Directive No. 31
Revision 1

Safety Management Systems

Policy Objective:

To outline Civil Aviation's approach to the implementation of safety management systems (SMS) in aviation organizations.

Definitions:

An aviation organization is an entity that holds an operations certificate. An "operations certificate" means

1. an air operator certificate issued under Part VII
2. a private operator certificate issued under Part VI
3. a special flight operations certificate — balloons issued under Part VI
4. a flight training unit operator certificate issued under Part IV
5. an airport certificate issued under Part III
6. an air traffic services operations certificate issued under Part VIII
7. an approved maintenance organization certificate issued under Part V
8. an approved training organization certificate issued under Part IV
9. an approved manufacturer certificate issued under Chapter 561 of the Airworthiness Manual
10. an approved distributor certificate issued under Chapter 563 of the Airworthiness Manual
11. any other certificate or other Canadian aviation document issued in respect of an aeronautical service or the conduct of an aeronautical activity, that is expressly stated, in the Canadian Aviation Regulations, to be an operations certificate for the purposes Part I.

Background:

Flight 2005: A Civil Aviation Safety Framework for Canada identifies implementing SMS in aviation organizations as an evolving direction. The goals are to establish, through proactive management, more industry accountability and to instill a positive safety culture throughout the aviation industry. This evolving direction has turned into the most important initiative, not only in Civil Aviation, but in other Transport Canada regulatory areas as well.

As the implementation of SMS is still evolving, there was a requirement to update this CAD to establish a step-by-step process for the implementation phase. Mr. Don Sherritt has been delegated responsibility for SMS implementation throughout Civil Aviation, at this phase.

Initially, activity towards implementing SMS in aviation organizations centred on the task of educating the aviation industry. A briefing campaign was developed and sessions began in Toronto in November 2001. The campaign will come to a close by the end of fiscal year 2003/2004 when the majority of the targeted audience will have been reached.

As the implementation of SMS progressed, more formal consultations were conducted within Civil Aviation to develop a common regulatory framework for requiring SMS. A discussion group was charged by Civil Aviation Regulatory Committee to define what a safety management system is, what the common elements are and to provide a standardized interpretation of the generic requirements and definitions to use as a reference tool when developing any Civil Aviation SMS regulatory framework.

Policy Statement:

Civil Aviation is committed to and supports the development and implementation of safety management systems in aviation organizations by:

• Promoting SMS to the aviation industry
• Educating the aviation industry on the concepts and principles of SMS
• Consulting with all segments of the aviation industry on regulatory development
• Making the required changes to the Canadian Aviation Regulations (CARs)
• Overseeing the implementation of SMS within aviation organizations

Application:

This Civil Aviation Directive applies to all areas of the national Civil Aviation program.

Approach:

Civil Aviation's approach to the successful implementation of SMS within an aviation organization is a sequential four-step process within each functional area:

1. Education and promotion
2. Regulatory development
3. Implementation
4. Monitoring

1.  Education & Promotion:

The first step towards implementing SMS in a particular aviation sector is to educate industry stakeholders on SMS concepts through a series of briefing sessions. This includes giving presentations, on demand, in advance of that sector of the industry developing regulatory standards, to:

• Provide participants with an understanding of SMS concepts
• Brief industry on current or proposed SMS regulatory initiatives
• Solicit industry feedback and input on general SMS-related issues

The briefing campaign includes writing a series of articles on SMS in aviation safety letters, and continuing to promote SMS at the Canadian Aviation Safety Seminar and other venues. Once the regulatory framework is defined for a sector, concept-type briefings to individual certificate holders become the responsibility of the approval authority for that certificate holder. This means that general briefings to groups of the industry are still appropriate. However, briefings to individual certificate holders are at the request of the approving authority.

2.  Regulatory Development:

The second step is the development of regulatory or guidance material. All facets of the regulatory spectrum will be required to introduce Notices of Proposed Amendments (NPAs) regulating SMS, where a regulatory solution is appropriate, and/or provide guidance materials related to the development of SMS.

To ensure standardization, the following guidelines provide the framework for the development of a comprehensive SMS and the regulatory requirements for all areas of the Civil Aviation Program. It is the responsibility of the functional Director to interpret these requirements in a comprehensive, performance-based regulatory framework that is appropriate to the entity being regulated.

