Transcript Safety Management Systems for Design and Manufacturing (D&M) Organizations

Safety Management Systems
for
Design and Manufacturing
(D&M) Organizations
Federal Aviation
Administration
Pilot Project
Executive Summary
MSMS Team
FAA Aircraft Certification Service
Federal Aviation
Administration
SL-1
Executive Summary Topics
• The Need for SMS
• SMS Background
– ICAO and FAA linkage
– Internal vs. External SMS
– Part 5 Rulemaking
• SMS Components
• D&M SMS Pilot Project Overview
• Communications with the FAA
Federal Aviation
Administration
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The Need for SMS
• SMS has the potential to provide an order of
magnitude reduction in the accident rate.
• The accident rate in the US is at an all time low
(2010 Air Carrier rate = 0.3/100 million passengers)
• US air traffic is expected to double over the next 15
years
• Without this sort of change the number of annual
accidents may double as well.
World-wide average: 31 multi-engine a/c accidents/year
Federal Aviation
Administration
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The Need for SMS (cont’d)
• International acceptability of products may be
predicated on the implementation of SMS.
– ICAO has defined the necessity for implementation of
SMS
– Many countries are already requiring SMS to be
implemented
• SMS has the potential to reduce the cost of remedial
action within a design or production system that will
save valuable resources.
Federal Aviation
Administration
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SMS Requirements Hierarchy
ICAO and FAA Linkage
ICAO State Safety
Program (SSP)
• Annex 8
•Safety Management Manual (ICAO Doc 9859)
FAA Office of Aviation
Safety (AVS)
• Order 8000.369; FAA SMS Guidance
• Order VS8000.367; AVS SMS Requirements
• Part 5 SMS rulemaking
AVS Lines of Business
FAA Aircraft
Certification Service
(AIR)
D&M SMS Framework
D&M SMS Pilot Project Guide
SMS for
D & M Organizations
Future - regulations
and associated policies
Federal Aviation
Administration
SL-5
What is FAA’s internal SMS?
FAA SMS
AVSSMS
ATO SMS
ARP SMS
AST SMS
Alignment across LOBs
• FAA will implement an SMS comprised of aligned
SMSs in:
–
–
–
–
Aviation Safety (AVS)
Air Traffic Organization (ATO)
Airports (ARP)
Commercial Space Transportation (AST).
Federal Aviation
Administration
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D&M SMS relation to FAA’s internal SMS?
Industry
AVSSMS
AVS is incorporating SMS principles
and tools into the processes and
procedures used to oversee
industry.
Cert
Holder
SMS
Cert
Holder
SMS
Cert
Holder
SMS
Cert
Holder
SMS
Certificate holders across
industry (e.g. operators,
airports, D&Ms) will implement
their own SMS to manage the
risk in their operations.
Federal Aviation
Administration
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D&M SMS relation to FAA’s internal SMS?
(cont’d)
Industry
AVSSMS
Cert
Holder
SMS
Cert
Holder
SMS
Cert
Holder
SMS
Cert
Holder
SMS
The AVSSMS and industry SMSs will be aligned to share
data/information, results of safety risk analyses, etc. to more
effectively and efficiently provide assurance of the safety of the
operations.
Federal Aviation
Administration
SL-8
Part 5 SMS NPRM
• Public Law 111-216, section 215
(August 1, 2010) directed FAA to
issue a proposed SMS
rule for Part 121 operators
within 90 days
SEC. 215. SAFETY MANAGEMENT SYSTEMS.
(a) RULEMAKING.—The Administrator of the Federal Aviation
Administration shall conduct a rulemaking proceeding to require
all part 121 air carriers to implement a safety management system.
(b) MATTERS TO CONSIDER.—In conducting the rulemaking
under subsection (a), the Administrator shall consider, at a minimum,
including each of the following as a part of the safety
management system:
• Part 5 Notice issued
Nov 5, 2010
– The preamble is important to
understand context of the rule
(1) An aviation safety action program.
(2) A flight operational quality assurance program.
(3) A line operations safety audit.
(4) An advanced qualification program.
(c) DEADLINES.—The Administrator shall issue—
(1) not later than 90 days after the date of enactment
of this Act, a notice of proposed rulemaking under subsection
(a); and
(2) not later than 24 months after the date of enactment
of this Act, a final rule under subsection (a).
