karman line aerospace sf345

Karman Line AerospaceAerospace Safety Program

Initial Release v1.0April 15, 2016

Director of Safety, KLACopyright, KLA and Aerospace PR

Approved for Public Disclosure

Calvin Baker, Leanne Ellis, Harrison Erb,Ryan Ierardi, John Key, Amador Salinas, Jay Thakor

TABLE OF CONTENTS

April 15, 2016 Initial Release v1.0 Page 1 of 34

1. STATEMENT OF POLICY Karman Line Aerospace (KLA) intends to provide a safe working environment for its employees. KLA shall provide the safest possible suborbital space science missions and orbital launches of small satellites to its customers. KLA shall respect and enhance the safety culture of its operating locations, currently established at Spaceport America and Spaceport Camden. In pursuing these goals, KLA shall maintain an active aerospace safety program and all company personnel are expected to participate in the program and take an active role in the identification, reduction, and elimination of hazards. This safety program shall be non-punitive. This document constitutes the KLA’s Safety Program.

Signed: ________________________, Chief Executive Officer, Karman Line Aerospace

2. ORGANIZATION


Figure 1 - Organizational Chart

2.1 Chain of CommandThe position of Director of Safety will be a full time position reporting directly to the Vice President of Safety. The Vice President of Safety will report directly to the President of Karman Line Aerospace. The President will report to the Chief Executive Officer of Karman Line Aerospace.

The Vice President of Maintenance and the Vice President of Operations will appoint an additional duty Aerospace Safety Manager to report directly to them. They will also appoint additional duty Aerospace Safety Specialists at each operating location under their supervision, which is currently inclusive of Spaceport Camden and Spaceport America.

2.2 Facility Safety Hierarchy

Figure 2 - Facility Safety Hierarchy

This hierarchy will be used at each location (i.e. New Mexico and Georgia) and lists out the facility safety hierarchy. The Flight Operations Specialist, Ground Operations Specialist, and Maintenance Specialist all report directly to the Director of Safety.


2.3 Launch Operations Hierarchy

Figure 3 - Launch Operations Hierarchy

3. AUTHORITY & RESPONSIBILITY

3.1 Chief Executive OfficerThe Chief Executive Officer (CEO) is responsible for creating, communicating, and implementing the organization's vision, mission, and direction. The CEO shall lead the


development and implementation of the overall organization's strategy. The CEO shall act as a liaison between the Board and the management of the company. The CEO is in charge of setting the culture, attitude, and values of the company, and is responsible for the overall success or failure of the company.

3.2 Chief Financial OfficerThe Chief Financial Officer (CFO) is accountable for the administrative, financial, and risk management operations of the company, to include the development of a financial and operational strategy, metrics tied to that strategy, and the ongoing development and monitoring of control systems designed to preserve company assets and report accurate financial results.

3.3 PresidentThe President is responsible for creating, communicating, and implementing the organization's vision, mission, and overall direction. The President shall oversee the complete operation of an organization in accordance with the direction established in the strategic plans.

3.4 Chief Technology OfficerThe Chief Technology Officer (CTO) shall focus on the scientific and technological issues or advances within the organization. The CTO shall lead the Information Technology (IT) department and is solely in-charge of the technological aspects of the company. The CTO must have basic business knowledge to succeed in this role.

3.5 Vice President of SafetyThe VP of Safety is responsible for overseeing the success of the entire program. The Vice President of Safety has the authority to develop and/or approve any modifications to the program.

3.6 Vice President of MaintenanceThe VP of Maintenance shall provide special insight to the Director of Safety in hazards and in regards to the maintenance facilities, personal protection equipment for maintenance staff members, and machinery protocol. The VP of Maintenance shall serve under the safety committee when needed.

3.7 Vice President of OperationsThe VP of Operations is responsible for overseeing the success of day-to-day operations in the flight operations, ground operations, and Maintenance departments. VP of Operations shall be a certified safety professional.


3.8 Director of SafetyThe Director of Safety shall develop, implement, and maintain the safety program. The Director of Safety has the responsibility of conducting inspections on any safety-related event. The Director of Safety shall be responsible for submitting the annual safety budget and distribution of all safety materials. Director of Safety will also lead internal investigations. The investigation team will include any personnel the Director of Safety deems necessary for the investigation. The Director of Safety may delegate responsibilities to subordinates.

4. REPORTINGThe KLA safety program is non-punitive. The Safety Department cannot punish an employee for reporting a hazard, incident, or accident. Reporting is required for all accidents and incidents. Reporting hazards is not required, but is recommended.

The Director of Safety will be responsible for the reporting program.

4.1 AnonymityReporting of a hazard, incident, or accident is anonymous; however, an employee does have the option to forgo anonymity by explicitly stating so in one of three ways. Explicitly stating this can take the form of (1) verbal via an over-the-phone report, (2) in writing via a written report, or (3) digitally via website or smartphone application report submission.

All reports, anonymous or otherwise, will be sanitized of identifiable information one week after submission.

4.1.1 NotificationsAll report resolutions, anonymous or otherwise, will be posted on the safety bulletin boards and physical newsletters. For non-anonymous reports, employee will personally be notified of resolution.

4.2 How to ReportReporting can be conducted in-person, online, via telephone, or via an in-house smartphone application.

Be prepared to provide the following information:● A detailed description of the event or situation● Location of the event or situation● Time of day when event or situation took place● Proposed solution (optional)● Mission phase(s) affected (if applicable)

○ Launch Processing


○ Launch○ Ascent○ On-Orbit Operations○ Entry○ Landing○ Post Mission

● Severity of the event○ High○ Medium○ Low

● Likelihood of event happening again○ High○ Medium○ Low

● Every report will end with the question: ○ What will cause the next accident?

