Federal Aviation Administration SL-1 Federal Aviation Administration Concepts and Implementation for the Pilot Project Participant Part II - Implementation.

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Presentation transcript:

Federal Aviation Administration SL-1 Federal Aviation Administration Concepts and Implementation for the Pilot Project Participant Part II - Implementation MSMS Team Member FAA Aircraft Certification Service

Federal Aviation Administration SL-2 Agenda  Related SMS Activities  SMS Fundamentals  SMS Pilot Project Implementation  Guidance & Tools  Preliminary Gap Analysis meeting  Working together during the Pilot Project  Questions

Federal Aviation Administration SL-3 Pilot Project Objectives  Provide recommendations and analysis to support of development of FAA regulations and associated policies  Validate or refine the D&M SMS Framework  Validate or refine guidance materials  Propose the appropriate applicability and scalability of SMS  Refine assessment and oversight policies

Federal Aviation Administration SL-4 MSMS Organizational Structure AIR-150 MSMS Team Lead Communication Lead MSMS Pilot Project Lead Data Collection & Analysis Focal Share point Focal FAA Participant Management Teams (PMT) PMT Includes: MSMS Team Member as FAA PMT Lead Manufacturing representatives (Field) Engineering representatives (Field) Pilot Project GAP Analysis & Framework Team ONE Team FAA Participant Management Teams (PMT) FAA Participant Management Teams (PMT) FAA Participant Management Teams (PMT) FAA Participant Management Teams (PMT)

Federal Aviation Administration SL-5 ? ?? MSMS Team Lead Pilot Project Lead (PPL) Participant Organization Point of Contact (POC) Participant Management Team Lead (PMTL) Participant Management Team Members (PMT) Other Resources ASI ASE ASI ASE MANUF $$ E NG HR QA Participant Executive / Corporate

Federal Aviation Administration SL-6 Roles & Responsibilities  D&M SMS Pilot Project Lead  Serves as the point of contact for the D&M Pilot Project  Coordinates and manages the FAA Participant Management Teams  Provides final acceptance to exit a Level  Pilot Project Lead:

Federal Aviation Administration SL-7 Roles & Responsibilities (Continued)  FAA Participant Management Team (PMT)  Consists of members of the MSMS Team & FAA field personnel from MIDOs and ACOs  Participate in meetings / telecons and site visits  Participate in procedure and process assessments  Provide status/updates to the oversight organization throughout the Pilot Project  Company PMT: MSMS Team: Kurt Krumlauf (lead) and Steve Slagle LAACO: Cheyenne DelCarmen and Joe Costa Phoenix MIDO: Don Henchar

Federal Aviation Administration SL-8 Roles & Responsibilities (Continued)  FAA PMT Lead  Leads the Participant Management Team  Provides direction, guidance and assistance to PMT and participant  Coordinates formal interaction with the participant, such as meetings, telecons, output deliverables, reviews of exit criteria  PMT Lead for Company: Kurt Krumlauf (562)

Federal Aviation Administration SL-9 Roles & Responsibilities (Continued) Participant Point of Contact (POC)  Company SMS Project Manager (or similar)  Serve as POC for SMS activities  Serve as primary contact to the FAA

Federal Aviation Administration SL-10  SMS will be implemented in 4 progressive Levels  This approach enables an organization to establish the basic building blocks (levels 1 and 2) before implementing the more complex activities of SRM and SA (levels 3 and 4)  Development and implementation of the SMS is more manageable AIR SMS Implementation Strategy

Federal Aviation Administration SL-11  Level 1 focuses on an agreement with the FAA for a completed gap analysis and development of an implementation plan.  Levels 2 & 3 will be subject to an assessment process by the FAA’s PMT  Level 4 is for the organization to verify the performance and effectiveness of their SMS management practices and operational processes AIR SMS Implementation Strategy

Federal Aviation Administration SL-12 Defining the Scope of Your Project  For an SMS to be fully effective it must be implemented organization-wide  However, for the pilot project you may want to scale down the project  Consider the company’s products, processes, and departments that you would like to include in the pilot project  The scope should be of appropriate magnitude with the goal of exiting Level 1 within six months.

