EGYPTIAN CIVIL AVIATION AUTHORITY

Guidance On The Development Of An SMS Implementation Plan For Service Providers

( All Certificate Holders )

Background

As part of ECAA safety programme; ECAA mandates that an [operator, maintenance organization, ATS provider, certified aerodrome] implements a safety management system (SMS) accepted by the ECAA that, as a minimum: .

1- Identifies safety hazards.

2-Ensures that remedial action necessary to maintain an acceptable level of safety is implemented.

3-Provides for continuous monitoring and regular assessment of the safety level achieved.

4-Aims to make continuous improvement to the overall level of safety. "1"

The following guidance should be used as reference to develop an SMS implementation plan that explains how a service provider organization will implement an SMS on the basis of ECAA requirements and international Standards and Recommended Practices (SARPs), the system description and the results of a gap analysis.

It is important to understand that the suggested plan is intended to be used only as reference guidance and it may need to be tailored to meet the needs of each service provider

The development of an appropriate and realistic SMS implementation plan will :

1- Assist service providers in preparing a realistic strategy for the implementation of an SMS that will meet the organization’s safety needs

2- Define the approach the organization will adopt for managing safety

3- Provide sequential steps on how to implement SMS

4- Provide an accountability framework for the implementation of the SMS

Two requirements should be completed prior to developing the SMS implementation plan , identify the accountable executive and, the safety accountabilities of managers.

Accountable executive must have:

1- Full authority for human resources issues.

2-Authority for major financial issues.

3- Direct responsibility for the conduct of the organization’s affairs.

4- Final authority over operations under certificate.

5- Final responsibility for all safety issues.

6-Identify the person (or planning group) within the organization responsible for developing the SMS implementation plan .

The success of the proposed SMS implementation plan depends on the support, commitment and participation of management, supervisors and line operational personals. A Phase approach is suggested for the development of the SMS implementation plan and the timeline for its implementation may be different, depending on the complexity of the organization.

SMS Implementation Plan – building blocks

(1)Safety planning and objectives

(2)Safety policy

(3)Safety roles and responsibilities

(4)System description

(5)Gap analysis

(6)Hazard identification processes

(7)Risk management processes

(8)Safety performance measurement

(9)Safety training

(10)Safety communication

(11)Coordination with third parties

(12)Management review (of safety performance)

SMS Implementation Plan – Phase approach

Phase 1- Safety Policy and Objectives (Planning)

This phase should be the blueprint on how the SMS requirements will be met and integrated to the organization’s work activities. In order to achieve that, the following issues should be completed,

(a) Management commitment to SMS implementation:

(1) Identify the safety objectives of the organization

(i) Objectives as a precise tangible elements to be validated (through the different phases) and linked to the safety performance indicators and safety performance targets.

(2) Develop a safety policy that contains at least addressed the following points :-

(i) Achieve the highest safety standards.

(ii) Observe all applicable legal requirements and international standards, and best effective practices.

(iii) Provide appropriate human and financial resources.

(iv) Enforce safety as one primary responsibility of all managers.

(v) Ensure that the policy is understood, implemented and maintained at all levels.

(3) Establish allocation of time for the SMS processes among the different management layers of the organization

(b) Management must establish the level of expectation for the SMS and its usage by contractors and sub-contractors on their jobsites

(1) Write SMS requirements into the contracting process

(2) Establish the SMS requirements in the bidding documentation

(1) Communicate, with visible endorsement, the safety policy to all staff

(2) Establish means to communicate safety related issues that could include:

(i) Safety policies and procedures

(ii) Newsletters

(iii) Bulletins

(iv) Website

Elaboration of System Description and Gap Analysis

(a) Establish the guidelines for system description and the interaction of its different components

(1)Required human performance considerations of the system operation

(2)Hardware components of the system

(3)Software components of the system

(4)Operational environment

(5)The system interactions with other systems in the air transportation system

(6)Contracted and purchased products and services

(b) Perform Gap Analysis against the four components and thirteen elements of the SMS framework as specified below .

(1) Safety policy and objectives

(i) Management commitment and responsibility

(ii) Safety accountabilities of managers

(iii) Appointment of key safety personnel

(iv) SMS implementation plan

(v) Coordination of emergency response planning

(vi) Documentation

(2) Safety risk management

(i) Hazard identification process

(ii) Risk assessment and mitigation process

(3) Safety assurance

(i) Safety performance monitoring and measurement

(ii) The management of change

(iii) Continuous improvement of the SMS

(4) Safety promotion

(i) Training and education

(ii) Safety communication

(c) Identify potential challenges in the implementation, develop plans to address challenges (i.e. risk assessment of the plan)

With the results of the gap analysis the implementation team should develop an SMS structure and determine the safety responsibilities of key personnel

Establishment of SMS Organizational Structure

(a) The implementation planning team to propose an SMS structure; and,

(b) Safety responsibilities of key personnel :-

(1) The safety office – Corporate functions

(i)Advising senior management on safety matters

(ii)Assisting line managers

(iii)Overseeing hazard identification systems

(2) The safety manager – Responsibilities

(i)Responsible individual and focal point for the development and maintenance of an effective safety management system

(ii)The safety manager functions and selection criteria

(3) The Safety Review Board (SRB):

(i)High level committee

(ii)Strategic safety functions

(4) Safety Action Group(s) (SAG):

(i)Reports to SRB and takes strategic direction from SRB

(c)Approval of SMS implementation plan and initial training

(1)Draft SMS implementation plan developed

(2)Identify the costs associated to training and planning of the implementation

(3)Draft budget for SMS implementation

(4)Approve initial budget for SMS implementation plan

(5)SMS implementation plan signed by accountable executive

(d) Training

(1) Introduction of SMS concepts accordingly to the level of all staff, contractors and sub-contractors

(2) Identify who needs to be training for further phases

(3) Identify the costs associated to training

(4) Organize and set up schedules for training of all supervisors and staff

Coordination of the emergency response plan

(a) Internal coordination

(1) Emergency planning team established.

(2) Emergency planning coordinator appointed .

(3) Procedures in place .

(4) Others

(b) External coordination

(1) Established with search and rescue services

(2) Established with Egyptian Civil Aviation Authority (ECAA) and investigation agencies

(3) Emergency Action Plan submitted to ECAA

(4) Others

Documentation

(a) Develop the safety library of the organization

(b) Development of SMSM (related to planning phase)

(d) Information on Phase 1 collected and distributed to the organization

Phase 1 Timeline - 1 to 6 months

Depends on the complexity of the organization

Deliverables:

(a) Safety objectives of the organization approved by accountable executive

(b) Safety Policy signed by accountable executive

(d) SMS organizational structure in place

(e) Lines of safety accountability established

(f) Approval of SMS implementation plan and initial training

(g) Emergency response planning in place

Milestones:

(a) Draft proposal of safety policy

(b) Gap Analysis results delivered

(c) Proposal of SMS organizational structure including allocation of resources and time for the SMS processes among the different management layers of the organization

(d) Estimated budget for SMS processes

Phase 2: Safety Risk Management (reactive processes)

Means of collecting, recording, acting on and generating feedback about hazards and risks in operations according to the results of the gap analysis

(a) Determine what form of intervention tool to be used to collect reactive information

(b) Decide which reporting system will be required and adapted to the organization.

(1) Mandatory reporting system

(2) Voluntary reporting systems

(3) Confidential reporting systems

(1) Customize the Risk Matrix to suit the organizational complexity

(2) Develop Risk Matrix instructions on the forms and/or in the training

(d) Determine risk management levels to be documented (i.e. intolerable, tolerable or acceptable)

(e) Write such requirements into the bid documentation for contractors, if necessary and notify contractors and sub-contractors in writing.

(f) Identify administration process/responsibilities for implementing strategies

(1) Will we need a database to capture reactive data from forms?

(2) Who will maintain filing/database?

(3) Who will analyze data for trends?

(4) How will trends be communicated to?

