Safety Assurance Analysis of Data Overview
Analysis of Data is the third component in the FAA’s Part 5 Safety Assurance requirements. It is a natural response to the Data Acquisition process. Data analysis is a process. This means two things for you:
- This process should have multiple steps; and
- These steps should be repeatable.
Moreover, organizing data analysis as a process ensures that you can make needed changes and improvements to the process that increases efficiency during exposure assessment. Analysis of Data is found in the FAA’s Part 5 .71(b) requirements, and notes that:
“The certificate holder must develop and maintain processes that analyze the data acquired through the processes and systems identified [in Data Acquisition] and any other relevant data with respect to its operations, products, and services."
Such data analysis will often be performed on an issue by issue basis. That is, safety reports will be submitted (data acquisition) and then processed (analysis of data). It’s the tendency of service providers to analyze the data from these reports in isolation – this is the easiest way after all. “In isolation” means not considering how the data from a report fits in with the overall trends.
Analysis of Data needs to always happen from the viewpoint of how the current data fits in with the grander scheme of the SMS program’s data trends. It can significantly impact how data from reports is viewed.
Develop Process to Analyze Data
Part 5 says that certificate holders must “develop” a process that analyzes data. Do not confuse “develop” with “maintain,” as they imply two different activities.
Develop means to create the framework for data analysis. This framework should:
- Document how data will be analyzed;
- Specify how data will not be analyzed in isolation; and
- Show clear steps in the data analysis process.
Developing an analysis process is the bureaucratic arm of data analysis
Maintain Process to Analyze Data
Part 5 documentation says that in addition to developing process, certificate holders must “maintain” a process for analyzing data. As said, develop and maintain are distinct from each other. Maintaining a process means actually practicing data analysis in your organization by:
- Following the process that is developed;
- Using it to analyze safety reports; and
- Letting data analysis inform further components of Safety Assurance (i.e., Safety Performance Assessment).
Showing that you maintain your data analysis process means demonstrating safety issue in which data analysis was performed.
- How did you arrive at your findings?
- How did you make safety decisions?
- How did you choose risk controls?
If you can show answers to these questions for a given safety issue, then you are clearly maintaining your process so long as what you show is in line with the process you developed and documented.
Analysis of Data of “Products and Services”
It’s easy to focus Safety Assurance as being exclusive to operations. However, the FAA makes in clear in 5.71(b) that data analysis is pertinent to “products, and services” as well. In fact, the FAA goes so far to bold this portion of the requirement in order to drive home the notion that Safety Assurance includes quality management system elements as well. For this reasons, combining SMS and QMS makes a lot of sense.
The fact is, faulty product and service operations can have strong safety implications in addition to business-quality implications. Just consider recent American Airlines problem regarding injuring a passenger when removing him from a flight, and suffering major losses due to negative media attention.
This is a perfect example of service quality operations having significant safety implications. Your data analysis should include products and services where applicable.
Goals and Outcomes of Data Analysis Process
The primary goal of the FAA's Part 5 Safety Assurance Analysis of Data element is to organize and examine data. Your data analysis process should cover the following:
- Establish how current safety concern fits into overall context of your program;
- Ensure that all needed data is at hand;
- Establish and hone data analysis method;
- Compare current safety performance against historical safety performance; and
- Allow you to prepare safety reports.
In smaller SMS programs, analysis of data can be done by one person, such as the designated safety manager. In larger organizations, analysis of data will probably be completed by a dedicated team of individuals.
For a full overview of FAA Part 5 compliance, see these free resources: