For new aviation safety managers, documenting the risk matrix process within a Safety Management System (SMS) can be a challenging task. The risk matrix is a cornerstone of aviation safety risk management, enabling organizations to assess and prioritize hazards based on their severity and likelihood.
For U.S.-based operators, ensuring that the risk matrix process complies with the Federal Aviation Administration’s (FAA) requirements under 14 CFR Part 5 is critical for regulatory adherence and effective safety management. A well-documented process not only satisfies FAA audits but also supports consistent risk assessments and fosters a proactive safety culture.
This article provides aviation safety managers with clear, actionable steps to document the risk matrix process, ensuring compliance with FAA standards while simplifying the task for newcomers.
The risk matrix is a visual tool that categorizes risks by plotting severity (potential impact) against likelihood (probability of occurrence), typically resulting in risk levels such as low, medium, or high.
Documenting the process for developing, using, and maintaining the risk matrix is a requirement under FAA’s SMS rule (14 CFR Part 5), specifically §5.53, which mandates documented safety risk management processes. According to FAA’s Advisory Circular (AC) 120-92B, documentation ensures that the risk assessment process is systematic, repeatable, and tailored to the organization’s operations.
A well-documented risk matrix process:
Ensures Compliance: Meets FAA requirements for SMS implementation and audit readiness.
Promotes Consistency: Provides a standardized approach for staff to assess risks.
Supports Training: Serves as a reference for onboarding new team members.
Facilitates Audits: Demonstrates to FAA inspectors that the SMS is robust and operational.
Enhances Safety: Enables accurate risk prioritization, reducing the likelihood of incidents.
For new safety managers, the challenge lies in understanding what to document and how to structure it. The following steps guide you through the process, aligning with FAA standards and simplifying documentation for beginners starting your SMS implementation.
Begin by familiarizing yourself with the FAA’s expectations for risk management documentation, as outlined in key regulatory and guidance documents.
Key References:
14 CFR Part 5.53: Requires a documented process for safety risk management, including hazard identification and risk assessment.
AC 120-92B: Emphasizes that risk assessment processes must be systematic, repeatable, and documented, with clear severity and likelihood criteria.
FAA Order 8040.4C: Outlines risk management principles, requiring defined risk levels and action protocols.
SMS Voluntary Program (SMSVP) Standard: Provides templates and examples for documenting risk matrices, available on the FAA website (faa.gov).
Core FAA Requirements:
The risk matrix process must describe how severity and likelihood are defined and assessed.
It must outline how risks are categorized and prioritized.
The process must be tailored to the organization’s size, complexity, and risk profile.
Documentation must be accessible, repeatable, and auditable.
Action Item: Download the FAA’s SMS Implementation Guide and SMS Gap Analysis Tool from faa.gov to understand documentation expectations and use as a checklist.
Example: A small charter operator might note, “Our risk matrix process complies with 14 CFR Part 5.53 by defining severity and likelihood criteria specific to our single-aircraft operation.”
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Document the structure of the risk matrix, including its design and components, to ensure it meets FAA’s requirement for a systematic approach.
Matrix Design:
Specify the grid size (e.g., 3x3, 4x4, or 5x5), with severity on one axis and likelihood on the other.
Example: “The risk matrix is a 5x5 grid, with five severity levels (negligible to catastrophic) and five likelihood levels (improbable to frequent).”
Severity Criteria:
Define levels based on potential consequences, such as injuries, aircraft damage, or operational disruptions.
Example: “Moderate severity includes single injuries or repair costs up to $100,000.”
Likelihood Criteria:
Define levels based on probability, using qualitative or quantitative measures.
Example: “Occasional likelihood means an event occurs once every 1–5 years, based on historical data.”
Risk Levels:
Assign categories (e.g., low, medium, high) with corresponding actions.
Example: “High-risk events (e.g., catastrophic severity, probable likelihood) require immediate mitigation within 24 hours.”
Visual Aids:
Include color coding (e.g., green for low, red for high) to enhance usability.
Documentation Tip: Include a table or diagram of the risk matrix in the documentation, labeled clearly (e.g., “Figure 1: Risk Matrix Structure”).
Example: An airline’s documentation might state, “The 5x5 risk matrix uses green for low risk (monitor), yellow for medium risk (mitigate within 30 days), and red for high risk (immediate action).”
Resource: Adapt risk matrix templates from the FAA’s SMSVP Guide or IATA’s SMS Implementation Guide (iata.org).
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The FAA requires the risk matrix to reflect the organization’s size, complexity, and risk profile (AC 120-92B). Document how the matrix was tailored to your operation.
Size and Complexity:
Explain how the matrix suits your operation’s scale.
