Proposed guidelines for preparing a safety management system

We asked for feedback on our draft guidance for preparing a safety management system (SMS). The guidance would be a multipart Advisory Circular (AC) applying to Parts 143, 171, 172, 173, 175 and Subpart 139.H of the Civil Aviation Safety Regulations 1998 (CASR). The consultation has now closed, and a summary of the feedback is provided below.

About this consultation
Originally, separate ACs on SMS were provided for each Part. While an SMS must be tailored to suit each situation, the basic components of an SMS (hazard identification; safety risk assessment and mitigation, etc.) are identical across aviation.

The similarity suggests a single source of information would be beneficial. Consistent guidance would aid consistent application, and a single document would be easier to keep up to date.

Accordingly, we developed a multi-part AC in consultation with Airservices Australia - the primary authorisation holder across all the applicable Parts. However, changing the SMS guidance would also affect other industry participants, and we released the draft for broader input via the CASA Consultation Hub.

We received two responses to the consultation: one respondent involved in producing aeronautical information and the other in the design of instrument flight procedures. Of the two, one consented to having their response made public.

Summary of feedback
A respondent pointed out that the AC's definition for 'hazard' was more suited to aircraft operations than the target audience of the AC. The respondent said the definition, whilst aligned with Annex 19 (Safety Management) to the Convention on International Civil Aviation, only describes potential to cause or contribute to an aircraft accident or aircraft incident. Whereas in their situation a hazard was more likely a condition potentially leading to or causing a reduction in data/database quality. The respondent recommended CASA considers alternatives to the definition and suggested the three hazard definitions in the Aerospace Industries Association (AIA) NAS9927 - Safety management system practices for design and manufacturing.

A respondent recommended the AC should include reference to 'AIA NAS9927' and 'AIA/AIAB/AIAC/ASD/GAMA SM-0001' as alternative and helpful industry standards for implementing and executing SMS by design and manufacturing organisations.

A respondent said it was unclear why the AC emphasised 'Internal safety investigation' with regard to Part 175 certificate holders. The respondent recommended the AC provides more detail about this emphasis.

A respondent identified that emergency preparedness and response was not relevant for a data service provider (DSP). The respondent recommended that the AC should acknowledge that emergency preparedness and response for some of the AC's audience may simply involve 'commitment to support aircraft operators experiencing emergency situations'.

A respondent said the AC should explain the differences between occupational safety, health and environment (OSHE) and aviation safety, and the role of Integrated Management System (IMS) which combines different management systems such as Quality, Safety, and OHSE. The respondent was of the view that the risk assessment for aviation SMS should be separate from any other risk assessments in an organisation.

Response to the feedback
Regarding the recommendation that the definition of 'hazard' should accommodate operations that are not specifically aircraft operations-centric: We believe that the highest order purpose of SMS in aviation is the safety for aircraft operations and that the term should ultimately focus at that level. Accordingly, the final AC will retain the Annex 19-based definition for 'hazard'.

Nevertheless, the final AC will include a subsection under Section 8.1 (Hazard identification) identifying that there are hazards beyond those that directly cause or contribute to an aircraft incident or accident, and that hazards may also exist in the broader aviation system or process.

Regarding the recommendation to include Aerospace Industries Association (AIA) standards: While appreciating the recommendation, we decided not to include those standards in this AC. We note AIA standards, particularly NAS9927, aim to assist organisations with compliance requirements for the United States of America. As the AC's intention is to encourage practices consistent with ICAO standards and recommended practices and existing Australian standards and guidance, we wish to avoid any references that may cause variation, however slight.

Regarding the questions about why 'Internal safety investigation' is particularly important to Part 175 certificate holders (the 3rd bullet on page 16): We do not consider those bullet points as implying that 'Internal safety investigation' is particularly important for Part 175 organisations. On the contrary, the paragraph and the bullet points simply identify SMS components uniquely required under Parts 172 (air traffic service providers) and 175 (aeronautical information service providers) of CASR but also recommend other organisations voluntarily include those components in their SMS.

Concerning the comment that some organisations - like data service providers - do not have a self-directed role in emergency response scenarios: We appreciate the recommendation. The final AC will include a small change in section 5.5 of the AC identifying that an ERP is scalable according to the functions of an organisation.

Regarding the recommendation the AC should include information about the difference between Occupational safety, health and environment (OSHE) versus aviation safety: the final AC will include a section explaining the difference.

CASA has finalised and published Multi-Part AC 139.H-06, AC 143-01, AC 171-06, AC 172-06, AC 173-07 and AC 175-01 - Version 1.0 - Guidelines for preparing a safety management system.

We thank the respondents for their comments and recommendations.