• The NPA shall include the standard definition of SMS:

  A safety management system is a systematic, explicit and comprehensive process for managing safety risks that integrates operations and technical systems with financial and human resource management, to achieve safe operation and compliance with the Canadian Aviation Regulations.

• A statement shall be made to the effect that:

  An aviation organization shall appoint an accountable executive to exercise overall control and act as the senior representative.

• A statement shall be made to the effect that:

  An aviation organization shall implement a safety management system to address all activities in accordance with the requirements set forth in the applicable parts of the regulations to ensure:
   

  1. A comprehensive corporate approach to safety
  2. A structure that is organized to effectively achieve its safety objectives
  3. Systems to assess and improve upon regulatory compliance

To ensure a standardized interpretation of the generic requirements listed above, the following shall be defined in performance-based, not prescriptive, terms and included when developing any Civil Aviation program standard relating to SMS.

1. A comprehensive corporate approach to safety, including:
    
   • A description of the organization's safety philosophy and policies
   • Instruction to staff to ensure that the stated policies are complied with
   • A means of planning, controlling and measuring performance
   • A means of managing hazards and risks
   • A means of reporting safety deficiencies, accidents and incidents
   • A means of containing system failure and preparing for emergencies
   • A means of investigating and analyzing occurrences and safety deficiencies, and for disseminating the lessons learned
   • A means of documenting processes, decisions and actions
      
2. A structure that is organized to effectively achieve its safety objectives, including:
    
   • Clear roles, responsibilities and accountabilities
   • A means of achieving coordination among organizational units
      
3. Systems to assess and improve upon regulatory compliance, including:
    
   • An evaluation/quality assurance system to ensure that the organization is in compliance with its policies and procedures and that those procedures remain effective
   • A system to confirm the effectiveness of any corrective actions taken

3.  Implementation:

The third step is overseeing the implementation of SMS. For the first wave of applicant's seeking Transport Canada approval, proposals will be processed through Headquarters. The knowledge gained during the initial approval process will be used to ensure a baseline interpretation and understanding of the performance requirements of acceptable safety management systems for use in the Regions. Functional areas will provide assistance and guidance regarding implementation of SMS in accordance with the regulatory requirements. Where an entity holds more than one certificate, the functional areas will work together to implement SMS.

4.  Monitoring:

At this point in the evolution of the implementation of SMS, the monitoring function will be the responsibility of individual functional areas, including the development of audit and inspection checklists.

Roles and Responsibilities:

Mr. Don Sherritt has been delegated by the Director General, Civil Aviation, responsibility for:

• Ensuring that a standardized approach is taken in the development of all Civil Aviation NPAs and guidance material related to SMS
• Providing guidance and advice in the development of regulatory frameworks and guidance materials relating to SMS
• Overseeing the implementation of SMS for large operators (airline and commuter categories) until sufficient guidance material and expertise is available to permit a decentralized approval process
• Scheduling regular meetings with functional directors to discuss progress on SMS implementation.

Functional Headquarters Directors, in coordination with Regional managers, are responsible for:

• Developing processes to support the implementation, procedures and practices of safety management systems within aviation organizations
• Providing techniques and tools to assess regulated entities' compliance with the provisions of safety management related regulations
• Reporting on the implementation of safety management systems in their functions to Don Sherritt.

The Director of System Safety is responsible for:

• Developing educational and promotional products to implement the briefing campaign
• Providing expertise and advice on the concepts of SMS, including philosophy and policy, to the aviation industry in advance of each sector developing regulatory standards
• Providing feedback to functional directors based on comments received during briefing sessions
• Providing concepts and principles briefings to employees, as required, until formal training is in place.

The Director of Learning Services is responsible for:

• Training Civil Aviation delegated officers on the mechanisms, audit checklists, tools and behavioral shift to ensure the regulatory requirements for SMS are being met by the aviation organizations they are inspecting.

Reporting:

Don Sherritt will report regularly to the Director General, Civil Aviation, on the implementation of safety management systems.

Further Information:

Don Sherritt
Director, Safety Management Systems Implementation
Telephone: (613) 952-4371
Facsimile: (613) 952-3298
E-mail: sherrid@tc.gc.ca

Merlin Preuss
Director General
Civil Aviation

Effective Date: December 9, 2002
Expiry Date: This directive will be revised as necessary as the implementation of SMS in aviation organizations evolves.