Federal Aviation Administration SL-13 2 Reactive Processes 3 Proactive Processes 4 Continuous Improvement 1 Planning & Organization Implementation Levels

Federal Aviation Administration SL-14 1 Planning & Organization

Federal Aviation Administration SL-15 Planning & Organization Level 1 Output Documents  Management Commitment definition (Letter)  Organization Safety Policy  Comprehensive SMS Implementation Plan for entire organization through level 4  SMS Training Plan for all employees 1

Federal Aviation Administration SL-16 Planning & Organization Level 1 Exit Criteria  Evidence of Accountable executive’s commitment to implement SMS, define safety policy and convey safety expectations and objectives to its employees  Evidence of adequate resources to implement SMS  Designate a management representative responsible for SMS development  Define safety-related positions for those who will participate in SMS development and implementation  Obtain agreement with FAA on your Detailed Gap Analysis and Implementation Plan  Identify safety competencies and develop a training plan  Complete a exit level one meeting with the FAA 1

Federal Aviation Administration SL-17 Level 2 Output Documents Reactive Processes 1.Objective evidence that SRM processes and procedures have been applied to at least one existing hazard and the mitigation process has been initiated 2.Updated comprehensive SMS implementation plan for all elements to take the participant through Level 4 3.Updated SMS training plan for all employees 2

Federal Aviation Administration SL-18 Level 2 Exit Criteria 2 Reactive Processes 1.Processes & procedures documented for operating the SMS to the level of reactive analysis, assessment and mitigating actions 2.Develop documentation relevant to SMS implementation plan and SRM components (reactive processes) 3.Initiate and document voluntary non-punitive employee reporting and feedback program 4.Conduct SMS training for staff directly involved in the SMS process to at least the level necessary for the SMS reactive processes

Federal Aviation Administration SL-19 Level 2 Exit Criteria (Continued) Reactive Processes 5.Apply SRM processes and procedures to at least one known (existing) hazard and initiate the mitigation process to control/mitigate the risk associated with the hazard 6.Update the Detailed Gap Analysis on the entire organization (pending scope) for all elements of the SMS Framework 7.Update the comprehensive SMS Implementation Plan for all elements to take the organization through Level 4 2

Federal Aviation Administration SL-20 Level 3 Output Documents 3 Proactive Processes 1. Objective evidence that SRM processes and procedures have been applied to all Element 2.1 (1) Hazard Identification and Analysis items 2. Objective evidence that SRM processes and procedures have been applied to at least one existing hazard and that the mitigation process has been initiated 3. Updated comprehensive SMS implementation plan for all elements 4. Updated SMS Training Plan for all employees

Federal Aviation Administration SL-21 Proactive Processes  Objective evidence that Hazard Identification and Analysis has been accomplished  Objective evidence that SRM processes and procedures have been applied to at least one existing hazard and mitigation process has been initiated  Updated comprehensive SMS implementation plan for all elements  Updated SMS training plan for all employees 3 Level 3 Exit Criteria (Continued)

Federal Aviation Administration SL-22 Proactive Processes 6.Objective evidence of compliance with Element 4.1 Competencies and Training 7.All applicable SMS processes and procedures have been applied to at least one existing hazard and mitigation process have been initiated 8.Complete SMS Training for Staff directly involved in SMS process to the level of accomplishing all SMS processes 9.Complete employee training commensurate with this level of implementation maturity 3 Level 3 Exit Criteria (Continued)

Federal Aviation Administration SL-23 Proactive Processes  Objective evidence of compliance with Competencies & Training  All applicable SRM processes and procedures have been applied to at least one existing hazard and that the mitigation process has been initiated  Complete SMS training for the staff directly involved in the SMS process to the level of accomplishing all SMS processes  Complete employee training commensurate with this level of implementation 3 Level 3 Exit Criteria (Continued)

Federal Aviation Administration SL-24 Level 4 Expectations 4 Continuous Improvements 1.The complete SA process, continuous monitoring & other SRM processes are functioning 2.Verify the performance and effectiveness of the SMS management practices and operational processes

