FAA issued GAP Analysis tool for safety management systems for air carriers.
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NPRM GAP Analysis Page 1 of 33 Location: Questions Component - Safety Policy Process Objectives SMSVP Requirement untary Program (SMSVP) - Air Carrier Gap Analysis Tool 0 Note: This SMS Voluntary Program Gap Analysis Tool is not regulatory, but is provided to aid aviation service providers in the evaluation of their existing systems, processes and programs as compared to SMS requirements in the SMSVoluntary Program Standard. This Gap Analysis Tool can be used by Part 121 Service Providers as a transition tool for service providers to use until 14 CFR part 5 is published. For Part 121 service providers, when 14 CFR Part 5 rule is published, if there are discrepancies between this tool and 14 CFR part 5, part 5 shall prevail for affected aircarriers. Blue colored column headings (C thru I) may be modified, added or deleted to reflect a service provider’s organizational structure. Any changes to the questions or references in column A, will render the document inaccurate, resulting in the development of an inacurate Implementation Plan. Service Provider: Company's Documentation Source Flt Ops Assmt Rating Disp. Assmt Rating MTC Assmt Rating Cabin Assmt Rating Ground Assmt Rating Cargo Assmt Rating Train. Assmt Rating This section provides guidance about how the accountable executive, in coordination with other senior managers, define safety performance objectives, assign accountability, and allocate resources. The Safety Policy component is where your management defines their commitment to managing safety throughout the organization. Does your safety management system have a safety policy component that is in accordance with SMSVP Standard, subpart B, Safety Policy?
Transcript
NPRM GAP Analysis
Page 1 of 32
Location:
Questions
Component - Safety Policy Process Objectives
SMSVP Requirement
SMSVoluntary Program (SMSVP) - Air Carrier Gap Analysis Tool 07/31/14
Note: This SMS Voluntary Program Gap Analysis Tool is not regulatory, but is provided to aid aviation service providers in the evaluation of their existing systems, processes and programs as compared to SMS requirements in the SMSVoluntary Program Standard. This Gap Analysis Tool can be used by Part 121 Service Providers as a transition tool for service providers to use until 14 CFR part 5 is published. For Part 121 service providers, when 14 CFR Part 5 rule is published, if there are discrepancies between this tool and 14 CFR part 5, part 5 shall prevail for affected aircarriers.Blue colored column headings (C thru I) may be modified, added or deleted to reflect a service provider’s organizational structure.Any changes to the questions or references in column A, will render the document inaccurate, resulting in the development of an inacurate Implementation Plan.
Service Provider:
Company's Documentation Source
Flt OpsAssmt Rating
Disp.Assmt Rating
MTCAssmt Rating
CabinAssmt Rating
GroundAssmt Rating
CargoAssmt Rating
Train.Assmt Rating
This section provides guidance about how the accountable executive, in coordination with other senior managers, define safety performance objectives, assign accountability, and allocate resources. The Safety Policy component is where your management defines their commitment to managing safety throughout the organization.
Does your safety management system have a safety policy component that is in accordance with SMSVP Standard, subpart B, Safety Policy?
(Note(s): This question addresses the SMS Safety Policy Component in its entirety and is best answered after responding to all other questions within this component.)
NPRM GAP Analysis
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QuestionsCompany's
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SMSVP Standard: 5.3 (a) (1)
SMSVP Standard: 5.3 (a)
Element - Safety Policy
Process Objectives
SMSVP Requirement
• Your organization's safety objectives,
Is your safety management system appropriate to the size, scope and complexity of your operations?
To provide the organization’s decision makers a means to document, communicate, establish, and achieve safety objectives for their organization. The accountable executive will commit to providing adequate resources to implement the SMS, achieve safety objectives, a safety reporting program, an emergency response plan, and definitions of unacceptable conduct by signing and regularly reviewing the organization’s safety policy.