(d) SAFETY MANAGEMENT SYSTEM DEFINED.—In this section,
the term ‘‘safety management system’’ means the program established
by the Federal Aviation Administration
Enact a final rule within 24 months
Federal Aviation
Administration
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What does Part 5 Propose?
• Requires Part 121 operators
DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Parts 5 and 119
[Docket No. FAA–2009–0671; Notice No.
10–15]
RIN 2120–AJ86
Safety Management Systems for Part
121 Certificate Holders
AGENCY: Federal Aviation
Administration (FAA), Department of
Transportation (DOT).
ACTION: Notice of proposed rulemaking
(NPRM)…
– Develop and implement SMS
– Submit their SMS implementation plan within 6 months of the
effective date of a final rule.
– Full implementation within 3 years
• New 121 applicants – must implement SMS prior to
beginning Operations
• Public comment period closed Mar 7, 2011
ANPRM for SMS was rescinded on March 17, 2011 to update the docket (ANPRM comment
review and corresponding ARC report was used to develop Part 5 ). FAA continues to
consider potential rulemaking for Part 21 and others per the original ANPRM.
Federal Aviation
Administration
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What does Part 5 Propose? (cont’d)
Key Points of Emphasis:
• International harmonization
• Scalability and flexibility
• SMS rule is not a substitute for
existing regulatory compliance
• Documentation and recordkeeping
are to be kept as long as relevant to
operation.
Federal Aviation
Administration
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What does Part 5 Propose? (cont’d)
Other Important Points:
• Proposal aligns with core SMS
documentation
• Cost-benefit identifies positive return for industry
• Proposal introduces SMS terms and definitions
• SMS is intended to be performance-based
Part 5 has been drafted with the intent that it could
be applied to D & M organizations in the future
Federal Aviation
Administration
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Part 5 vs. D&M SMS Framework
• Why and how are they different?
– FAA Rulemaking team and the MSMS Team
started with the ICAO SMS framework and FAA
Order VS8000.367 Appendix B
– D&M SMS framework designed to support pilot project objectives
– D&M SMS framework developed for D&M organizations
• Air Operator terminology vs. D&M terminology
• System definition and associated hazards
• D&M framework safety assurance component more rigorous
• D&M SMS Framework developed before Part 5
requirements
• Part 5 may change as a result of public comment
Federal Aviation
Administration
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Addressing Differences
• Pilot Project feedback will help us develop
appropriate FAA regulations and associated
policies for D&M organizations
• We will reconcile any differences between the
framework and the final version of Part 5
– Interoperability
– Standardization
– Enforceability
– Unique D&M Attributes
Federal Aviation
Administration
SL-14
The Four Components of SMS
Policy
Safety Risk
Managemen
t
Safety
Assurance
Safety Promotion
SMS is a management system and it applies to an
entire organization not just the specific design and
manufacturing elements of a company
Federal Aviation
Administration
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The Four Components of SMS
• Safety Policy: Establishes senior management’s commitment to
continually improve safety; defines the methods, processes, and
organizational structure needed to meet safety goals.
• Safety Risk Management: Determines the need for, and
adequacy of, new or revised risk controls based on the assessment
of acceptable risk (applicable to products, processes and
organizational decisions).
• Safety Assurance: Evaluates the continued effectiveness of
implemented risk control strategies; supports the identification of
new hazards.
• Safety Promotion: Includes training, communication, and other
actions to create a positive safety culture within all levels of the
workforce.
Federal Aviation
Administration
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D&M SMS Pilot Project
Anticipated Pilot Project Duration and Launch Timeframes
Jan – Jun 2011
Pratt & Whitney
Honeywell
Co. No. 3
Co. No. 4
Co. No. 5
Jul – Dec 2011
Co. No. 6
Co. No. 7
Co. No. 8
Co. No. 9
Co. No. 10
Co. No. 11
Co. No. 12
Jan – Dec 2012
2013 & beyond
Participants build
and improve
their SMS…
Potential
Rulemaking
Activities
Participants: Design & Manufacturing Companies – representing a cross-section
of the industry (small, med, large, TSO/PMA, STC to TC/PC, aircraft, engines,
parts)
FAA Involvement: MSMS Team and Local ACO/ECO and MIDO representatives
Federal Aviation
Administration
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High-Level Concept and Purpose of
Pilot Project
• Concept: To collaboratively work with Industry to
develop a workable D&M SMS model.