Example: “For our small flight school with three aircraft, a 3x3 matrix simplifies risk assessments for training flights and maintenance.”
For larger operators: “Our airline’s 5x5 matrix accounts for complex operations across 50 aircraft and international routes.”
Risk Profile:
Detail how criteria reflect specific hazards, using historical data or stakeholder input.
Example: “Severity criteria are based on passenger volume, with ‘catastrophic’ defined as loss of aircraft or multiple fatalities, reflecting our high-capacity fleet.”
Data Sources:
Note sources used to define criteria, such as incident reports, industry benchmarks (e.g., IATA safety reports), or regulatory guidance.
Example: “Likelihood levels are informed by 5 years of incident data and FAA safety alerts.”
Documentation Tip: Include a section titled “Customization Rationale” to explain tailoring, demonstrating compliance with FAA’s requirement for proportionality.
Example: A maintenance organization might document, “The risk matrix is tailored to Part 145 operations, with ‘major’ severity defined as repairs grounding aircraft for over 48 hours, based on historical maintenance delays.”
Document the step-by-step process for using the risk matrix to assess risks, ensuring it is repeatable and systematic as required by 14 CFR Part 5.55.
Process Steps:
Hazard Identification: Describe how hazards are identified (e.g., safety reports, audits, staff input).
Risk Assessment: Explain how severity and likelihood are determined for each hazard.
Risk Categorization: Detail how the matrix assigns risk levels (e.g., “Plot severity and likelihood on the 5x5 grid”).
Action Assignment: Specify actions for each risk level (e.g., “High risk triggers immediate investigation”).
Documentation: Note how assessments are recorded (e.g., in a safety database).
Roles and Responsibilities:
Identify who conducts assessments (e.g., safety officers, department heads).
Example: “Pilots report hazards, and the Safety Manager assigns risk levels using the matrix.”
Tools:
Mention tools used, such as spreadsheets, SMS software (e.g., SMS Pro), or paper forms.
Example: “Risk assessments are logged in a Google Sheet with the risk matrix template.”
Documentation Tip: Use a numbered list or flowchart to present the process clearly, labeled as “Risk Assessment Workflow.”
Example: An airport’s documentation might state, “1. Ground staff report hazards (e.g., runway debris). 2. The Safety Manager evaluates severity (e.g., moderate for potential tire damage) and likelihood (e.g., occasional based on traffic). 3. The risk is plotted as ‘medium’ on the 4x4 matrix, triggering mitigation within 7 days.”
Tool: Use SKYbrary’s Safety Management Toolkit (skybrary.aero) for process templates.
The FAA emphasizes stakeholder involvement in risk management (AC 120-92B). Document how staff and other parties contribute to the risk matrix process.
Stakeholder Roles:
Internal: Pilots, maintenance crews, dispatchers, and managers provide input on hazards and criteria.
External: Regulators (e.g., FAA FSDO), contractors, or partner airlines may inform interfaces.
Example: “Pilots reviewed likelihood criteria to ensure alignment with regional weather risks.”
Engagement Methods:
Describe workshops, interviews, or surveys used to gather input.
Example: “A safety workshop on [date] included ground staff to map taxiway collision risks.”
Feedback Integration:
Note how feedback refines the process.
Example: “Maintenance staff feedback simplified severity definitions for clarity.”
Documentation Tip: Include a section titled “Stakeholder Engagement” with dates and outcomes of involvement.
Example: A cargo operator might document, “On [date], dispatchers and loadmasters validated ‘load shift’ hazard criteria, ensuring the matrix reflects operational realities.”
Action Item: Join LinkedIn groups like "Aviation Safety Management Systems," “Aviation Safety Professionals” or follow #AviationSafety on X for peer insights on stakeholder engagement.
Document how the risk matrix process was tested and validated to ensure it produces consistent, compliant results, aligning with FAA Order 8040.4C.
Testing Methods:
Historical Scenarios: Apply the matrix to past incidents (e.g., a runway incursion) to verify accuracy.
Hypothetical Scenarios: Test emerging risks (e.g., drone encounters).
Example: “A ‘bird strike’ scenario was assessed as ‘major severity, occasional likelihood,’ confirming appropriate categorization.”
Consistency Checks:
Have multiple staff assess the same scenario to ensure uniform results.
Example: “Three safety officers rated a ‘fuel leak’ scenario, achieving consistent ‘high risk’ ratings.”
Validation:
Cross-reference with FAA standards (e.g., Part 5, AC 120-92B).
Example: “The process was validated against the SMSVP Standard on [date].”
Documentation Tip: Include a “Testing and Validation” section with scenario results and validation dates.