Does your safety management system have a safety policy that includes at least the following minimum requirements:
• A commitment to fulfill your organization's safety objectives;
• A clear statement to commit the necessary resources for implementating your safety management system;
NPRM GAP Analysis
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QuestionsCompany's
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SMSVP Standard: 5.21(a)
SMSVP Standard: 5.21(b); 5.21(c) & 5.21(d)
Process Objectives
• A safety reporting policy that defines requirements for your employee's to report safety hazards or issues;
• A policy that defines unacceptable behavior and conditions for disciplinary action; and
• An emergency response plan that provides for the safe transition from normal to emergency operations in accordance with the requirements of SMSVP Standard 5.27, Coordination of Emergency Response Planning?
Do your safety management processes require your safety policy be:
• Signed by your accountable executive (described in §5.25);
• Documented and communicated throughout your organization; and
• Regularly reviewed by your accountable executive to ensure it remains relevant and appropriate to your organization?
Element - Safety Accountability and Authority
To provide the organization’s decision makers a means to define accountability for safety for all employees within their area of responsibility, and identify authority for safety risk acceptance.
NPRM GAP Analysis
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SMSVP Requirement
Process Objectives
SMSVP Requirement
Does your safety management policy define accountability for safety for all personnel, specifically:
• Your accountable executive SMSVP Standard 5.25;
• All members of management in regard to developing, implementing, and maintaining SMS processes within their area of responsibility; and
• Employees relative to your organization's safety performance?
To provide the organization’s decision makers a means to designate the accountable executive, define responsibilities of the accountable executive and senior management with respect to a properly functioning SMS.
Does your organization identify an accountable executive who, irrespective of other functions, satisfies the following:
• Is the final authority over operations authorized to be conducted under your certificate(s);
• Controls the financial resources required for the operations to be conducted under your certificate(s);
NPRM GAP Analysis
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SMSVP Standard: 5.25(a)
• Develop and sign your safety policy;
SMSVP Standard: 5.25(b)
Process Objectives
• Controls the human resources required for the operations authorized to be conducted under your certificate(s); and
• Retains ultimate responsibility for the safety performance of the operations conducted under your certificate(s)?
In your safety management processes, is your accountable executive required to accomplish the following:
• Ensure that your SMS is properly implemented and performing in all areas of the organization;
• Communicate your safety policy throughout the organization;
• Regularly review your safety policy to ensure it remains relevant and appropriate to your organization; and
• Regularly review the safety performance of your organization and direct actions necessary to address substandard safety performance in accordance with SMSVP Standard 5.75, Continuous Improvement?
Element - Designation & Responsibility of Required Safety Management Personnel
NPRM GAP Analysis
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SMSVP Requirement
• Hazard identification and safety risk assessment
SMSVP Standard: 5.23(a)(2)
To provide the organization’s decision makers a means to designate the accountable executive, define responsibilities of the accountable executive and senior management with respect to a properly functioning SMS.
Does your safety policy require all members of management to develop, implement and maintain SMS processes within their area of responsibility to include, but not limited to, the following:
• Assuring the effectiveness of safety risk controls;
• Promoting safety as required of the SMSVP Standard, subpart E, Safety Promotion; and
• Advising your accountable executive on the performance of the SMS and on any need for improvement?
(Note: The questions above include owners of operational processes (Managers, Directors, etc.), at the decisional level across the organization.)
Does your safety management processes identify the levels of management with the authority to make decisions regarding safety risk acceptance for the company?
NPRM GAP Analysis
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SMSVP Standard: 5.23(b)
(Note(s): This question/process includes owners of operational processes (Managers, Directors, etc.), at the decisional level across the organization.)
Documentation Definition (reference FAA VS Order 8000.367) - Information or meaningful data and its supporting medium (e.g., paper, electronic) that is distinct from records because it is the written description of policies, processes, procedures, objectives, requirements, authorities, responsibilities, or work instructions.)
Do your safety management processes require your accountable executive to designate a management representive who, on behalf of your accountable executive, is responsible for:
• Coordinating the implementation, maintenance, and integration of the SMS throughout your organization;
• Facilitating hazard identification and safety risk analysis;
• Monitoring effectiveness of safety risk controls; and
• Ensure safety promotion is communicated throughout your organization;
• Regularly report to your accountable executive on the performance of the SMS and any need for improvement?
