback System**  **”** , with the term **“ Confidential Employee Reporting**  **System ”**  in their manuals and documentation. [This is an optional wording change as there are no functional differences in the processes. No1/ 8 /15 N 8900. 281 Appendix A

A

- 7 **SMSPP Process Part 5 Reference**  **Differences** requirement to match part 5 wording if the process is in compliance.] • The certificate holder must develop and maintain processes and systems to acquire data with respect to its operations, products, and services to monitor the safety p erformance of the organization. These processes and systems must include, at a minimum, the following: (7) A confidential employee reporting system in which employees can report **hazards, issues, concerns, occurrences, incidents**  , as well as propose solution s and safety improvements. [Bold text is not addressed in AC 120

- 92A with reference to the Employee Reporting System] **Process 3.1.7 Analysis of**  **Data.** § 5.71(b), Safety Performance Monitoring and Measurement • The certificate holder must develop and maintain

processes and systems to acquire data with respect to its operations, products, and services to monitor the safety performance of the organization. These processes and systems must include, at a minimum, processes, the following: (8) The certificate holder must develop and maintain processes that analyze the data acquired through the processes and systems identified under paragraph (a) of this section and any other relevant data with respect to its operations, **products, and services.** [Bold text is not addressed in AC 120

- 92A. There is a requirement for this process in the AC but it only refers to “operations”. Review existing process, if “operations” includes products and services. No change is required.] **Process 3.1.8 System Assessment.**  § 5.73, Safety Performance Assessment No change noted.

**Element 3.2 Management Of**  **Change.** § 5.73(a)(4), Safety Performance Assessment • This process has been included with § 5.73(a)(4)

[Combining of processes]
**Element 3.3 Continuous**  **Improvement.** § 5.75, Continuou s Improvement No change noted.

**Process 3.3.1 Preventive/Corrective**  **Action.** § 5.75, Continuous Improvement No change noted

.

**Process 3.3.2** § 5.73(a)(4), Safety • This process has been included with § 5.73(a)(4)1/ 8 /15 N 8900. 281 Appendix A

A

- 8 **SMSPP Process Part 5 Reference**  **Differences Management Review.**  Performance Assessment [Combining of processes] **Component 4.0 Safety Promotion.**  Subpart E, Safety Promotion
**Element 4.1 Competencies and**  **Training.** § 5.91, Competencies and Training No change noted.

**Process 4.1.1 Personnel Expectations**  **(Competence).** § 5.91, Competencies and Training No change noted.

**Process 4.1.2 Training.** § 5.91, Competencies and Training No change noted.

**Element 4.2 Communication and**  **Aw areness.**  § 5.93, Safety Communication • Compare and contrast these AC 120

- 92A,

Appendix 1 elements/processes with part 5 requirements to ensure compliance: 1.1b(2)(l), 1.2b(3), 1.3b(1)(c), 3.3b(2)(b), 4.0b(1)(c) and (d), and 4.2b(1).1/ 8 /15 N 8900. 281 Appendix B

B

- 1 **Ap pendix B. Comparison**  **Ta ble for Safety**  **Management Sy stem Pilot Project**  **Participants** The following table compares Advisory Circular (AC) 120

- 92A, Appendix 1, Av iation Service Provider Safety Management Sy stem Framework: Func tional Expectations, with Ti tle 14 of the Code of Feder al Regulations (14 CFR) part 5. It is designed for certificate holders participating in the SMSPPwho have implemented Safety Management Systems (SMS) according to the AC. This appendix is for information only

. **AC 120**
**- 92A Appendix 1 (SMSPP)**  **14 CFR Part 5 Component 1.0 Safety Policy and Objectives**  **Subpart B, Safety Policy,** § 5.51(a)(1) Element 1.1 Safety Policy § 5.21 Safety Policy Element 1.2 Management Commitment and Safety Accountabilities § 5.23 Safety Accountability and Authority

Element 1.3 Key Safety Personnel § 5.25 Designation and Responsibilities of Required Safety Management Personnel Element 1.4 Emergency Preparedness and Response § 5.27 Coordination of Emergency Response Planning
Element 1.5 SMS Documentation and Records Subpart F, SMS D ocumentation and Recordkeeping, §§ 5.95 and 5.97 **Component 2.0 Safety Risk Management Subpart C, Safety Risk Management,**  § 5.51 Applicability Element 2.1 Hazard Identification and Analysis § 5.53 System Analysis and Hazard Identification Process 2.1.1 System Description and Task Analysis § 5.53(a) and (b) Process 2.1.2 Identify Hazards § 5.53(c) Element 2.2 Risk Assessment and Control § 5.55(a) Safety Risk Assessment and Control Process 2.2.1 Analyze Safety Risk § 5.55(a) Process 2.2.2 Assess Safety Risk § 5.55(b) Process 2.2.3 Control/Mitigate Safety Risk § 5.55(c) and (d) **Component 3.0 Safety Assurance Subpart D, Safety Assurance**  Element 3.1 Safety Performance Monitoring and Measurement § 5.71 Safety Performance Monitoring and Measurement Process 3.1.1 Continuous Monitoring § 5.71(a)(1) and (2) Process 3.1.2 Internal Audits by Operational Departments § 5.71(a)(3)
Process 3.1.3 Internal Evaluation § 5.71(a)(4) Process 3.1.4 External Auditing of the SMS § 5.71(a)(3) Process 3.1.5 Investig ation § 5.71(a)(5) and (6)1/ 8 /15 N 8900. 281 Appendix B

B

- 2 **AC 120**
**- 92A Appendix 1 (SMSPP)**  **14 CFR Part 5** Process 3.1.6 Employee Reporting and Feedback System § 5.71(a)(7) Process 3.1.7 Analysis of Data § 5.71(b) Process 3.1.8 System Assessment § 5.73(a) Safety Performance Assessment Element 3.2 Management of Change § 5.73(a)(2)

–(5) and (b) Element 3.3 Continuous Improvement § 5.75 Continuous Improvement Process 3.3.1 Preventive/Corrective Action § 5.75 Continuous Improvement Process 3.3.2 Management Review § 5.73(a) **Component 4.0 Safety Promotion Subpart E, Safety**  **Promotion** Element 4.1 Competencies and Training § 5.91 Competencies and Training Process 4.1.1 Personnel Requirements (Com petence) § 5.91 Process 4.1.2 Training § 5.91 Element 4.2 Communication and Awareness § 5.93 Safety Communication