Federal Aviation Administration SL-25 Agenda  Introductions  Related SMS Activities  SMS Fundamentals  SMS Pilot Project Implementation  Guidance & Tools  Preliminary Gap Analysis meeting  Working together during the Pilot Project  Questions

Federal Aviation Administration SL-26 Guidance and Tools  D&M SMS Pilot Project Guide, referred to as “The Guide”  Developmental Guidance (DG) for D&M SMS Framework  Tools  Gap Analysis Tool  Assessment Tool  Implementation Planning Tool  AIR SMS Website (SharePoint)

Federal Aviation Administration SL-27 D&M SMS Pilot Project Guide  SMS Background and Introduction  Roles, Responsibilities and Relationships  Implementation Processes  Pilot project process for implementation of level 1  Pilot project process for implementation of level 2 & 3  FAA Assessment of the SMS levels  D&M SMS Framework  Information on SRM & SA integration  System Description and Hazard Identification  Definitions and Acronyms

Federal Aviation Administration SL-28 System Description  Assists an organization to:  Define its system and identifying hazards  Establish the scope and boundaries of the company to which SMS applies  Appendix D of “The Guide”  Currently it provides a summary of a system description  A more comprehensive system description is under development and will be included  Data and information received from the Pilot will be used to improve “The Guide”

Federal Aviation Administration SL-29 Developmental Guidance (DG) for D&M SMS Framework Purpose  Provides assistance to an organization in developing their SMS using the D&M SMS Framework  Clarifies the intent and explains the expectations in the D&M SMS Framework

Federal Aviation Administration SL-30 Developmental Guidance (Continued) Overview  Provide examples and ways an organization may choose to develop its SMS  Formatted to follow the Framework in “The Guide”  Comparable to an Advisory Circular (imbeds Framework expectations and guidance)  Focuses on the areas that may not be self- explanatory to the participant  Designed to be a living document

Federal Aviation Administration SL-31 Developmental Guidance (Continued)

Federal Aviation Administration SL-32 Gap Analysis Tool Purpose  Assists participants in documenting their gaps and status toward meeting the D&M SMS expectations  Provides a mechanism to learn more about the expectations  Provides a basis for a participant’s Implementation Plan Gap tool

Federal Aviation Administration SL-33 Gap Analysis Tool (Continued) Structure  Excel Spreadsheet with multiple tabs  Combines Preliminary and Detailed Gap Analysis tools in one file  Follows the structure of the D&M SMS Framework  Provides step-by-step instructions on how to use  Provides an Executive Summary  Automatically populates system segment ratings  Records Lessons Learned and comments for each Element and Sub-Element Gap tool

Federal Aviation Administration SL-34 Assessment Tool Structure  Assessment tab is within the Gap tool  Assessment tab will be used by PMT to assess policies and procedures  Tracks and documents the PMT's assessment of an organization's SMS  Documents an organization's evidence for achieving specified ratings for each D&M SMS Framework Expectation Gap tool

Federal Aviation Administration SL-35 Assessment Tool (Continued) Structure  Provides a single repository for PMT assessment outputs  Provides a Lessons Learned mechanism to collect feedback on the assessment process Gap tool

Federal Aviation Administration SL-36 Implementation Plan Tool Structure  Implementation plan tab is in the Gap tool  Identifies tasks and activities that are needed in order to close the gaps  Identifies the anticipated timeframe and point of contacts for the planned tasks and activities  Provide a high-level view of the timeline  Provides a narrative that describes how the organization intends to close all expectation gaps and achieve a fully functioning SMS. Gap tool

Federal Aviation Administration SL-37 AIR SMS Website (SharePoint)  Project information / data will be shared with the FAA on the MSMS SharePoint site  Each participant places deliverable documents in their own file location to share with FAA  Files are protected from viewing from other participants  Only selected FAA users will have access to view participant information  Data will not be kept beyond PMT assessment

Federal Aviation Administration SL-38 AIR SMS Website (SharePoint) Other Information to be shared with all participants  FAA SMS guidance documents  Gap analysis and assessment tools  Frequently Asked Question’s (FAQ’s) (non-proprietary)  Generic (non-proprietary) Lessons Learned information  Best Practices  Other SMS information