NPRM GAP Analysis
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SMSVP Standard: 5.25(c)
Process Objectives
SMSVP Requirement
(Note(s): The above qustion includes safety support personnel such as a Safety Officer, Director of Safety, Safety Department, etc., and associated staff.)
Element - Coordination of Emergency Response Planning
To provide the organization’s decision makers a means to develop and the accountable executive must approve an emergency response plan. This plan must delegate emergency authority throughout your organization, assign employee responsibilities during the emergency and coordinate your plans with organizations you interface with when you provide services.
Where emergency response procedures are necessary, do you develop and does your accountable executive and management representative approve, as part of the safety policy, an emergency response plan that provides for the safe transition from normal to emergency operations, and that addresses at least the following:
• Delegation of emergency authority throughout your organization;
• Assignment of employee responsibilities during an emergency; and
NPRM GAP Analysis
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QuestionsCompany's
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Element - SMS Documentation
Process Objective
SMSVP Requirement
SMSVP Standard: 5.95(a) & 5.21 (c)
• Coordination of the emergency response plan with other affected organizations (e.g., code share partners, airports, contractors, affiliates, etc.)?
To provide the organization’s decision makers have a means to ensure that you have documented safety policies; SMS processes and procedures.
(Note(s): Documentation Definition (reference FAA VS Order 8000.367) - Information or meaningful data and its supporting medium (e.g., paper, electronic) that is distinct from records because it is the written description of policies, processes, procedures, objectives, requirements, authorities, responsibilities, or work instructions.)
Do you have a process to develop and maintain SMS documentation that describes your safety policy, processes and procedures?
Does your safety management system ensure compliance with the relevant regulatory standards in 14 CFR?
NPRM GAP Analysis
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SMSVP Standard: 5.3(b)
Process Objective
SMSVP Requirement
SMSVP Standard: 5.3(a)(2)
Component - Safety Risk Management
To provide the organization’s decision makers a means to understand the critical characteristics of their systems and apply this knowledge to identify hazards, analyze and assess risk and design risk controls when designing, revising, or developing operational changes, or when identifying a new hazard or ineffective risk controls.
Does your safety management system have a safety risk management component that is in accordance with SMSVP Standard, subpart C, Safety Risk Management?
(Note(s): This question addresses the SMS Safety Risk Management Component in its entirety and is best answered after responding to all other questions within this component.
Your Continuous Analysis and Surveillance System (CASS) processes should be reviewed when you identify risk in the SMS Safety Risk Management and/or the SMS Safety Assurance Components.)
NPRM GAP Analysis
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Element - Applicability
SMSVP Requirement
• Implementation of new systems;
• Revision of existing systems;
• Development of operational procedures; and
SMSVP Standard: 5.51
SMSVP Standard: 5.23(a)(2)(i)
Does your safety management system require that the safety risk management process be used when any of the following conditions occur in your operational processes:
• Identification of hazards or ineffective risk controls identified through your safety assurance processes contained within the SMSVP Standard, subpart D, Safety Assurance?
Does your safety management system define accountability for developing, implementing and maintaining hazard identification and risk assessment processes for each of your operational manager's in their areas of responsibility?
(Note(s): This question/process includes owners of operational processes (Managers, Directors, etc.), at the decisional level across the organization.)
NPRM GAP Analysis
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SMSVP Standard: 5.23(b)
SMSVP Standard: 5.25(c)(2)
Does your safety management documentation identify the levels of management with the authority to make decisions regarding safety risk acceptance for the company?
(Note(s): This question/process includes owners of operational processes (Managers, Directors, etc.), at the decisional level across the organization.
Documentation Definition (reference FAA VS Order 8000.367) - Information or meaningful data and its supporting medium (e.g., paper, electronic) that is distinct from records because it is the written description of policies, processes, procedures, objectives, requirements, authorities, responsibilities, or work instructions.)
