For new aviation safety managers, writing a system description for a Safety Management System (SMS) can feel daunting. The system description is a foundational document that summarizes an organization’s processes, activities, and interfaces, serving as the starting point for hazard identification and safety risk assessment.
It outlines the aviation system in which the organization operates, including internal and external entities, authorities, and interfaces that contribute to safe service delivery.
A well-crafted system description is critical for implementing an effective SMS, ensuring compliance with International Civil Aviation Organization (ICAO) Annex 19 and national regulations like the FAA’s 14 CFR Part 5 or EASA’s requirements. This article provides actionable tips to help aviation safety managers quickly and effectively write a system description, streamlining the process while meeting regulatory and operational needs.
The system description is the blueprint of an organization’s aviation operations within the SMS framework. According to ICAO’s Safety Management Manual (Doc 9859), it defines the scope of the SMS by identifying the systems, processes, and interfaces that must be monitored for safety risks. For service providers (e.g., airlines, airports, maintenance organizations) or State civil aviation authorities, the system description:
Guides Hazard Identification: Pinpoints areas where hazards may arise, such as flight operations or ground handling.
Supports Risk Assessment: Provides context for evaluating the severity and likelihood of risks.
Ensures Compliance: Demonstrates to regulators (e.g., FAA, EASA) that the SMS covers all relevant activities.
Facilitates Communication: Aligns internal and external stakeholders on safety responsibilities.
Streamlines SMS Implementation: Serves as a reference for developing policies, procedures, and training.
For new safety managers, the challenge lies in organizing complex information into a clear, concise document. The following tips simplify the process, helping you create a system description that is both compliant and practical.
Before writing, clarify the system description’s purpose: to map the organization’s aviation system and its interfaces for SMS implementation. This understanding sets the foundation for a focused document.
Purpose: The system description identifies all processes, activities, and entities that impact safety, providing a framework for hazard identification and risk management.
Scope: It covers:
Internal Processes: Activities within the organization, such as flight operations, maintenance, or air traffic control.
External Interfaces: Interactions with other entities, like regulators, suppliers, or contracted ground handlers.
System Context: The broader aviation system, including regulatory oversight and industry standards.
Action Item: Review ICAO Annex 19 and the Safety Management Manual (Doc 9859) to understand the system description’s role. For U.S. operators, consult FAA’s Advisory Circular (AC) 120-92B for SMS guidance.
Example: For a small flight school, the scope might include pilot training, aircraft maintenance, and interactions with the local FAA Flight Standards District Office (FSDO).
Collect detailed information about your organization’s structure, operations, and external relationships to ensure the system description is comprehensive.
Internal Data:
Organizational Structure: Identify departments (e.g., operations, maintenance, safety) and key roles (e.g., Chief Pilot, Safety Manager). Many of these will be your internal interfaces.
Operational Activities: List core processes, such as flight scheduling, fueling, or baggage handling.
Resources: Note assets like aircraft types, facilities, or technology systems (e.g., flight planning software).
External Data:
Regulatory Authorities: Identify oversight bodies (e.g., FAA, EASA) and their requirements.
Partners and Suppliers: List external entities, such as fuel providers, contracted maintenance organizations, or air traffic control.
Industry Context: Consider standards from organizations like the International Air Transport Association (IATA) or Airports Council International (ACI).
How to Gather:
Review organizational charts, operational manuals, and contracts.
Interview department heads to understand workflows.
Check regulatory documents for compliance obligations.
Example: An airport’s system description might include runway maintenance, terminal operations, and interfaces with airlines, air traffic control, and the FAA’s Airport Certification Program.
Tool: Use the FAA’s SMS Gap Analysis Tool or SKYbrary’s Safety Management Toolkit (skybrary.aero) to structure data collection.
Break down your organization’s operations into key processes and activities to create a clear picture of the aviation system.
Process Categories:
Flight Operations: Pilot training, flight planning, in-flight procedures.
Ground Operations: Baggage handling, refueling, de-icing.
Maintenance: Inspections, repairs, record-keeping.
Management and Support: Safety reporting, training, quality assurance.
Activity Details:
Describe each process, including inputs (e.g., flight schedules), outputs (e.g., completed flights), and responsible parties (e.g., dispatchers).
Note potential hazards (e.g., runway incursions, maintenance errors) to guide future risk assessments.
