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FAA Part 5 Compliance | Safety Assurance Continuous Improvement

Posted by Tyler Britton on Jan 6, 2020 6:15:00 AM

Purpose of Continuous Improvement in Safety Assurance Pillar

Part 5 Compliance FAA Safety Assurance Continuous Improvement

In every aviation safety management system (SMS), the accountable executive is responsible for ensuring the SMS is properly implemented and performing in all areas of the organization. The intent is not for the aviation SMS to reach some ideal "plateau of safety" and then maintain the "ideal safety level." Far from it!

The purpose of the aviation SMS is to demonstrate that the organization can proactively manage safety year-after-year, audit-after-audit.

As your SMS matures, your ability to collect and analyze safety data will increase. Your safety management capabilities are expected to gradually become more sophisticated. Furthermore, SMS regulatory auditors will have higher expectations of your SMS as more data has been collected, or should have been collected.

How will you react to these demands to demonstrate continuous improvement?

Related Articles on Continuous Improvement in Aviation SMS Implementations

What is Continuous Improvement in Aviation SMS

Continuous Improvement in FAA Part 5 compliance (Part 5.75) is simply a requirement for correcting “deficiencies identified in the assessments conducted under [the Safety Performance Assessment] process.” (Part 5.75 documentation)

The continuous improvement element is triggered when safety performance is found to be unacceptable, and the problem is due to the company’s compliance/safety policy or risk controls. Corrective actions are used to correct the deficiencies in the applicable compliance/safety policy.

The continuous improvement element is the final step in the Safety Assurance process. At this point:

  • Risk has already been analyzed;
  • Risk has already been assessed;
  • The problem(s) has been identified; and
  • The only action needed is to develop, implement and monitor corrective actions.

Continuous improvement is measured as a result of:

  • Classifying safety data during reactive and proactive risk management processes; and
  • Comparing results against organizational safety goals and objectives.

Part 5 Compliance

What Is a Corrective Action

A corrective action is an action used to correct any undesirable element of safety performance. Most commonly, corrective actions are called CPAs, (for corrective actions and preventive actions). You may also see them called CAPAs (corrective action and preventative action) or RCAs (recommended corrective action), though CPA is the most recognized globally in the aviation industry.

Generally, corrective actions are facilitated by subject matter experts, such as department heads, and reviewed/overseen by either:

  • safety mangers;
  • quality assurance teams; and/or
  • safety committees.

Corrective actions fix safety issues by making changes that bring an adverse element of the program into an acceptable level of safety (ALoS) or as low as reasonably possible (ALARP).

Corrective actions differ from:

  • Preventative actions, which are used to include a new element into the SMS in order to reduce the likelihood of undesirable things (which may not have happened yet); and
  • Detective actions, which are used to include new elements into the SMS in order to identify emerging undesirable elements.

Corrective actions are generally considered as a part of reactive risk management activities. Having effective corrective action implementation strategies is absolutely essential to the development and success of the Safety Assurance Pillar of aviation SMS implementations.

Related Articles on Corrective Actions in Aviation SMS

Example Scenario for Continuous Improvement

Here is an example safety concern that would culminate in the Safety Assurance continuous improvement action:

  • A safety incident is reported and safety mangers are notified (Data Acquisition);
  • A preliminary investigation is performed (Analysis of Data)
  • A risk assessment is performed (Safety Performance Assessment);
  • Based on the assessment and investigation, the responsible manager determines that deficiencies in company policy and control measures contributed to the safety issue;
  • Based on these findings, he/she will issue corrective action(s) to employees in order to correct the problem(s) (Continuous Improvement); and
  • The system will continue to be monitored.

As shown above, corrective actions are triggered by some kind of safety event or discovery. Corrective actions are extremely important for aviation SMS implementations, as safety programs first and foremost need to be able to quickly and efficiently fix problems.

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Continuous Improvement Corrective Action Types

Corrective actions can be anything from training, to safety policy update, to new control measures. They can address individual people or the bureaucracy of the safety management system. Corrections of individuals are usually things like:

  • Attending remedial aviation SMS training;
  • Update safety policy to correct specific human behavior; or
  • Probation, performance reviews, etc. (usually in more serious circumstances).

Corrections of the SMS bureaucracy are usually:

  • Updating a dated safety policy or procedure;
  • Replacing a malfunctioning/old piece of equipment, sign, etc.; or
  • Fixing an area of non-compliance in the program.

Any significant changes to the System that could potentially compromise operational safety will require that the changes are processed through the Safety Risk Management (SRM) process.

Related Safety Risk Management (SRM) Articles

Final Thought: Indications of Continuous Improvement Compliance

Establishing whether or not you are compliant with the FAA’s continuous improvement element is as simple as assessing whether or not:

  • You have documented the process for creating corrective actions, which may be physically documented in something like a Word document, or inherently documented in the process of aviation safety management software;
  • You have evidence of creating corrective actions in response to safety performance deficiencies, including justification of why those corrective actions were created;
  • You have evidence that corrective actions are delivered to relevant employees, and that the actions are carried out to completion; and
  • You have documented evidence for reviewing the effectiveness of the control measures.

For a full overview of FAA compliance, you will find these resources valuable:

 

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Published May 2017. Last updated December 2019.

Topics: 3-Safety Assurance, FAA Compliance

Site content provided by Northwest Data Solutions is meant for informational purposes only. Opinions presented here are not provided by any civil aviation authority or standards body.

 

 

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