(5) Develop control and mitigation strategies (for reactive processes)

(g) Build the safety library

(h) Collect information for safety performance indicators

(i) Train-the-Trainer(s)

(j) Train the Managers

(k) Train the front line personnel

(l) Provide ongoing coaching and guidance by supervisors or ( Managers) to front line personnel

Phase 2 Time line - 6 to 18 months

Depends on the complexity of the organization

Deliverables :

(a) Safety reporting system (for reactive processes) in place

(b) Safety library in place

Milestones :

(a) Risk assessment matrix in place for reactive processes

(b) Formal procedure to translate operational safety data into hazard-related information

(d) Convey safety critical information to the organization based on reactive processes

Phase 3: Safety Risk Management (proactive and predictive processes)

(a) Determine what form of intervention tool to be used to collect proactive and predictive information (e.g., confidential reporting systems, flight data analysis, normal operations monitoring etc.)

(b) Update guidelines, procedures, hardware and software to support the proactive and predictive intervention tools.

(d) Identify administration process/responsibilities

(1) Will we need a database to capture proactive and predictive data from forms?

(2) Who will maintain filing/database?

(3) Who will analyze data for trends?

(4) How will trends be communicated to?

(e) Train flight safety manager on specific intervention tools on collecting information

(f) Determine risk management levels to be documented (as in phase 2)

(g) Use the risk matrix as in Phase 2

(h) Develop control and mitigation strategies

(i) Brief supervisors and frontline personnel on proactive and predictive processes

(j) Requirements into the bid documentation for contractors and sub-contractors in writing

(k) Develop safety performance indicators and targets

Phase 3 Time line - 6 to 12 months

Depends on the complexity of the organization

Deliverables –

(a) Safety reporting system (for proactive and predictive processes) in place

(b) Safety performance indicators and targets approved by CEO

Milestones –

(a) Risk control/mitigation strategies developed

(b) Safety performance indicators and targets reviewed by the Safety Review Board (SRB) or equivalent

(d) Convey safety critical information to the organization based on reactive processes

Phase 4: Operational Safety Assurance and Safety Promotion

Acceptable levels of safety

(a) Define safety performance indicators and safety performance targets of an acceptable level(s) of safety of the organization

(b) Establish safety requirements to deliver the safety performance indicators and safety performance targets of an acceptable level of safety

Safety performance monitoring and measurement .

Define the process by which the safety performance of the organization is verified in comparison to the approved safety policies and objectives

(a) Safety reporting

(b) Safety studies

(d) Audits

(e) Surveys

(f) Internal safety investigations for occurrences or events that are not required to be investigated or reported to the ECAA

(g) Define safety performance indicators and safety performance targets of an acceptable level(s) of safety of the organization

(h) Establish safety requirements to deliver the safety performance indicators and safety performance targets of an acceptable level of safety

(i) Establish lines of accountability for measures of reliability, availability and/or accuracy related to safety requirements

Management of change

Assess internal and external changes

(a) Identify affected established processes and services

(b) Arrangements to ensure safety performance

SMS continuous improvement:

(a) Proactive evaluation of facilities, equipment, documentation and procedures completed through audits and surveys

(b) Proactive evaluation of the individuals’ performance completed to verify the fulfilment of their safety responsibilities

(c) Procedures for Reactive evaluations in place to verify the effectiveness of the system for control and mitigation of risks ( accidents, incidents and major events investigations)

(d) Training relevant to operational safety assurance

(e) Documentation relevant to operational safety assurance

(f) Identify changes required from trend analysis of Risks being reported

Safe Work Practices being updated

Additions to the Safety Program

Safety Promotion

Effective methods to promote safety in this phase should include among others:

(a) Review, revise and communicate changes to your organization’s SMS usage and standards

(b) Share “lessons learned” that promote improvement of the SMS

(c) Identify methods to communicate successes of SMS (i.e. after training is completed, trends identified in the documentation submitted, changes to the safety related programs, etc.)

(d) Review safety policy including the reporting policy

(e) Promote participation by all personnel in the identification of hazards

Phase 4 Time line - 4 to 12 months

Depends of the complexity of the organization

Deliverables:

(a) Acceptable levels of Safety established and submitted to the Egyptian Civil Aviation Authority

(b) Revised Safety strategies and processes approved by the CEO

Milestones:

(a) Processes for safety performance monitoring and measurement approved and established

(b) Re-evaluate strategies and processes by the SRB