Federal Aviation Administration SL-39 Pilot Project - Data collection  Specific data, lessons learned, feedback will be collected to assist the MSMS team in the development of the SMS framework, policy and processes  Data and information will be general (i.e. procedures) and not technical (i.e. Design) in nature  If proprietary data is received, it will not be preserved or shared outside the MSMS team (data will be deleted / returned when FAA assessment is complete)  Data collection and analysis tools will be used

Federal Aviation Administration SL-40 Pilot Project - Data Collection  Specific data and information to be collected is being developed by MSMS team  Examples of data and information that will be requested are:  Lessons learned data and feedback on the SMS framework and pilot project processes  Number of days to complete gap analysis and to exit each level  Number of procedures and processes (new and existing)  Types and number of hazards identified  SMS processes and procedures that are also part of quality system

Federal Aviation Administration SL-41 Protection of Participant Information  The FAA Recognizes the importance of your participation in the pilot project and protection of data  FAA will exercise due diligence to not share data outside FAA  FAA will limit the types of data it retains  Limit data within the FAA  Please note:  We may share de-identified information  SMS information that is not specifically protected under Part 193 and may be subject to FOIA

Federal Aviation Administration SL-42 Agenda  Introductions  Related SMS Activities  SMS Fundamentals  SMS Pilot Project Implementation  AIR SMS Guidance & Tools  Preliminary Gap Analysis meeting  Working together during the Pilot Project  Questions

Federal Aviation Administration SL-43  Over the next two days we will work together on a Preliminary Gap Analysis  The Gap analysis tool will be used  The meeting will be facilitated by the POC and PMT Preliminary Gap Analysis

Federal Aviation Administration SL-44 Purpose of the preliminary gap analysis  Ensure the organization and FAA have a common understanding of the Gap Analysis Process and framework  Develop a common understanding of the D&M SMS Framework Expectations in the context of the organization and its operations  Preliminary Gap Analysis Tool assists the organization in conducting an initial high-level “first look” / “best guess” in assessing compliance with the SMS  Provides a starting place for the organization to conduct a detailed evaluation of the gaps

Federal Aviation Administration SL-45 Agenda  Introductions  Related SMS Activities  SMS Fundamentals  SMS Pilot Project Implementation  AIR SMS Guidance & Tools  Preliminary Gap Analysis meeting  Working together during the Pilot Project  Questions

Federal Aviation Administration SL-46 Working together during the Pilot Project  Pilot project should not interfere with the FAA’s Certificate Management (CM) responsibilities and Type Certification activities (e.g. ACSEP, DOIP, Designee Mgt)  Changes to a PAH’s FAA approved quality system will continue to be approved per Part 21 and FAA policy  The PMT will work with the participant for the duration of the pilot  Communication process is outlined in “The Guide”  Meetings / telecons are anticipated  Formal communications / decisions will be between the POC and PMTL  Etc.

Federal Aviation Administration SL-47  Deviations, clarifications (interpretation), improvements concerning the framework, guidance material, tools will be coordinated per instructions in “The Guide”  Feedback and lessons learned will be collected throughout the pilot project  Changes to pilot project guidance will be posted on SharePoint Working together during the Pilot Project (continued)

Federal Aviation Administration SL-48  After this meeting:  After the preliminary gap analysis the PMT will continue working with you  Within the next few weeks the POC and PMT Lead will schedule ongoing meetings / telecons The PMT will work closely together in initial discussions and activities  Participants should complete a Detailed Gap Analysis and have an Implementation Plan within six months  Schedule an Exit Level 1 validation meeting with PMT Working together during the Pilot Project (continued)

Federal Aviation Administration SL-49 What happens After the Pilot Project?  Company should continue developing their SMS to get to Level 4  Sustaining support by the FAA will continue per instructions in “The Guide”  Local FAA Offices will continue to work with company until SMS rule and FAA policy is finalized  POCs should continue working with the local FAA offices

Federal Aviation Administration SL-50