SMS Pro Aviation Safety Software Blog 4 Airlines & Airports

FAA Part 5 Compliance | Safety Assurance Performance Monitoring and Data Acquisition Components

Posted by Tyler Britton on Jul 5, 2017 6:04:00 AM

What is Safety Assurance for FAA

Part 5 Compliance FAA Safety Assurance Data Acquisition and System MonitoringSafety Assurance is designed to ensure that airport SMS programs, airline SMS programs, and aviation service providers practice their safety program effectively. It is one of the Four Pillars of SMS. Safety assurance practices have strong overlaps with quality management. As aviation SMS programs are implemented, the Safety Assurance pillar will continually become more important.

The first two elements of Safety Assurance as defined by the Federal Aviation Administration are:

  1. System Monitoring; and
  2. Data Acquisition.

These two elements are tightly intertwined, and as such the FAA considers them together. Here is the FAA’s Safety Performance Monitoring and Data Acquisition components.

Monitor Operational Processes

The FAA’s Part 5 (5.71(a)(1)) indicates that you need to develop a process for monitoring operational processes on a day-to-day basis. These operational processes include:

  • Supervision of employees;
  • Reviewing safety data, such as duty logs or safety reports; and
  • Safety policy and procedure (including checklists).

It goes without saying that the larger the organization, the more complex this monitoring will be. In smaller organizations, monitoring operational processes may be fulfilled by only one person. As organizations grow, the burden of this monitoring will transfer to multiple people (such as a safety team), and eventually to multiple tiers of management.

Having a solid issue management process is one way to fulfill this element.

Monitoring Operational Environment

The second part of the FAA’s Safety Performance Monitoring and Data Acquisition in Part 5 (5.71(a)(2)) is monitoring the operational environment to detect changes. This element is a bit troubling because:

  • “…changes” is rather vague; and
  • The distinction between this element and monitoring operational processes is blurred.

The FAA’s Advisory Circular admits that this element involves “practices that are similar to those of operational processes.” However, the important point is that:

  • “Operational environment” is equivalent to the “System” that is described in the first part of the FAA’s SRM process; and
  • “Changes” are assumed to be elements of the operational environment that are not accounted for in the “System”.

As in the previous case, an Issue Management process will fulfill this element.

Auditing Operational Processes

Auditing operational processes, Part 5 (5.71(a)(3)), is a straightforward data acquisition action that safety professionals are familiar with. One doesn’t often think of aviation SMS audits as having the goal of “data acquisition,” however they do have one primary goal:

  • Evaluate to what extent organization practices are being followed as documented.

This component is three-fold:

  • That you outline an auditing process;
  • That you develop auditing procedures; and
  • That you follow through with actually conducting audits.

This is explicitly stated in Part 5. Auditing can be completed by documenting the audit results:

The Advisory Circular indicates that the frequency of audits should scale with the size of the organization (larger company means more audits).

Evaluation of SMS Program

Evaluation of the SMS program – Part 5 (5.71(a)(4) – is a tough nut to crack because of seemingly conflicting information. The AC says that evaluations are usually carried out by an independent party. This indicates that the primary difference between Auditing and Evaluation is:

  • That an evaluation is performed by an external party.

However, the AC goes on to say that an “…evaluation is an internal oversight tool…” So, which is it: an internal or external function? The happy medium here is that:

  • Each section of an audit is overseen by the relevant department head (or similar person in charge);
  • Evaluations are carried out by an “objective” party that is not regularly involved with what is being evaluated.

Organizations will need to list what their specific criteria or for how conducts evaluations, clarifying things like:

  • What does “objective” mean to the company;
  • What qualifications an evaluator needs to have; and
  • The scope of what each evaluator is evaluating.

The goal of evaluations is to provide a summary of the entire SMS program, such as a list of what is “working” and what “isn’t working” that can be presented to the accountable executive.

Perform Investigations on Safety Incidents and Non-Compliance

Part 5 (5.71(a)(5) further points to a different data acquisition process, Investigations, which is somewhat similar to Evaluations and Audits. However, the difference between Investigations and Evaluations/Audits is that Investigations are performed:

  • On an individual issue (i.e., issue by issue basis); and
  • To establish “what went wrong” for a specific hazard (dangerous condition).

Both Audits and Evaluations analyze the SMS program as a whole. Investigations are designed for specific cases. In the same manner, Part 5 (5.71(a)(6) calls for investigations of non-compliance. These investigations also are done on a case by case basis. Of course, this requirement entails that you have a way for employees to report potential non-compliance.

Have Confidential Reporting System

The last component of the Part 5 requirements for Safety Monitoring and Data Acquisition is the requirement for SMS programs to have a confidential reporting system (5.71(a)(7)). All this entails is that employees can report:

  • Hazards;
  • Safety issues;
  • Concerns; and
  • Suggestions.

Of course, the “confidential” portion of this requirement also entails that employees can report confidentially. “Confidential” should be defined by each organization, but generally means that employees can report:

  • Anonymously;
  • Without other employees seeing their report; and
  • Without managers (other than safety manager) seeing the report.

SMS programs under the FAA need to define a process and ensure that it works for employees.


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

FAA Part 5 Compliance

FAA SRM Compliance Guide

Topics: 3-Safety Assurance, FAA Compliance

 

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