• Purpose: To collect input on potential rulemaking
requirements, scalability, applicability, implementation
assessment/oversight methods, tools and guidance as
they relate to D&M SMS.
Federal Aviation
Administration
SL-18
High-Level List of Tasks Required
During Pilot Project
Level 1 – Approximately six months
Orientation &
Preliminary
Gap Analysis
Detailed
Gap Analysis
Develop
Implementation
Plan & ID Safety
Objectives
Develop
Safety Policy
Levels 2 & 3 – go through Level 2 and into Level 3 within 18 months
Document and
Implement
Company’s SMS
Evaluate
Progress to SMS
Goals/Objectives
Conduct
SRM and SA
Maintain Policy
and
Promote SMS
Level 4 – Continuous Improvement
Federal Aviation
Administration
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Preliminary Gap Analysis Tool
• Purpose
– Enables a company to take a quick snap shot of
where they are in terms of SMS functionality
– Facilitates dialogue between FAA and participants
– Caution: Preliminary Gap Analysis results may
appear to show a large gap though the effort to
close the gap may be small
• Link to Preliminary Gap Analysis Tool
Federal Aviation
Administration
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Responsibilities and Expectations
Participant
FAA
• Contribute adequate resources to
accomplish pilot project tasks
• Complete detailed gap analysis within six
months
• Execute implementation planning tasks
within six months (exit Level 1)
• Implement SMS to achieve Level 3 within 18
months and maintain momentum
• Provide feedback to the FAA on how to
achieve the expectations outlined in the FAA
Framework
• Provide feedback on the approaches to
assessing Participant SMSs, oversight
processes, and other relevant areas of
concern
• Actively participate in lessons learned and
data collection processes in support of
achieving SMS pilot project objectives.
• Conduct orientation sessions
• Provide final acceptance to exit each level
• Support Participant through gap analysis
assessment process and implementation
plan development
• Provide guidance and advice to the company
on SMS implementation and best practices
• Collect lessons learned and other data to
support achieving Pilot Project objectives
• Communicate the benefits of SMS internally
to the FAA and externally to industry
• Establish forums to share best practices
information among pilot project participants
• Actively participate in lessons learned and
data collection processes in support of
achieving SMS pilot project objectives.
Federal Aviation
Administration
SL-21
Management Commitment
and Resources
• Identify an accountable executive to
oversee the implementation and maintenance of the SMS
• Executives commit to sponsoring and providing resources to
implement and maintain SMS
• Executives and management learn SMS concepts
• Executives and management endorse SMS policy and define
objectives
• Executives and management promote SMS throughout the
organization
– Visibly endorse SMS
– Personally involved in the SMS implementation
– Communicate SMS implementation and benefits to the workforce.
Federal Aviation
Administration
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Benefits of Participating in the Pilot
Project
• Opportunity to achieve safety benefit of SMS
• Contribute to shaping of FAA regulations, orders
and policy
• Get a head start toward implementing SMS
• At the forefront of influencing/shaping the larger
international aviation D&M community
• Enables the local FAA office to support the
participant and become knowledgeable of SMS
– Providing for a more seamless integration of SMS into the
Pilot Project Participant’s system.
Federal Aviation
Administration
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FAA - Participant
Communications
• Interaction managed by Participant POC and FAA’s
Participant Management Team Lead
• Anticipated meetings in Level 1:
– Scheduled and ad-hoc discussions to understand D&M SMS
Framework and Developmental Guidance
• Important for us to work closely together in initial activities
– Detailed Gap Analysis and Implementation Plan review meeting
(Exit Level 1 discussion)
• Information may be exchanged in-person and/or via
email, phone and SharePoint site
• FAA will ask for feedback on the SMS expectations,
assessment process, and pilot project process
Federal Aviation
Administration
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Key Executive Summary Takeaways
• Need your commitment to apply the necessary
resources to conduct the Pilot Project
• Need to work collaboratively over the next 18
months to support the pilot project
• Looking for your input to shape the future of SMS
We look forward to working with you in Aircraft
Certification’s D&M SMS Pilot Project
Federal Aviation
Administration
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