Does your safety management system ensure that your accountable executive designates a management representative to facilitate hazard identification and safety risk analysis?
(Note(s): This question/process includes safety support personnel such as a Safety Officer, Director of Safety, Safety Department, etc., and associated staff.)
Element - System Analysis & Hazard Identification
NPRM GAP Analysis
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Process - System Analysis
Process Objectives
SMSVP Requirement
• Function and purpose of the system;
• The system's operating environment;
SMSVP Standard: 5.53(a) & 5.53(b)
Process - Hazard Identification
Process Objective
Process Objectives. To provide the organization’s decision makers a means to describe and analyze its systems, operations, and operational environment to gain an understanding of critical design and performance factors, processes, and activities in order to identify hazards.
When applying safety risk management, do you have a process to describe and analyze the system for use in identifying hazards, and does this system analysis consider the following information:
• An outline of the system's processes and procedures;
• The personnel, equipment, and facilities necessary for operating the system?
NPRM GAP Analysis
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SMSVP Requirement
SMSVP Standard: 5.53(c)
Process - Analyze Safety Risk
Process Objective
SMSVP Requirement
To provide the organization’s decision makers a means to identify and document hazards to your operations, in the context of your system analysis, that are likely to cause death, serious physical harm, or damage to aircraft, aviation equipment or property.
Does the safety risk management component of your safety management system ensure that processes to identify hazards within the context of your system analysis are developed and maintained?
Element - Safety Risk Assessment and Control
To provide the organization’s decision makers a means to determine and analyze the severity and likelihood of potential events associated with identified hazards, and consider the risk factors associated with severity and likelihood..
Does the safety risk management component of your safety management system ensure that processes are developed and maintained to analyze safety risk associated with identified hazards?
NPRM GAP Analysis
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SMSVP Standard: 5.55(a)
Process - Safety Risk Assessment
Process Objective
SMSVP Requirement
SMSVP Standard: 5.55(b)
Process - Safety Risk Control
Process Objective
SMSVP Requirement
To provide the organization’s authorized decision makers a means to define and assess the risk associated with each identified hazard to determine if the risks are acceptable or not.
Does the safety risk management component of your safety management system define a process for conducting risk assessments that allows for the determination of acceptable safety risk?
To provide the organization’s decision makers a means to develop and maintain risk control(s) for each identified hazard with unacceptable risk to reduce the risk to an acceptable level. You must evaluate whether the risk will be acceptable with the proposed risk control applied before implementing the risk control.
Do you have a process to ensure that risk controls that are necessary as a result of your safety risk assessment process are developed, implemented and maintained?
NPRM GAP Analysis
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SMSVP Standard: 5.55(c) and 5.53(a)
SMSVP Standard: 5.55 (d)
SMSVP Standard: 5.73(a)(3)
Process Objective
(Note(s): Implementation of controls should include appropriate procedures, instructions and/or methods.)
Does your risk management process have procedures to evaluate whether the risk will be acceptable with the safety risk control applied before the risk control is implemented?
Does your safety management system have a process to ensure implemented risk controls are evaluated in the safety assurance component to identify ineffective controls?
Element - SMS Documentation and Recordkeeping (SRM)
To provide the organization’s decision makers a means to ensure that you have documented safety policies, SMS processes and procedures, and that a document/record management process is established and maintained that records SRM outputs.
NPRM GAP Analysis
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SMSVP Standard: 5.95(b)
SMSVP Standard: 5.97(a)
Component - Safety Assurance
Process Objective
SMSVP Requirement
(Note(s): Documentation Definition (reference FAA VS Order 8000.367) - Information or meaningful data and its supporting medium (e.g., paper, electronic) that is distinct from records because it is the written description of policies, processes, procedures, objectives, requirements, authorities, responsibilities, or work instructions.)
Do you have a process to develop and maintain SMS documentation that describes your safety risk management processes and procedures?
Do you have a process to maintain records of safety risk management outputs for as long as the controls remain relevant to your operations?