4.3 Methods of Reporting

4.3.1 In-PersonProceed to the safety office and submit a report in-person.

4.3.2. TelephonePlace a call to the Safety Office and request accident/incident or hazard reporting. Hazard reporting will allow you to fill out a hazard report verbally. Requesting accident/incident report will take you to a person who can immediately begin reacting to the accident/incident.

4.3.3 OnlineVisit the employee website and fill out your report online.

4.3.4 Smartphone ApplicationThe company smartphone application will allow employees to submit reports via their smartphone in the form of (1) text, (2) audio, (3) video, or (4) pictures. This will allow for greater participation in the safety program due to how easy it will be to submit accident, incident, or hazard reports.

5. DISTRIBUTION OF SAFETY INFORMATIONSafety information will be distributed in several different methods to employees based on the level of importance. Safety information will be split up into four levels of importance: (1) critical, (2) routine, (3) future reference, and (4) useless. Each level of importance correlates with when, how, or if the information will be distributed.


5.1 Types of Information

5.1.1 CriticalCritical information is defined as needing to be immediately sent out to employees to avoid an accident. The designation of critical information shall not be taken lightly because all information sent to your employees includes some of your reputation. Critical information must be distributed and acknowledged if it is to be effective.

Distribution: Critical information will be sent out via the following methods: (1) flight crew briefings before a flight and (2) smartphone application push notification1.

Verification: One push notification has been acknowledged system will receive kickback data showing a successful delivery of the info. Flight crews will have to sign out after flight briefing confirming that they have received the critical information.

5.1.2 RoutineRoutine information is defined as needing to be available to employees, but not requiring acknowledgement. Non-critical safety information shall be placed in areas where employees can read the information at his or her leisure.

Distribution: Routine information will be sent out via the following methods: (1) smartphone application update, (2) blog post, (3) physical newsletter, (4) digital newsletter, and (5) bulletin board (separate from OSHA bulletin board).

5.1.3 Future ReferenceFuture reference information is defined as being cataloged for future use. This information can be used to identify trends, which may elevate the information to non-critical or critical.

Distribution: Future reference information will not be distributed.

5.1.4 UselessUseless information is that which cannot benefit the safety department or any other department. All information defined as useless shall immediately be disposed.

Distribution: Useless information will not be distributed.

5.2 Methods of DistributionThere will be six methods of distribution: (1) flight crew briefings, (2) smartphone application, (3) bulletin boards, (4) blog posts, (5) physical newsletters, and (6) email

1 A push notification is one that alerts the smartphone owner. For the notification to go away, the smartphone owner must acknowledge the notification.


newsletters. Methods 3-6 all provide the same information in different mediums, thus provide redundancy.

5.2.1 Flight Crew BriefingsAll critical pieces of information will be covered in mandatory pre-flight briefings attended by all taking part in the mission to include crew and spaceflight participants.

5.2.2 Smartphone ApplicationThe KLA smartphone application will be used to distribute safety information. The smartphone application will include both critical and routine safety information. Critical information will be sent to the user via push notification. Routine safety information will populate the safety section of the application.

5.2.3 Bulletin BoardA safety bulletin board in common areas will include routine safety information only. This bulletin board will not include critical safety information. The bulletin board should be monitored; any non-safety information should be removed immediately.

5.2.4 BlogAll routine information will be posted to Karmin Line Safety Blog. The blog will be updated as new safety information becomes available. Blog followers can subscribe for email updates on new posts.

5.2.5 NewsletterPhysical newsletters will include routine safety information. Physical newsletters will be one-page, two-sided flyers in the lunch area of the facility. Newsletters will be eye catching and engaging to encourage continual readership.

5.2.6 EmailDigital newsletters will contain the same information as the physical newsletters, but be sent to employees via email.

5.3 File Management SystemAll files shall be stored using a cloud storage service, such as Google Drive, Dropbox, or Microsoft SharePoint.

6. SAFETY COMMITTEESBoth the New Mexico and Georgia locations shall have their own safety committees. Each committee shall have no fewer than five and no more than seven members at any given time. The chairman of each committee shall be a line manager, appointed by the


appropriate Director of Operations on a yearly rotation. The remaining members shall be randomly selected and will be a cross-section of employees from both the managerial and operational levels of all departments. This allows the committee to include viewpoints from all across the company.

6.1 Committee PurposeThe purpose of the committee is to achieve group consensus on the various safety issues facing our company. To that end, the committee will review any incident reports that have transpired between the current and previous meeting, as well as review the current safety program and any issues the members bring up.

6.2 MeetingsThe committee will hold quarterly meetings. The committee chairman is required to start and end all meetings on time. To the best of the committee’s ability, all agenda items shall be addressed or resolved during the meeting; unfinished business automatically carries over to the next meeting. Minutes will be kept of all meetings to include the resolution and action taken. Minutes will be recorded by the Director of Safety.

6.3 Role of the ChairmanThe chairman shall be capable of facilitating the meeting without dominating it, and ensure that all voices are heard equally, both keeping dominant personalities in check and ensuring more reserved ones get the chance to speak up. They must be able to accomplish all items on the agenda every meeting, and will be the final word on when a subject is closed. Once the committee comes to a resolution on an issue, the committee must take appropriate actions.

7. SAFETY INSPECTIONSThere will be three types of inspections: (1) formal inspections, (2) informal inspections, and (3) spot inspections. Informal and spot inspections can lessen the magnitude of formal inspections. All safety inspections will be conducted in accordance with 14 CFR 400 et seq. If Karman Line Aerospace chooses to go above and beyond, holding inspections to the ISO 9001 & 14001 level is advised.

7.1 Inspection PreparationInspections shall be led by the Director of Safety responsible for the inspected facility. Before all inspections fair warning will be given along with an inspection checklist. All remarks regarding the facility, positive or negative, will be noted in the final inspection report. Following the review, an informal walkthrough of the facility will be conducted to


answer any possible questions, as well as to validate the reports findings. No irrelevant or unproven data will be discussed during this walkthrough.

7.2 Formal InspectionsA formal inspection is a high-detail verification looking at all aspects or details of a department. Formal inspections will be announced to the department being inspected. A checklist shall be created and delivered to the department prior to the inspection. Formal inspections will take place once a year. The Safety Committee does have the ability to change the frequency of formal inspections; however, the frequency of formal inspections shall not be less than once per year. All discrepancies must be corrected immediately.

7.2.1 FrequencyFormal inspections will take place on a three-year rotation. Year one will include the Director of Safety in charge of the location, Georgia or New Mexico, completing a safety inspection at his or her own facility. Year two will include the two Directors inspecting each other’s facility (e.g. Director of Safety for Georgia Operations inspects New Mexico site, the Director of Safety for New Mexico Operations inspects the Georgia site). This will avoid complacency by having “fresh eyes” that are familiar with space activities to review each site. Year three will include a third-party inspector for each site. This will avoid complacency by having “fresh eyes” that are unfamiliar with space activities and will scrutinize all aspects.

7.3 Informal InspectionsAn informal inspection is a low-detail verification looking at the big picture or large problem areas. Informal inspections will be announced to the department being inspected. A checklist shall be created and delivered to the department prior to the inspection. Informal inspections will take place on a monthly basis. All discrepancies must be corrected immediately.

7.4 Spot InspectionsA spot inspection will be initiated in response to a specific salient or believed issue and will allow for immediate addressal of that issue. It is a quick method to check up on individual areas of concern. A report is only necessary in the case of a violation.

7.5 Report StructureA report shall be manufactured from each inspection. The report shall include detailed descriptions of potential hazards and proposed solutions, as well as areas of success. All data will be presented without bias. If further investigation is needed, the inspector


may take any involved parties on a walking tour of the relevant facilities. No irrelevant issues shall be brought up during this time.

7.6 Report SubmissionThe inspection report shall be submitted to the Safety Committee and the Director of Safety. Report must be submitted in a timely manner.

7.7 Report Review/EvaluationThe inspection report shall be reviewed two weeks after the inspection. Discrepancies must be corrected or steps must be taken to correct the discrepancies. The Director of Safety will be responsible for reporting the results of the inspection to both the VP of Safety and the Safety Committees. This report will include an in-depth review of the findings of the inspection, as well as any recommendations for resolving any validated hazards.

7.8 Post-InspectionOne of the most important aspects of the inspection review is the emphasis on normalization of deviance. The reiteration of an invariable safety culture is imperative to consistent risk mitigation within KLA. When hazards are pointed out, not resolved, and continually stay unresolved, it becomes a norm for workers. Make a point to address and resolve as many hazards as possible and bring these hazards or incidents up to line managers. The facility line managers will be responsible for monitoring the corrections, and must report any discrepancies to the Director of Safety. Any recurring hazards will require recurring follow-up inspections until they have been properly corrected.

8. SAFETY TRAININGThree kinds of training that will take place: (1) initial training, (2) specialized training, and (3) recurrent training. These three forms of training cover safety culture indoctrination of new employees, training needed for select employees to complete specific job duties, and training to keep all employees up-to-date on proper procedures. All training responsibilities and records will be kept by the Director of Safety.

8.1 Training RecordsAll training records will be kept until employee termination (i.e. voluntary resignation, retirement, etc.).


8.2 Initial TrainingInitial training is performed on all new employees, no matter his or her position. This will ensure a baseline of safety knowledge. Initial training shall take place after a tour of the facility and the specific area where the employee will work. Initial training will include, but not be limited to: (1) location of the Safety Office, (2) contact information for the Safety Office, (3) reporting procedures for hazards/incidents/accidents, and (4) emergency procedures. All initial training procedures or policies listed below are subject to recurrent training, section 8.4.

8.3 Specialized TrainingSpecialized training shall be completed as-needed based on the employee’s job description. Employees will not receive training for a job he or she was not hired to perform. For example, a secretary will not need training on the proper operation of a forklift. All specialized training procedures or policies listed below are subject to recurrent training, section 8.4.

8.3.1 Hazardous Material (HAZMAT) TrainingHAZMAT training is both initial and annual recurrent and must be Federal Aviation Administration (FAA) approved. All personnel involved in handling materials of hazard must receive this type of training. Operators who do not transport hazardous materials, must provide minimum training so that the personnel can recognize those materials. Personnel must also be trained in compliance with the RCRA (Resource Conservation and Recovery Act). This act deals with proper management of hazardous waste (storing, handling, and disposing of solid, liquid, and gaseous wastes), and must be trained to regulation standards2.

8.3.2 Fire Suppression TrainingThe quantity and amount of time required will be set by the director of safety. Those selected to be trained in this will be required to do so with the local fire department. Personnel may also volunteer to be trained in fire suppression.

8.3.3 CPR / First Aid / First ResponderWill follow National CPR Foundation to train and authorize personnel in CPR. The director of safety must be CPR certified. First responder training shall be based on the guidelines provided by the National Training and Education Division for first responders, the director of safety must oversee the success of this training and must also participate. All Personnel will be trained in basic first aid, this will be provided the director of safety.

2 Hazardous Waste training: Title 40 CFR part 262.34


8.3.4 Space Flight Participant TrainingAll spaceflight participants must be trained on emergency procedures in response but not limited to cabin de-pressurization, smoke, emergency egress, and fire in accordance with 14 CFR 460.51.

8.3.5 Attitude/Mentality TrainingAll employees shall be trained to avoid hazardous attitudes in the workplace, including anti-authority, impulsivity, invulnerability, machoism and resignation.

8.4 Recurrent TrainingRecurrent training is the event of presenting initial or specialized training to an employee again. If new procedures or policies have been implemented, recurrent training should be scheduled as soon as possible for the employees it affects. The scope of the recurrent training will be dependent on the task being trained and will be dictated by applicable regulations or at the discretion of the Director of Safety.

8.5 Training EffectivenessAt the end of each training session or certification course, there will be either a written or oral examination that is proctored and signed off by a qualified individual. This will validate that the employee or contractor has learned and knows how to execute the required training that was provided to them.

9. SAFETY AWARDSAwards will be earned by individuals going above and beyond to create a safe environment within KLA. Four awards have been established: (1) Safety Achievement, (2) Aerospace Safety Manager of the Month, (3) Best Safety Evaluation, and (4) Best Resolution of a Hazardous Situation.

All safety awards shall be presented publicly by the Director of Safety. This is not only a right of the recipient, but also a benefit to the organization as a whole by publicly stating that a person is rewarded for going above and beyond one’s job description.

9.1 Safety AchievementCriteria: This award shall be earned by completing some form of advanced safety training activity, such as, but not limited to: (1) CPR Certification, (2) Fire Extinguisher Certification, and (3) First Aid Certification.

Award: This will be a framed award, signed by the Director of Safety, Vice President of Safety, Chief Executive Officer, and an affiliated safety manager.


9.2 Aerospace Safety Manager of the MonthCriteria: Award earned based on overall performance and safety activity. Recipient shall consistently incorporate and reinforce proper safety culture in all subordinate’s activities, along with his/her own.

Award: This will be a framed award, signed by the Director of Safety, VP of Safety, CEO, and an affiliated safety manager. Plaque put on display outside each affiliated safety manager’s office.

9.3 Best Safety EvaluationCriteria: This would be a division award and it would involve a very consistent, good evaluation every time one is conducted. Good safety culture shall be demonstrated through the division of people.

Award: This will be a framed award, signed by the Director of Safety, VP of Safety, CEO, and an affiliated safety manager. Presented to a group of employees in a certain division of the company.

9.4 Best Resolution of a Hazardous SituationCriteria: One must go above and beyond to correctly respond to an inherent hazardous situation. In addition, the recipient must not have caused the hazardous situation to occur.

Award: This will be a framed award, signed by the Director of Safety, VP of Safety, CEO, and an affiliated safety manager.

10. ACCIDENT INVESTIGATIONKLA will investigate and resolve all incidents to minimize the probability of future accidents.

10.1 Definitions

10.1.1 AccidentAn event shall be defined as an accident if one or more of the following situations occur: loss of (1) one or more people, (2) mission, (3) launch vehicle, (4) ground support equipment, and (5) other of the like.


10.1.2 IncidentAn event shall be defined as an incident if one or more of the following situations occur: near loss of or damage to (1) people, (2) mission, (3) launch vehicle , (4) ground support equipment, and (5) other of the like.

10.2 Delegated AuthorityIf the Director of Safety is gone, the Operations Safety Manager has authority.

If the Operations Safety Manager is gone, the Accident Preparedness Manager has authority.

If the Accident Preparedness Manager is gone, the Maintenance Specialist has authority.

10.3 Pre-Accident PlanThe Director of Safety will develop a pre-accident plan that will be reviewed, amended (if needed) and then approved by the VP of Safety. The pre-accident plan will outline and detail the coordinated effort by all emergency entities who must respond to an accessible launch/landing/suborbital/orbital space flight failure. The pre-accident plan will be neatly organized in individual binders, providing checklists and instructions for every step and issue that must be addressed through the first 24 hours of an accident and will be tailored to each individual’s role in the accident plan.

10.4 Pre-Accident Plan Training and ExercisesThe Director of Safety will lead a tabletop exercise annually, which will be supervised by the VP of Safety and include the entire accident response team. The tabletop exercise will work through the entire pre-accident plan and all coordinated procedures that would be used during an accident. The table top exercise will help identify procedures that need to be re-written and problem areas that may require more coordination. In the event that changes are made to the pre-accident plan, a tabletop exercise is to be performed on the portion that has been changed to show fluidity and prove that the changes have a positive impact on the pre-accident plan. The VP of Safety must approve amendments to the pre-accident plan.

Every three years, the VP of Safety will coordinate a full-scale exercise that will include all emergency response teams, the internal investigation team, accident response team, and personnel playing the role of government entities such as the National Transportation Safety Board (NTSB), the Federal Aviation Administration (FAA) and local entities. The teams will play out an accident scenario from the confirmation of an accident through what would occur during the first 24 hours.


