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FAA Part 5 Safety Policy Documentation Compliance

FAA Part 5 compliance for Safety Policy is largely the concern of new aviation SMS implementations for Part 121 operators. 

An aviation safety management system (SMS) is logically broken up into components and elements. This logical arrangement makes it easier for safety professionals to organize multiple subsystems within a large, inter-related system of elements. 

Safety Policy requirements are mainly fulfilled in the first phase of aviation SMS implementation and reviewed throughout the lifetime of the SMS.

Fortunately, the FAA’s Part 5 compliance guidelines on this SMS Pillar are very clear, and well outlined.

Safety Policy Greatly Affects Safety Culture and Safety Performance

"Safety Policy" is a major asset for building an effective safety culture in aviation safety management systems (SMS). An aviation SMS is a complex system of inter-related components and elements, and "Safety Policy" is one of the four SMS components (or pillars). For a quick review, the four SMS components are:

Plan Continuation Bias for the Layman

Several years ago NASA analyzed pilots' actions from 19 airline accidents from the viewpoint of "real-time" - i.e. during the flight and without hindsight bias. NASA found that the primary cause of the accidents was something they called "plan continuation bias."

For those of you who aren't unfamiliar with this concept, the premise is this: when you have "someplace to get to" you tend to ignore your environment.

Procedures at Heart of Aviation Safety Management

I currently just finished my freshman year at San Diego Christian College (SDCC) enrolled as an aviation major seeking a career in commercial aviation. SDCC employs a third party who they rent aircraft and employ instructors from.

If I have learned one thing from my first year of training, it is that policies and procedures are everything, that is, they are more important than most people readily consider during everyday flight operations.

What Is Documentation in Aviation SMS?

In November 2006, the International Civil Aviation Authority (ICAO) mandated that all member states implement formal aviation safety management systems (SMS). Each member state's civil aviation authority (CAA)  is responsible for providing oversight to ensure the operators required to implement the aviation SMS are in compliance.

Aviation SMS implementations need to be accounted for in 2 main ways. First, they need to be functioning, which means that SMS components are actively used by employees in the company. Second, the SMS' risk management activities need to be "documented."

Aviation Safety Managers Start with Something

When artists paint on a blank canvas, it gives them an opportunity to start with nothing and creatively turn it into something. This allows the artist to create a picture without having to change or modify a picture that already exists.

When implementing a Safety Management System (SMS), most Safety Managers do not have the luxury of starting with a blank canvas; instead, they must overlay the SMS on what could be a very challenging organizational culture, thereby creating

Org Charts Help to Define Accountabilities in Aviation SMS

Safety accountabilities in aviation safety management systems (SMS) implementations outline the bureaucratic structure of organizational safety expectations. Defining accountabilities has the ultimate goal of clearly communicating:

• What levels of responsibility are defined in the aviation SMS;
• Different levels of responsibility for each role; and
• Which roles have authority to make certain safety decisions.

The Concept of Management Commitment in Aviation SMS Programs

Management’s commitment in aviation safety management systems (SMS) is an extremely important part of the Four Pillar’s Safety Policy component.

Without a doubt, your SMS will fail without support from senior management.

Successful aviation SMS have exceptional safety cultures that rely significantly upon strong management commitment. The reasons management commitment is so critical for Safety Policy in the Four Pillars and aviation safety culture are:

SMS Implementation Guidance Still Needed

Over a dozen years (Nov 2006) have passed since ICAO issued its first mandate requiring member states to implement formal, structured aviation safety management systems (SMS).

Purpose of Non-Punitive Reporting Policies in Aviation SMS Programs

Dedicated, hard-working safety managers drive the setup of airline and airports' aviation safety management systems (SMS).

These safety managers are often left to decipher ambiguous requirements that are open to multiple interpretations. This comes into play especially when upper management wants to "pencil-whip" an aviation SMS and merely check the boxes.