To provide the organization’s decision makers a means obtain timely feedback on the status, performance, and potential problems associated with processes in their area of responsibility. Safety assurance will monitor, measure, and evaluate your safety performance and the effectiveness of your risk controls.
NPRM GAP Analysis
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SMSVP Standard: 5.3(a)(3)
Process - Continuous Monitoring
Process Objective
SMSVP Requirement
Does your safety management system have a safety assurance component that is in accordance with the SMSVP Standard, Subpart D, Safety Assurance?
(Note(s): This question addresses the SMS Safety Assurance Component in its entirety and is best answered after responding to all other questions within this component.
Your Continuous Analysis and Surveillance System (CASS) processes should be reviewed when you identify risk in the SMS Safety Risk Management and/or the SMS Safety Assurance Components.)
Element - Safety Performance Monitoring and Measurement
To provide the organization’s decision makers a means to monitor and gather data with respect to operations, operational processes, and the operational environment. This includes products and services, identifying hazards, measuring the effectiveness of safety risk controls, and monitoring the safety performance of your organization.
NPRM GAP Analysis
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• continuous monitoring of operational processes,
SMSVP Standard: 5.71(a)(1) & 5.71(a)(2)
Process - Auditing
Process Objective
SMSVP Requirement
SMSVP Standard: 5.71(a)(3)
Process - Evaluations
Process Objective
Does your safety management system 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 to include:
• periodic moitoring of the operational environment to detect changes?
To provide the organization’s decision makers a means to gather data with respect to operations, products and services, and monitoring the safety performance of your organization through audits of operational processes and systems.
Does your safety management system develop and maintain processes and systems to acquire data with respect to your operations, products, and services to monitor the safety performance of your organization to include auditing your operational processes and systems?
NPRM GAP Analysis
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SMSVP Requirement
• Your SMS
• Your operational process and systems?
SMSVP Standard: 5.71(a)(4)
Process - Investigations
Process Objective
SMSVP Requirement
To provide the organization’s decision makers a means to gather data with respect to operations, products and services, and monitoring the safety performance of your organization through evaluations of the SMS and operational processes and systems.
Does your safety management system develop and maintain processes and systems to acquire data with respect your operations, products, and services to monitor the safety performance of your organization to include evaluations of:
To provide the organization’s decision makers a means to gather data with respect to operations, products and services, and monitoring the safety performance of your organization through investigation of incidents, accidents, potential non-compliance with regulatory standards or other safety risk controls established through your safety risk management process.
NPRM GAP Analysis
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• Incidents and accidents,
SMSVP Standard: 5.71(a)(5) & 5.71(a)(6)
Process Objective
SMSVP Requirement
Does your safety management system develop and maintain processes and systems to acquire data with respect to your operations, products, and services to monitor safety performance to include investigating the following :
• Reports regarding potential non-compliance with regulatory standards or other safety risk controls established through your SRM process?
Process - Confidential Employee Reporting System
To provide the organization’s decision makers a means to gather data with respect to operations, products and services, and monitoring the safety performance of your organization through a confidential employee reporting system in which employees can report hazards, issues, concerns, occurrences, incidents, as well as propose solutions and safety improvements.
NPRM GAP Analysis
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SMSVP Standard: 5.71(a)(7)
Process - Analyze Data
Process Objective
SMSVP Requirement
SMSVP Standard: 5.71(b)
Does your safety management system develop and maintain processes and systems to acquire data with respect to your operations, products, and services to monitor the safety performance to include a confidential employee reporting system in which employees can report hazards, issues, concerns, occurrences, incidents, as well as propose solutions and safety improvements?
To provide the organization’s decision makers a means to analyze data with respect to operations, products and services. This analysis will monitor the safety performance of your organization through audits, evaluations, investigations, and employee reports, and any other relevant data with respect to your operations, products, and services.
Have you developed, and do you maintain procedures to analyze data acquired from your safety assurance monitoring and measurement processes (the above five processes) and other relevant data from your operations, products and services?
NPRM GAP Analysis
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Process Objective
SMSVP Requirement
• Identify new hazards?