10.5 Accident PlanIn the event that there is failed launch/landing/suborbital/orbital space flight, the Flight Director will notify the Director of Safety and the Director of Safety will notify the NTSB, FAA, and VP of Safety immediately. All pertinent information about the spacecraft, mission, payload, crew (if crewed vehicle), and mission control data will be secured and passed on to the NTSB and copies retained for the internal investigation.

Being the launch operator, Kamran Line Aerospace will apply for party status (refer to Appendix B for party status procedures). As mandated by the FAA AST, the launch operator is responsible for the investigation of their accidents. The NTSB is the ultimate authority for accident investigations.

Due to the nature of suborbital and orbital launches, missions controllers and operators at the spaceport mission control center are tracking the telemetry and performance data of the spacecraft and launching platforms. Therefore in the case of an accident controllers will be able to track/predict the debris field, accident locations, and be able to provide the Accident Response Team with an accurate location of where to respond.

10.6 Internal Investigation Team and Accident Response TeamThe internal investigation team and accident response team will be selected by the Director of Safety at each location. The Accident Response Team and Internal Investigation Team must be composed of qualified individuals with all necessary certifications, protective equipment, identification, and communication sources. This is to ensure that the response team will be granted access to the accident site by the National Transportation Safety Board (NTSB).

Table 1 - Accident Response PlanPhase # Phase Description Corresponding Actions

1 Accident has been confirmed by mission control

1. Flight director notifies director of safety, who then notifies the NTSB, FAA, and VP of safety

2. Emergency services dispatched to location3. Accident response team activated and dispatched

to site4. Key personnel responding to the accident are

replaced by step in personnel5. Crisis communications plan activated by both

launch operator and launch site operator6. Mission control begins data collection of pertinent

information7. Operations halted until further assessment of

range safety or in the case of an accident at the


launch site infrastructure will be evaluated repaired and verified to operate at 100%

2 Accident response team and emergency personnel arrive

1. Principal first responder duties (e.g. put out fires, treat the wounded, etc.)

2. Accident site is secured and preserved3. Emergency services arrive on scene 4. Accident response team arrives on scene5. Hazardous materials and fire suppression is

handled by fire services6. Crew is attended to by emergency medical

services personnel7. Mission control finalizes records of all mission data

including passenger data (if crewed)8. Data is passed on to response team and NTSB9. Status of crew identified10. Crew transported to emergency centers for

identification or treatment

3 NTSB arrives 1. Accident response team follows instructions of the NTSB and conduct internal investigation alongside NTSB

4 As information becomes available

1. Change social media logos to grayscale following a fatality

2. Identification of crew and condition3. Next of kin notification process begins

10.7 Next of KinKLA shall follow NTSB policies for next of kin notifications. In the event of an accident, next of kin shall be notified prior to the public and the media. Next of kin shall be provided all accommodations for travel, lodging, etc.

Refer to Appendix B for the NTSB’s “Information for Families, Friends and Survivors.”

10.8 NTSBThe NTSB will investigate all accidents as defined by Title 49 Part 830, see Appendix C.

11. SAFETY ANALYSISA moving average of three months and 12 months will be used to identify trends of incidents and accidents. A risk matrix will be used to classify the threat level and likelihood of hazards within the facility.


11.1 Moving AveragesMoving averages will be generated for incidents, accidents, and total incidents and accidents.

11.1.1 Three-Month Moving AverageThe three-month moving average will be used to identify near-term changes or effects of incidents/accidents. The three-month average will be calculated as such:

¿of eventst

he past t h reemont h s /exposuret

he past t h reemont hs=t h ree−mont haverage

Example:4 events/ 480hoursof exposure=0.083% events/hour=anaccident occurs every 120h ours

11.1.2 Twelve-Month Moving AverageThe 12-month average will be used to identify long-term changes or effect of incidents/accidents. The 12-month average will be calculated as such:

¿of eventst

he past 12mont h s /exposuret

he past 12mont hs=12−mont haverage

Example:14events /2080hoursof exposure=0.0067% events/hour=anaccide n t occurs every∼148hours

11.2 Tombstone SafetyIf an accident or incident occurs, the safety program must be reviewed to identify any needed changes to promote employee safety.

11.3 Risk MatrixA nine-cell risk matrix will be used to classify all risks within the spaceport. The simplicity of a nine-cell matrix will result in any risk deviation being easily identifiable; if the deviation results in higher risk, a change in procedures or immediate action should be taken. The risk matrix will be split up into three colors:

Table 2 - Risk Matrix Colors

Color Meaning

Monitor risk

Manage risk aggressively and consider procedures to avoid risk

Implement new procedure immediately to lessen risk


Table 3 - Risk Matrix

THREAT LEVEL

LIKELIHOOD

11.4 Hazard ResolutionProvide one or more of the following solutions for hazards. The solution types are listed from best to worst.

11.4.1 Engineering SolutionEngineering solutions eliminate the hazard entirely by designing the hazard out of the system. This is the best solution.

11.4.2 Control SolutionControl solutions include changing a procedure or placing a person near the hazard to lessen the exposure to the hazard.

11.4.3 Personnel SolutionPersonnel solutions include the addition of signage to warn personnel of a hazard.

11.4.4 Protective Equipment SolutionProtective equipment solutions include reducing the effects of the hazard by providing personal protective equipment (PPE). This is the worst solution.

11.5 Flight Data RecordersAll flight data recorder information will be downloaded following each suborbital and orbital flight. Any data that exceeds mission thresholds will be analyzed. The crew will


be interviewed to identify any off-nominal procedures that occurred. The remaining data will be used to identify whether or not any maintenance needs to be completed.