How to Map:
Create a flowchart or table to visualize processes.
Use existing operational manuals as a reference.
Engage frontline staff (e.g., pilots, ground crew) to ensure accuracy.
Example: For a cargo operator, map processes like “cargo loading” (inputs: cargo manifests; outputs: secured cargo; hazards: load shifts) and “maintenance scheduling” (inputs: maintenance logs; outputs: airworthy aircraft; hazards: missed inspections).
Pro Tip: Start with high-level processes and add details iteratively to avoid becoming overwhelmed.
Interfaces—interactions within and outside the organization—are critical for a complete system description, as they often introduce safety risks.
Internal Interfaces:
Interactions between departments, such as operations coordinating with maintenance for aircraft availability.
Example: A maintenance team notifying dispatchers of a delayed repair.
External Interfaces:
Relationships with regulators, contractors, or other operators.
Example: An airline interfacing with air traffic control for takeoff clearances or with a fuel supplier for quality checks.
Risk Points:
Highlight interfaces where miscommunication or errors could occur, such as handoffs between ground crew and pilots.
How to Identify:
Review operational workflows to spot handoffs (e.g., shift changes, data transfers).
Check contracts or service agreements with external parties.
Consult staff to identify undocumented interfaces.
Example: A regional airline’s system description might note an internal interface between flight operations and crew scheduling (risk: scheduling errors) and an external interface with a contracted de-icing provider (risk: improper de-icing).
Tool: Use a process mapping tool like Microsoft Visio or Lucidchart to diagram interfaces. Microsoft PowerPoint can also add value if you don't have Visio.
Ensure the system description meets regulatory expectations by aligning with ICAO, FAA, or EASA standards.
ICAO Annex 19:
Requires a system description that defines the SMS scope, including all safety-critical processes and interfaces.
See Doc 9859 for examples of system descriptions.
FAA (14 CFR Part 5):
Mandates that the SMS covers all operational processes and includes risk management for identified hazards.
Reference AC 120-92B for guidance on documenting systems.
EASA:
Requires a system description that reflects the organization’s complexity and risk profile.
Use EASA’s Management System Assessment Tool for compliance checks.
How to Align:
Cross-reference your system description with regulatory checklists.
Include a statement confirming the SMS scope (e.g., “This system description covers all safety-critical processes as required by 14 CFR Part 5”).
Document how interfaces with regulators (e.g., FAA FSDO) are managed.
Example: A maintenance organization might state, “The system description includes maintenance, quality control, and interfaces with the FAA, ensuring compliance with Part 145 and SMS requirements.”
Resource: Download FAA’s SMS Voluntary Program (SMSVP) Guide (faa.gov) for compliance templates.
A template simplifies the writing process by providing a clear framework for organizing information.
Template Components:
Introduction: State the purpose and scope of the system description.
Organization Overview: Describe the organization’s size, structure, and operational context.
Processes and Activities: List key operational processes with descriptions.
Interfaces: Detail internal and external interactions.
Regulatory Context: Outline compliance with ICAO, FAA, or EASA standards.
Conclusion: Summarize the SMS scope and next steps (e.g., hazard identification).
Formatting Tips:
Use headings and subheadings for clarity.
Include tables or diagrams for processes and interfaces.
Keep language concise and jargon-free for accessibility.
Example Template:
Introduction: “This system description outlines [Organization Name]’s aviation system for SMS implementation, covering all safety-critical processes and interfaces as required by ICAO Annex 19.”
Organization Overview: “[Organization Name] operates [number] aircraft, with [number] employees, focusing on [e.g., passenger transport, cargo].”
Processes and Activities: Table listing processes (e.g., flight operations, maintenance) with descriptions and hazards.
Interfaces: Diagram showing internal (e.g., operations-maintenance) and external (e.g., FAA, fuel suppliers) interactions.
Regulatory Context: “The SMS aligns with FAA’s 14 CFR Part 5 and AC 120-92B.”
Conclusion: “This document provides the foundation for hazard identification and risk assessment.”
Resource: Adapt templates from NBAA’s SMS Toolkit (nbaa.org) or IATA’s SMS Implementation Guide (iata.org).
Involving stakeholders ensures the system description is accurate and fosters buy-in for Sms implementation.