Process - Safety Performance Assessment
To provide the organization’s decision makers a means to conduct assessments, including reviews by the accountable executive, of safety performance against safety objectives and to ensure compliance with safety risk controls. You must evaluate the performance of your SMS, evaluate the effectiveness of safety risk controls, identify ineffective controls or new hazards, and identify changes in your operation. Ineffective controls or new hazards must be addressed through the SRM process.
Do you have documented processes to assess safety performance against your safety performance objectives that include reviews by your accountable executive to:
• Ensure compliance with your established safety risk controls;
• Evaluate the performance of your safety management system;
• Evaluate the effectiveness of your safety risk controls establlished under your SRM and identify any ineffective controls;
• Identify changes in your operational environment that may introduce new hazards,
NPRM GAP Analysis
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SMSVP Standard: 5.73(a) & 5.25(b)(5)
SMSVP Standard: 5.25(c)(3):
SMSVP Standard: 5.23(a)(2)(ii)
SMSVP Standard: 5.73(b)
Element - Continuous Improvement
Does your safety management processes ensure that the accountable executive designate a management representative who, on behalf your accountable executive, monitors the effectiveness of your safety risk controls?
(Note(s): This question/process includes safety support personnel such as a Safety Officer, Director of Safety, Safety Department, etc., and associated staff.)
Does your safety management system define accountability for assuring the effectiveness of safety risk controls for all your managers in their areas of responsibility?
(Note(s): This question/process includes owners of operational processes (Managers, Directors, etc.), at the decisional level across the organization.)
Do you have procedures to ensure you address in your safety risk management process any ineffective controls, new hazards or potential hazards identified during safety performance assessments (conducted as part of your safety assurance process)?
NPRM GAP Analysis
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Process Objective
SMSVP Requirement
SMSVP Standard: 5.75 & 5.25(b)(5)
SMSVP Standard: 5.75 & 5.25(b)(5)
Process Objective
To provide the organization’s decision makers a means to correct safety performance deficiencies identified in your safety performance assessment process.
Does your safety management have process to correct safety performance deficiencies identified during your safety performance assessments (conducted as part of your safety assurance process)?
Does your safey management have processes to ensure your accountable executive directs actions necessary to address substandard safety performance?
Element - SMS Documentation and Recordkeeping (SA)
To provide the organization’s decision makers a means to ensure that you have documented safety policies, SMS processes and procedures, and that a document/record management process is established and maintained that records SA outputs.
NPRM GAP Analysis
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SMSVP Standard: 5.95(b)
SMSVP Standard: 5.97(b) and 5.3 (b)
Component - Safety Promotion
Process Objective
(Note(s): Documentation Definition (reference FAA VS Order 8000.367) - Information or meaningful data and its supporting medium (e.g., paper, electronic) that is distinct from records because it is the written description of policies, processes, procedures, objectives, requirements, authorities, responsibilities, or work instructions.)
Do you have a process to develop and maintain SMS documentation that describes your safety assurance processes and procedures?
Do you have procedures to maintain records of outputs of the safety assurance processes for a minimum of 5 years?
Safety Promotion: General Expectations
NPRM GAP Analysis
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SMSVP Requirement
SMSVP Standard: 5.3(a)(4)
SMSVP Standard: 5.25(c)(4)
To provide your accountable executive and the organization’s decision makers a means to promote the growth of a positive safety culture, attain and maintain employee competencies necessary to perform their duties relevant to your operation and performance of the SMS, provide employees with effective SMS training, and a means to receive organization wide safety communication.
Does your safety management system have a safety promotion component that is in accordance with SMSVP Standard, Subpart E, Safety Promotion?
(Note(s): This question addresses the SMS Safety Promotion Component in its entirety and is best answered after responding to all other questions within this component.)
Do your safety management processes ensure that the accountable executive designates a management representative, who on behalf of the accountable executive, is responsible for ensuring safety promotion throughout your organization?
(Note(s): This question/process includes safety support personnel such as a Safety Officer, Director of Safety, Safety Department, etc., and associated staff.)