11.6 Safety Analysis ReportA monthly report will be generated with the results of the moving averages, risk matrices, hazard/incident/accident resolutions, and flight data recorder analysis. This report will be made available once a month to management and sent to the VP of Safety.

12. OCCUPATIONAL SAFETY AND HEALTH

12.1 Occupational Safety and Health Administration

12.1.1 CommunicationsThe Director of Safety must make an appointment to meet the local Occupational Safety and Health Administration (OSHA) inspector. This is important because each OSHA inspector interprets the safety regulations differently. By understanding how the OSHA inspector interprets the safety regulations, the Director of Safety can ensure optimal compliance.

12.1.2 OSHA RequestsAn organization has four hours to respond to a request by OSHA. Use all four hours to gather the relevant information. Only provide the specific information OSHA requests.

12.1.3 OSHA OffensesIf an OSHA offense is incurred, there is an option to abate the offense. Abating, or challenging, the offense often results in a lesser fine.

12.2 MaintenanceThe Director of Safety oversees efforts to include spacecraft maintenance in the safety program.

12.2.1 Maintenance SafetyIn addition to the OSHA program, there must be spacecraft maintenance safety program in order to maintain a safe, operable fleet. This is achieved through Quality Assurance (QA). The Director of Safety will appoint a QA inspector to assess discrepancies.


12.2.2 Maintenance AnalysisMethods of logging and analyzing equipment failures must be conducted. The Director of Safety will be responsible for understanding maintenance data collection.

12.2.3 Maintenance Shop SafetyAll OSHA standards are applicable and must be maintained in maintenance shops. Items to take into consideration include:

● Compressed Air Systems● Compressed Gas Storage● Flammable Storage● Solvents● Electrical Shops and Electrical Maintenance● Battery Maintenance● Aircraft Paint Shops

12.2.4 Maintenance InspectionsMaintenance technicians cannot perform required inspections on their own work; however they can and are encouraged to inspect each other's work for required inspections.

12.2.5 Maintenance Safety InspectionThere are two main parts of spacecraft maintenance that are examined under a safety inspection: the quality of work and how safe the work is done. The Director of Safety will be responsible for the inspection or delegate it to appropriate subordinates.

12.2.6 Spacecraft DiscrepanciesIf there is a discrepancy reported by a pilot or space flight participant (SFP), the pilot or SFP should report the discrepancy to maintenance. This will allow maintenance to properly diagnose and correct discrepancies.

Once the discrepancies have been addressed and resolved by the maintenance department, there shall be a feedback section in the report that includes a description for the pilot/SFP how the discrepancy was resolved.

12.2.7 Delayed or Deferred DiscrepanciesDelayed or deferred discrepancies are not advised, but are sometimes necessary. If a vehicle or piece of equipment cannot be fixed immediately (e.g. parts must be ordered, parts must be made, etc.), then a delayed or deferred discrepancy is acceptable.


12.3 Miscellaneous

12.3.3 Spacecraft Avionics Configuration ControlThere are many ways to configure an orbital or suborbital vehicle or rocket. Configuration must be tightly controlled as it is important to understand which hardware is needed for a given mission.

12.3.4 Tool ControlKLA will use a lockout / tagout (LOTO) system. This will keep track of every tool in the facility. Using the LOTO system will help maintenance to avoid leaving tools in spacecraft, thus avoiding any unneeded hazards. In addition, it will reduce acquisition costs from replacing lost tools.

12.3.5 Technical DataThere must be a system implemented that will address Airworthiness Directives and Service Bulletins posted by the various companies that contributed to the spacecraft. Gathering technical data from the actual usage of the spacecraft during its operation is very useful to see trending data. This can be kept through a flight data recorder, or a device that uses bandwidth/datalink to transmit current data to a file dump in order to process data.

For more information on flight data recorder information usage, please refer to section 11.5.

12.3.6 Flight Line SafetyKeeping your head on a swivel when operating on the flight line is the first line of defense to prevent accidents or incidents. Proper marshalling of spacecraft, chalking, fueling, engine start, and parking must have a minimum of two people attending each suborbital spacecraft and a minimum of 10 people for orbital spacecraft.

These minimums are put in place to mitigate ramp damage and collision avoidance with other spacecraft as well as vehicles and objects lying or parked on the ramp for other various ramp operations.

12.3.7 Hanger SafetyOne of the biggest causes of damage is the confinement and storage of spacecraft. There are also many different factors that need to be kept track of in hangars that can not only affect the safety of spacecraft/aircraft, but the safety of the workers.

12.3.7.1 Electrical SystemsCircuit breakers must be accessible to all employees. Denote all high voltage receptacles to reinforce the fact that if the employee is not careful, they can die from high voltage exposure.


12.3.7.2 Air Pressure SystemsThis is important to regulate. These pressure systems can be used for air tools, and the proper upkeep and maintenance of these systems is critical to worker safety. One or two large compressors can easily feed many hoses that allow mechanics to use air tools. All of hoses and compressors must have regular inspections.

12.3.7.3 Cords and LinesWorkers can trip on these cords and lines. Cords and lines must be in bright colors that are easy to see. For cords or lines that are not brightly colored, the area should have signs denoting the hazard.

12.3.7.4 Equipment RacksApplicable equipment should be stored on racks. If improperly stored, the equipment will become a hazard. When equipment falls, this may cause harm to the employees as well as the equipment.

12.3.7.5 Hangar WorkstandsHangar workstands are used by maintenance technicians to work on equipment or spacecraft. These must be as clean as possible and well-organized. This will help to avoid loss of parts.

