federal aviation administration sl-1 federal aviation administration concepts and implementation for...
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Federal AviationAdministration
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Federal AviationAdministration
Concepts and Implementation for the Pilot Project Participant
Part II - Implementation
MSMS Team Member
FAA Aircraft Certification Service
Federal AviationAdministration
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Agenda
Related SMS ActivitiesSMS Fundamentals SMS Pilot Project Implementation Guidance & Tools Preliminary Gap Analysis meetingWorking together during the Pilot ProjectQuestions
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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
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MSMS Organizational Structure
AIR-150
MSMSTeam Lead
CommunicationLead
MSMSPilot Project
Lead Data Collection &Analysis Focal
Share point Focal
FAA ParticipantManagement Teams (PMT)
PMT Includes:• MSMS Team Member as FAA PMT Lead• Manufacturing representatives (Field)• Engineering representatives (Field)
Pilot Pilot ProjectProject
GAP Analysis & Framework
Team
ONETeam
FAA ParticipantManagement Teams (PMT)FAA Participant
Management Teams (PMT)FAA ParticipantManagement Teams (PMT)FAA Participant
Management Teams (PMT)
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MSMS Team Lead
Pilot Project Lead(PPL)
Participant OrganizationPoint of Contact
(POC)
Participant ManagementTeam Lead
(PMTL)
Participant ManagementTeam Members
(PMT)
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HRQA
ParticipantExecutive
/ Corporate
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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: [email protected]
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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
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Roles & Responsibilities (Continued)
FAA PMT LeadLeads the Participant Management TeamProvides 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 [email protected] (562) 627-5285
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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
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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
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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
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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.
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2ReactiveProcesses
3ProactiveProcesses
4ContinuousImprovement
1Planning &Organization
Implementation LevelsImplementation Levels
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D&M SMS Pilot Project Process (Level 1)
PMT Lead
2. Initial Pilot Project Participant and Local FAA Office Telecon
StartMSMS Team
1. Organize the FAA (Participant
Management Team)
Pilot Project Participant
5.a Company Conducts Detailed Gap Analysis Assessment prior to formal Gap meeting with PMT
Detailed Gap Analysis
Pilot Project Participant
5.b Present Detailed Gap Analysis with PMT
PMT
5.c Provide feedback to the Participant on
Detailed Gap Analysis Assessment
Not Ready
Pilot Project Participant
7.a Develop Implementation Plan, Safety Commitment approach & Training
Plan
Implementation Plan
Pilot Project Participant
7.b Present Implementation Plan,
Commitment, and Training Plan and Review with PMT
PMT
7.c Provide feedback to the Participant on
Imp. Plan, Commitment approach, and Training
Plan
6.Participant
ready to proceed with
Implementation Plan?
8.Participant
ready to proceed to Level
2?
Not Ready
Participant Proceeds with
Implementation (Level 2)
Yes
Yes
PMTL
4.c Conduct Preliminary Gap
Analysis
Pilot Project Participant
3.a Send Statement of Commitment and POC
Info to PMTL
Pilot Project Participant
3.b. Begin developing Initial System
Description prior to the preliminary gap
analysis
PMT
4.b Conduct Pilot Project Participant
Orientation
Orientation and Preliminary Gap Analysis Meeting
PMT & Participant
4.a Conduct PMT team meeting
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Planning &Organization
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Planning &Organization
Level 1 Output Level 1 Output DocumentsDocuments
Management Commitment definition (Letter)
Organization Safety Policy
Comprehensive SMS Implementation Plan for entire organization through level 4
SMS Training Plan for all employees
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Planning &OrganizationLevel 1 Exit CriteriaLevel 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
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Level 2 Output DocumentsLevel 2 Output Documents ReactiveProcesses
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
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Level 2 Exit CriteriaLevel 2 Exit Criteria2 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
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Level 2 Exit Criteria Level 2 Exit Criteria (Continued)(Continued)ReactiveProcesses
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
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Level 3 Output DocumentsLevel 3 Output Documents3 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
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ProactiveProcesses
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
3Level 3 Exit Criteria Level 3 Exit Criteria (Continued)(Continued)
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ProactiveProcesses
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
3Level 3 Exit Criteria Level 3 Exit Criteria (Continued)(Continued)
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ProactiveProcesses
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
3Level 3 Exit Criteria Level 3 Exit Criteria (Continued)(Continued)
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Level 4 ExpectationsLevel 4 Expectations 4 ContinuousImprovements
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
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Agenda
IntroductionsRelated SMS ActivitiesSMS FundamentalsSMS Pilot Project ImplementationGuidance & Tools Preliminary Gap Analysis meetingWorking together during the Pilot ProjectQuestions
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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)
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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
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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”
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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
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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
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Developmental Guidance (Continued)
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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 FAAFAA will limit the types of data it retains Limit data within the FAA
Please note: We may share de-identified informationSMS information that is not specifically
protected under Part 193 and may be subject to FOIA
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Agenda
IntroductionsRelated SMS ActivitiesSMS FundamentalsSMS Pilot Project ImplementationAIR SMS Guidance & ToolsPreliminary Gap Analysis meetingWorking together during the Pilot ProjectQuestions
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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
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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
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Agenda
IntroductionsRelated SMS ActivitiesSMS FundamentalsSMS Pilot Project ImplementationAIR SMS Guidance & ToolsPreliminary Gap Analysis meetingWorking together during the Pilot ProjectQuestions
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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.
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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)
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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)
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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
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