Who to Engage:
Internal: Department heads, frontline staff (e.g., pilots, ground crew), and safety officers.
External: Regulators, contractors, or partner organizations.
How to Engage:
Hold workshops to map processes and interfaces.
Conduct interviews to clarify roles and responsibilities.
Share drafts for feedback to catch gaps or errors.
Benefits:
Improves accuracy by incorporating diverse perspectives.
Builds a safety culture by involving staff early.
Example: A small airport might hold a meeting with air traffic controllers, ground staff, and airline representatives to confirm interfaces, such as runway inspections and aircraft handoffs.
Action Item: Join LinkedIn groups like "Aviation Safety Management Systems," “Aviation Safety Professionals” or follow #SMSImplementation on X to connect with peers for stakeholder engagement strategies.
Avoid perfectionism by starting with a basic system description and refining it over time.
Initial Draft:
Focus on high-level processes (e.g., flight operations, maintenance).
Include obvious interfaces (e.g., regulator oversight, key suppliers).
Use a simple template to organize information.
Iterative Refinement:
Add details as you gather more data (e.g., specific hazards, minor interfaces).
Update the description during SMS implementation (e.g., after hazard identification).
Incorporate feedback from audits or staff.
Example: A new safety manager for a flight school might start with a one-page system description covering training flights, aircraft checks, and FAA oversight, then expand it to include student scheduling and weather monitoring after team input.
Pro Tip: Set a deadline (e.g., two weeks) for the initial draft to maintain momentum.
Use industry resources to accelerate the writing process and ensure compliance.
Regulatory Resources:
FAA: SMSVP Guide, AC 120-92B, and SMS Gap Analysis Tool (faa.gov).
ICAO: Safety Management Manual (Doc 9859) (icao.int).
EASA: Management System Assessment Tool (easa.europa.eu).
Industry Resources:
Online Platforms:
Aviation Safety Network (aviation-safety.net) for case studies.
SMS Pro (asms-pro.com) for free and paid templates.
How to Use:
Adapt sample system descriptions to your operation.
Cross-reference resources to ensure regulatory alignment.
Bookmark key websites for quick access during writing.
Example: A maintenance organization might adapt a system description template from the FAA’s SMSVP Guide, customizing it to include Part 145 processes like component repairs and FAA audits.
Finalize the system description with clear documentation and validation to ensure it’s ready for SMS implementation and regulatory scrutiny.
Documentation:
Include the system description in the SMS manual or safety policy.
Use a version control system (e.g., SMS Pro's version-controlled Document Manger or “Version 1.0, [Date]”) to track updates.
Ensure accessibility to all staff via a shared drive, intranet or SMS Pro's version-controlled Document Manger.
Validation:
Review the description against ICAO Annex 19 or FAA Part 5 requirements.
Test its applicability by using it for initial hazard identification (e.g., list hazards for each process).
Seek feedback from regulators or SMS consultants during audits.
Example: An airline might validate its system description by applying it to a risk assessment for “runway incursions,” ensuring all relevant processes (e.g., air traffic control interfaces) are covered.
Tool: Use EASA’s Management System Assessment Tool to validate compliance.
Writing a system description can present challenges, especially for new safety managers. Here’s how to address common issues:
Challenge: Overwhelm from complex operations.
Solution: Start with high-level processes and use templates to organize information.
Challenge: Limited knowledge of interfaces.
Solution: Engage stakeholders and review contracts to uncover hidden interactions.
Challenge: Time constraints.
Solution: Set a deadline for a basic draft and refine iteratively, leveraging existing resources.
Challenge: Ensuring regulatory compliance.
Solution: Cross-reference ICAO, FAA, or EASA guidance and seek peer feedback via LinkedIn or industry events.
Writing a system description for an aviation SMS is a critical but manageable task for new safety managers. By
This document not only satisfies regulatory requirements but also provides a roadmap for hazard identification and risk management, strengthening your organization’s safety culture.
Start by reviewing your organization’s operations and downloading a template from the FAA or IATA. Engage your team to ensure accuracy and use free resources from SKYbrary or NBAA to fill gaps. With these tips, you’ll quickly produce a system description that meets ICAO, FAA, or EASA standards and supports a safer aviation operation.
SMS Pro includes a system description template in our Proactive Hazard Analysis Tool (PHAT).