12.3.7.6 HeatersIf flammable items are placed too close to heaters, they may catch on fire. Even though heaters are used to regulate temperature inside of hangar for the employees comfort, use with caution.

12.3.7.7 Fall ProtectionHand rails, hand guards, harnesses, and spotters must be present when working at heights above 10 ft.

12.3.7.8 Fire ProtectionFire extinguishers, fire blankets, and hoses must be able to be accessed under OSHA regulations. A built in fire extinguishment system is also required in the event of large fires.

12.3.7.9 Hangar Safety EquipmentFirst aid kits, deluge showers, and eyewash fountains must be installed in OSHA regulated and approved areas. These safety items must not be blocked in any way.

12.3.7.10 Hangar DoorDoor lasers are suggested for install on the main hangar doors. These can help mitigate door damage to spacecraft, automotive vehicles, personnel, or maintenance equipment.

All debris must be removed when closing the doors to avoid damage.


12.3.7.11 Hangar FloorThe hangar floor must remain clean to avoid accidents due to debris or spills. Make sure all tools and machines are stored properly. Any liquids or materials that pose as a hazard to the safety and operation of the workers must be swept or mopped up as much as possible in order to mitigate risk. Reflection tape or paint must be placed around areas where employees must be cautious, or not go into. This same principle applies to roads; the clearer markings present on the road, the more direction provided to people operating within the area and fewer accidents will happen.

12.4 ITARThe International Traffic in Arms Regulations (ITAR) will be observed as it pertains to safety.

13. ENVIRONMENTAL SAFETYKLA must abide by all policies and laws pertaining to the Environmental Protection Agency (EPA). The following section lists applicable policies and laws for environmental safety for KLA.

13.1 Applicable Policies and Laws● Clean Air Act● Clean Water Act● The Resource Conservation and Recovery Act● Superfund Amendment and Reauthorization Act● The National Environmental Policy Act● FAA Noise Regulations● OSHA Hazard Communications Act● Hazardous Waste Operations and Emergency Response Standard

Refer to Appendix B for more information on the policies and laws listed above.

13.2 Environmental Protection AgencyKLA must properly store, handle, and dispose of solid, liquid, and gaseous wastes. The EPA has a list of over 400 substances labeled as wastes through the Resource Conservation and Recovery Act (RCRA). In addition, unlisted wastes must follow the same regulations if they are:

● Ignitable● Corrosive● Reactive● Toxic

Refer to Appendix B for more information on the EPA and the RCRA.


13.2.1 Hazardous Waste ManagementManagement of the above hazardous wastes shall follow procedures such as:

● Survey● Controls● Reduction● Recovery and Reuse● Recycling● Treatment● Disposal

Refer to Appendix B for more information on Title 40 CFR part 265.

14. CONTRACTORSWhether it be a full time, part time, or contracted employee of the company, the actions of contractors speak on behalf of KLA as a whole. Safety precautions must be taken before employing a contractor.

14.1 Contractor Safety RecordA contractor’s safety record must be analyzed prior to employment. If the contractor does not provide a safety record, or the safety record is less than satisfactory, a new contractor should be considered.

Contracts should include a clause concerning the contractor’s safety record. If the contractor’s safety record falls below an agreed upon level, KLA has the option to find a new contractor.

14.2 Maintaining Safety Record with Respect to Contractors Contractor safety records shall be kept for five years following the end of the contract.

14.3 Contractor StandardsA contractor’s standards must be analyzed prior to employment. If the contractor does not meet KLA’s standards, then an agreement must be made between the contractor and KLA to bring the contractor’s standards up to those of KLA. The contract must be written to include a

Contracts should include a clause concerning the contractor’s standards. If the contractor’s standards fall below an agreed upon level, KLA has the option to find a new contractor.


14.4 Integration into Safety Program and CultureNew contractors and their employees must complete a safety culture integration course with KLA. Information presented should include, but not be limited to: (1) safety standards, (2) safety record, (3) safety procedures, (4) hangar safety, and (5) flight line safety.

15. FISCAL RESPONSIBILITY14 CFR chapter III part 440KLA will work alongside the FAA to determine its maximum probable loss (MPL) for each launch as part of the policy review associated with receiving a launching license. Once the MPL is determined, KLA will receive a corresponding insurance quote covering the disclosed amount including a buffer should anything exceed the determined MPL.

The insurance policy will cover:● Spacecraft/payload assembly, integration and testing during the manufacturing

phase● Pre-launch operations such as storage at launch facility, transit to launch pad,

and contingency exposures● Production facility damages● Launch facility damages● Launching operations covering the launch and payload● On-orbit coverage for operational life of spacecraft, or to cover manufactures

obligations to client in case of malfunctions/non performance● Third party liabilities during launch/orbital operations/landing● Assist other contractors associated with the launch who will also posses their

own insurance

Accidents and incidents will always have financial repercussions. It is an inherent factor that must be accepted and accounted for.

15.1 Direct CostsSome of the direct costs associated with an accident would be damage to physical assets, along with any repair costs to buildings, land or materialistic objects etc.

15.2 Indirect CostsSome of the indirect costs associated with an accident would be long term medical bills, lawsuits, time of downed craft (loss of profit), and damage to brand.


16. DISASTER RESPONSE PLAN

16.1 SecurityBoth spaceports will be required to have a small contingent security force present at all times; the number and responsibilities of this force will be determined by the facility’s Director of Safety.