NPRM GAP Analysis
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SMSVP Standard: 5.23 (a) (2) (iii)
Element - Competencies and Training
Process Objective
SMSVP Requirement
Does your organization’s safety management system define accountability for promoting safety for each operational manager in their areas of responsibility?
(Note(s): This question/process includes owners of operational processes (Managers, Directors, etc.), at the decisional level across the organization.)
To provide the organization’s decision makers a means to train employees so they are competent in the performance of their SMS related duties.
(Note: In order to attain and maintain competencies necessary for their position, you must first identify the competencies required for each position.)
Does your safety management system have a process to ensure that your organization provides training to each individual identified in § 5.23 to ensure the individuals attain and maintain the competencies necessary to perform their duties relevant to the operation and performance of the SMS?
NPRM GAP Analysis
Page 29 of 32
QuestionsCompany's
Documentation Source
Flt OpsAssmt Rating
Disp.Assmt Rating
MTCAssmt Rating
CabinAssmt Rating
GroundAssmt Rating
CargoAssmt Rating
Train.Assmt Rating
SMSVP Standard: 5.91
Element - Safety Communication
Process Objective
SMSVP Requirement
• Ensures that employees are aware of the SMS;
SMSVP Standard: 5.93
(Note(s): Competence can be assessed at the completion of training by written, oral, or demonstration tests, and then measured periodically during the performance of that individual’s work by way of periodic evaluations or supervisor/management observations (reference AC 120-92).)
To provide the organization’s decision makers a means to communicate safety information
Does your safety management have processes and does it maintain process and systems to communicate safety information that:
• Conveys safety critical information;
• Explains why safety actions have been taken; and
• Explains why safety procedures are introduced or changed?
Element - SMS Documentation and Recordkeeping (Promotion)
NPRM GAP Analysis
Page 30 of 32
QuestionsCompany's
Documentation Source
Flt OpsAssmt Rating
Disp.Assmt Rating
MTCAssmt Rating
CabinAssmt Rating
GroundAssmt Rating
CargoAssmt Rating
Train.Assmt Rating
SMSVP Standard: 5.95(b) & 5.3 (b)
SMSVP Standard: 5.97(c) & 5.3(b)
SMSVP Standard: 5.97 (d) & 5.3(b)
(Note(s): Documentation Definition (reference FAA VS Order 8000.367) - Information or meaningful data and its supporting medium (e.g., paper, electronic) that is distinct from records because it is the written description of policies, processes, procedures, objectives, requirements, authorities, responsibilities, or work instructions.)
Do you have a process to develop and maintain SMS documentation that describes your safety promotion processes and procedures?
Do you have processes to maintain records of all SMS training accomplished for each individual for a minimum period of 24 consecutive calendar months after the completion of training?
Do you have a process to retain the records of all SMS safety communications for a minimum of 24 consecutive calendar months?
NOTE:
To be considered for “acceptance” by your CMT, each requirement of this SMS gap analysis should have a validated assessment scale rating of “Accomplished” or “Demonstrated”.
NPRM GAP Analysis
Page 31 of 32
QuestionsCompany's
Documentation Source
Flt OpsAssmt Rating
Disp.Assmt Rating
MTCAssmt Rating
CabinAssmt Rating
GroundAssmt Rating
CargoAssmt Rating
Train.Assmt Rating
Assessment Level Assessment Scale
Not Performed
NP
Planned
PLN
Documented**
DOC
Accomplished**
ACC
Assessment Rating ScaleWord Picture
No action has been taken on this requirement
A plan exists with actions to be taken or manual/s affected, a scheduled completion date and responsible individual or group identified to meet this requirement.
The policy and procedural guidance of this requirement are incorporated into company documents such as manuals, training material, and work instructions.
Resources are in place to accomplish all objectives of this requirement. Employees are expected to be trained and knowledgeable on the policies and procedures which were documented in the previous assessment level (DOC).
This requirement of your company’s SMS has been subjected to at least one round of evaluation/auditing by your company (and validated by the CMT/CHDO) to demonstrate operational performance and