Example: An airline might document, “The matrix was tested on [date] using a ‘taxiway collision’ scenario, rated as ‘medium risk,’ aligning with FAA’s systematic assessment requirements.”
Resource: Use the FAA’s SMS Assurance Guide for validation templates.
The FAA requires continuous improvement of SMS processes (14 CFR Part 5.97). Document how the risk matrix process is maintained and updated.
Review Schedule:
Specify frequency (e.g., annually or after operational changes).
Example: “The risk matrix process is reviewed yearly or after fleet expansions.”
Update Triggers:
Note events prompting updates, such as new hazards (e.g., cybersecurity risks) or regulatory changes.
Example: “Likelihood criteria were updated in [year] to reflect increased drone activity.”
Feedback Loop:
Describe how staff or audit findings inform updates.
Example: “Audit findings on [date] prompted clearer severity definitions.”
Documentation Tip: Include a “Maintenance and Updates” section with a review schedule and update log.
Example: A maintenance organization might document, “The risk matrix process is updated annually, with criteria revised in [year] based on FAA feedback during an SMSVP audit.”
Incorporate the risk matrix process documentation into the SMS manual or safety policy, ensuring accessibility and auditability (14 CFR Part 5.53).
Integration:
Place the documentation in a dedicated section (e.g., “Safety Risk Management”).
Example: “The risk matrix process is documented in Chapter 3 of the SMS Manual.”
Accessibility:
Store in a shared drive, intranet, or SMS software.
Example: “The process is accessible via the company’s SMS Pro portal.”
Version Control:
Use versioning (e.g., “Version 1.0, [Date]”) to track revisions.
Example: “Version 2.0, updated [Date], reflects new likelihood criteria.”
Documentation Tip: Include a table of contents in the SMS manual to locate the risk matrix process easily.
Example: An airport might state, “The risk matrix process, Version 1.1, is stored in the SMS Manual on the intranet, accessible to all safety staff.”
Document the process with FAA audits in mind, ensuring readiness for oversight or SMSVP evaluations.
Audit Preparation:
Compile supporting evidence, such as testing results, stakeholder feedback, and update logs.
Example: “Audit records include scenario tests from [date] and stakeholder meeting notes.”
Key FAA Focus Areas:
Clarity of severity and likelihood criteria.
Evidence of customization and stakeholder involvement.
Consistency and repeatability of the process.
Documentation accessibility.
Mock Audit:
Conduct an internal review using the FAA’s SMS Gap Analysis Tool.
Example: “A mock audit on [date] confirmed compliance with Part 5.55.”
Documentation Tip: Include an “Audit Readiness” section summarizing preparation steps.
Example: A flight school might document, “The risk matrix process is audit-ready, with documentation stored in the SMS Manual and validated against the SMSVP Standard.”
Document how staff are trained to use the risk matrix process, supporting FAA’s emphasis on safety promotion (14 CFR Part 5.91).
Training Plan:
Describe training methods (e.g., workshops, online modules).
Example: “New staff complete a 1-hour risk matrix training session.”
Content:
Cover matrix structure, assessment steps, and documentation requirements.
Example: “Training includes a ‘runway excursion’ scenario to practice risk assessment.”
Frequency:
Specify initial and refresher training schedules.
Example: “Refresher training occurs annually.”
Documentation Tip: Include a “Training” section with training schedules and content outlines.
Example: An airline might document, “Pilots and dispatchers are trained on the risk matrix process during onboarding, with annual refreshers using real-world scenarios.”
Documenting the risk matrix process can be challenging for new safety managers. Here’s how to address common issues:
Challenge: Uncertainty about FAA requirements.
Solution: Study 14 CFR Part 5, AC 120-92B, and the SMSVP Guide, and consult FAA’s SMS website for FAQs.
Challenge: Overcomplicating documentation.
Solution: Use templates from FAA or IATA and focus on clarity and brevity.
Challenge: Limited resources for small operators.
Solution: Leverage free FAA tools (e.g., SMS Gap Analysis Tool) and prioritize high-impact risks.
Challenge: Staff resistance to new processes.
Solution: Engage stakeholders early and highlight benefits (e.g., improved safety, audit readiness).
Documenting the risk matrix process for FAA compliance is a critical task for aviation safety managers, particularly newcomers. By
This process ensures regulatory adherence, enhances safety, and provides a repeatable framework for risk management.
Start by reviewing your current risk matrix and downloading FAA’s SMS Implementation Guide. Engage your team to ensure accuracy and use resources from SKYbrary, IATA, or NBAA to streamline documentation.
With these steps, you’ll produce a risk matrix process that meets FAA standards, withstands audits, and strengthens your organization’s safety culture in the dynamic aviation industry.