16.2 WeatherWeather will be heavily monitored in the days leading up to a launch. If deemed hazardous to personnel or equipment, measures will be taken to evacuate all personnel from the facility.

16.3 Personnel ThreatsAny threats to personnel will be immediately reported to local authorities. If applicable, facility security personnel will attempt to contain the threat and evacuate all other personnel.

16.4 State of Emergency/Evacuation PlanIn the event that a large-scale evacuation is required, the resident launch facility will be responsible for the safety of all personnel and civilians present. If anyone is found to be lacking in shelter, the facility, in coordination with local law enforcement, will lead them to nearby shelters.

16.5 Mental Stability Annual personnel evaluations will take place to ensure mental stability of employees.

16.6 Terrorism Preparedness The Director of Safety will assess all sites, missions, and procedures for potential vulnerabilities and security risks that may be exploited by terrorists or criminals. Recognizing the fact that not all terrorist threats can be prevented, the Disaster Preparedness Plan covers necessary actions initiated in response to terrorist threats and attacks.

16.7 Employee NotificationFor more information, please refer to critical information distribution in section 5.1.1


16.8 Public RelationsKLA will have a Crisis Communications Plan as required by the FAA. In the event of a disaster, Karman Line will initiate media relations to address the situation at hand as soon as facts begin coming to light. Karman Line will only report on information pertinent to its operations and those involved. Refer to Section 10.7 Next of Kin for notification procedures.

17. GROUND OPERATIONS

17.1 Driving Regulations Rigorous driving rules and regulations are in place to ensure safety and create a easier systematic flow of traffic.

17.1.1 Speed LimitThe following speed limits will be implemented within the grounds of the spaceport.

● Parking area○ 5 mph within 25 feet of a spacecraft○ Normally 15 mph

● Vehicle parking area○ 5 mph

● Taxiways and Runways○ Maximum of 15 mph○ Speeds may decrease if environmental changes occur

● Suborbital vehicle tow speed○ 10 mph

● Orbital vehicle crawler speed○ 1 mph

17.1.2 ParkingAll vehicles are to be parked in designated areas only, with all possible safety precautions taken to ensure they do not interfere with equipment.

17.1.3 Vehicle LimitationsIt is to the discretion of the facility how many vehicles are allowed in the operating area at any given time. Anyone who wishes to utilize a vehicle must file an application to do so, and, once approved, must be given appropriate identification, which is to be displayed at all times.

17.1.4 Vehicle FlowUnless necessary, all vehicles will be kept on the perimeter of the operating area. Should a vehicle require closer access, it will primarily be limited to designated


roadways. Any vehicle required to bypass these standards will be equipped with appropriate identification measures.


18. REVIEW AND REVISIONThis spaceport safety program will be maintained by the Director of Safety. This safety program will be reviewed once a year at a minimum. Immediate changes will take place on an as-needed basis (e.g. after an accident, incident, or hazard is identified). For a revision of this safety program to go into effect, the CEO must sign below.

Table XX - Revision History

Version Date Changes / Notes CEO Signature

1.0 Initial Release


APPENDIX A - ACRONYMSAST FAA Office of Commercial Space Transportation

CEO Chief Executive Officer

CFO Chief Financial Officer

CPR Cardiopulmonary Resuscitation

CTO Chief Technology Officer

FAA Federal Aviation Administration

GA Georgia

HAZMAT Hazardous Materials

ISO International Standards Organization

IT Information Technology

ITAR International Traffic in Arms Regulations

KLA Karman Line Aerospace

LOTO Lockout and Tagout

NASA National Aeronautics and Science Administration

NM New Mexico

NTSB National Transportation Safety Board

MPH Miles Per Hour

MPL Maximum Probable Loss

OSHA Occupational Safety and Health Administration

PPE Personal Protective Equipment

RCRA Resource Conservation and Recovery Act

SFP Space Flight Participant

QA Quality Assurance

VP Vice President


APPENDIX B - EXTERNAL INFORMATIONTitle Link

Guidelines on the Hazard Analysis of Commercial Space

https://www.faa.gov/about/office_org/headquarters_offices/ast/licenses_permits/media/hazard.pdf

Procedures for Requesting NTSB Party Status

http://www.ecfr.gov/cgi-bin/text-idx?SID=8414ba0223fa510486342a721c56e17e&mc=true&node=pt49.7.831&rgn=div5

SFP Training http://www.ecfr.gov/cgi-bin/text-idx?rgn=div5&node=14:4.0.2.9.24#se14.4.460_151

Title 40 CFR part 265 http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title40/40cfr265_main_02.tpl

Information for Families, Friends and Survivors

https://app.ntsb.gov/tda/family.html

Airway Facilities Environmental and Safety Compliance Program

http://www.faa.gov/documentLibrary/media/Order/1050.17.pdf

Clean Water Act https://www.epa.gov/laws-regulations/summary-clean-air-act

The Resource Conservation and Recovery Act

https://www.epa.gov/laws-regulations/summary-resource-conservation-and-recovery-act

Superfund Amendment and Reauthorization Act

https://www.epa.gov/superfund/superfund-amendments-and-reauthorization-act-sara

The National Environmental Policy Act

https://www.epa.gov/laws-regulations/summary-national-environmental-policy-act

FAA Noise Regulations http://www.faa.gov/airports/environmental/airport_noise/

OSHA Hazard Communications Act

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099

Hazardous Waste Operations and Emergency Response Standard

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765

14 CFR 417.407 Hazard Control Implementation

http://www.ecfr.gov/cgi-bin/text-idx?node=pt14.4.417#se14.4.417_1407


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