CAP 712 and SMS
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CAP 712 and SMS
Does anybody know if the UK CAA will re-issue the CAP 712 (Safety Management Systems for Commercial Air Transport Operations)?
I know that ICAO has revised the Safety Management Manual (Doc 9859) this year.
Regards
I know that ICAO has revised the Safety Management Manual (Doc 9859) this year.
Regards
I don’t know, but I suspect that the CAA will not renew the document.
Their regulatory trend appears to be an alignment with EASA (to be good Europeans) which requires fitting in with ICAO and EASA requirements. Thus all that CAA might do is issue SMS guidance materials (other than in EASA’s EU-OPS), which could be country/culture specific - Human Factors Aspects of Safety Management Systems – from the other SMS thread.
There is an interestingly titled view from EASA in a Draft (NPA) EU-OPS GM OR.OPS.100.GEN(d) Operator responsibilities - DEVELOPMENT OF STANDARD OPERATING PROCEDURES (SOP), pages 36-48.
Their regulatory trend appears to be an alignment with EASA (to be good Europeans) which requires fitting in with ICAO and EASA requirements. Thus all that CAA might do is issue SMS guidance materials (other than in EASA’s EU-OPS), which could be country/culture specific - Human Factors Aspects of Safety Management Systems – from the other SMS thread.
There is an interestingly titled view from EASA in a Draft (NPA) EU-OPS GM OR.OPS.100.GEN(d) Operator responsibilities - DEVELOPMENT OF STANDARD OPERATING PROCEDURES (SOP), pages 36-48.
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CAP 712 was withdrawn some time ago. It was quite a confusing document & development of SMS has moved on.
If you search around the UK CAA website there is/was a document entitled SMS - Guidance to Operators, which last time I checked was at Version 2 October 2008. I think this replaced CAP712.
Also available is CAP 726 Auditing SMS. This is a ccontains a checklist based on the CAA SMS roadshows conducted in Autumn of 2008, which I have used and then reproduced in an audit report. It's quite a good tool for identifying initial gap analysis.
If you search around the UK CAA website there is/was a document entitled SMS - Guidance to Operators, which last time I checked was at Version 2 October 2008. I think this replaced CAP712.
Also available is CAP 726 Auditing SMS. This is a ccontains a checklist based on the CAA SMS roadshows conducted in Autumn of 2008, which I have used and then reproduced in an audit report. It's quite a good tool for identifying initial gap analysis.
I believe the link to the EASA NPA regarding Organisation requirements, Guidance for development of SOPs, should perhaps be:
GM OR.OPS.100.GEN(d) Operator responsibilities DEVELOPMENT OF STANDARD OPERATING PROCEDURES (SOP) Pages 36-49.
By the way, this guidance is fairly closely aligned with the upcoming new ISO standard on Risk Management, ISO 31000, which will probably be published next month, along with a new and harmonised ISO Guide 73 for the general risk terminology.
GM OR.OPS.100.GEN(d) Operator responsibilities DEVELOPMENT OF STANDARD OPERATING PROCEDURES (SOP) Pages 36-49.
By the way, this guidance is fairly closely aligned with the upcoming new ISO standard on Risk Management, ISO 31000, which will probably be published next month, along with a new and harmonised ISO Guide 73 for the general risk terminology.
Ghostdancer
Is there an open link to CAP 726 Auditing SMS. I am a Safety Officer at a large US corporate operator starting a SMS program as part of IS-BAO certification.
GF
Is there an open link to CAP 726 Auditing SMS. I am a Safety Officer at a large US corporate operator starting a SMS program as part of IS-BAO certification.
GF
CAP 726 literally poses many questions, but gives few answers, ICAO SMM provides a lot of answers, but I am not sure they are absolutely clear about the questions.
My view is that much of what is being said and written about SMS is not that easy to translate into real world, day to day actions.
Perhaps the SMS Concept text from 2006 in the JAA Draft NPA-OPS-66A, which was never published, provides some ideas of what an SMS could be. (I have not found it anywhere on the Internet, so the text is enclosed below.)
Basically what it says is that a Safety Management System is a Quality Management System + a (Safety) Risk Management System, and that many of the elements are common, but addresses different issues. It also points to actions on 3 levels, probably inspired by the system description in Reason's model of organisational accidents (organisation, workplace and person).
My view is that much of what is being said and written about SMS is not that easy to translate into real world, day to day actions.
Perhaps the SMS Concept text from 2006 in the JAA Draft NPA-OPS-66A, which was never published, provides some ideas of what an SMS could be. (I have not found it anywhere on the Internet, so the text is enclosed below.)
Basically what it says is that a Safety Management System is a Quality Management System + a (Safety) Risk Management System, and that many of the elements are common, but addresses different issues. It also points to actions on 3 levels, probably inspired by the system description in Reason's model of organisational accidents (organisation, workplace and person).
"SMS Concept
Safety Management can be seen as the operator’s systematic implementation of Risk management in the planning, control and supervision of all relevant processes to ensure safe operations.
Risk Management should be associated with all safety-related processes from decisions made by senior management to those made in the cockpit. It should be applied to main, support and production processes and it should be an integral part of the safety culture.
The requirement for a Safety Management System replaces and goes beyond the present requirement for an accident prevention and flight safety programme.
Risk Management
Risk is often defined in terms of a combination of the consequences of an event and their likelihood. Risk Management is directed towards realizing potential opportunities whilst managing adverse effects.
A Risk Management process is the systematic application of the operator’s policies, procedures and practices to: establishing context, identifying hazards, analysing, evaluating, and treating risk, monitoring the effect of actions taken and reviewing the process.
A Risk Management process includes standard management elements, such as:
top level commitment, establishment of policies and goals, provision of adequate resources - both organisational and fiscal, allocation of responsibilities and fostering a positive safety culture.
Risk Management is applied to establish a solid basis for planning the operations or activities and for taking decisions. Risk Management enables the operator to achieve pro-active rather than re-active management. This is achieved by collecting and analysing available information to identify hazards and impose risk controls when planning for operations rather than dealing with them after operations have commenced and things have gone wrong.
Risk Management should also be used for channelling experience back into revised planning when required. It is also a process that should be employed to evaluate the safety effect of changes applied to an organisation.
It is not possible to eliminate all risk from an activity, only to minimise it. In the management process, risks need to be assessed and treated to the extent possible to obtain a risk level which is acceptable. To determine the acceptable risk level is, in principle the responsibility of the management, and will be influenced by factors external to the company. Laws, regulations, ethics and the society in general influences acceptable risk, as well as factors such as insurance premiums and passenger’s perception are major influences on acceptable risk.
Balancing the safety benefits of risk control against feasibility and cost to implement, can lead to other criteria, such as the principle of As Low As Reasonably Practical (ALARP) instead of quantitative risk acceptance criteria.
As part of Risk Management, there is a need to address the improbable event of an accident. The Emergency response plan may be seen as the operator’s preparation to reduce further consequences once an accident or incident has happened.
Establishment of a Safety Management System
Safety critical processes need to be determined. Operators who have implemented an ISO 9000:2000 based Quality Management System should already have the processes defined, and need only to apply the risk management process to the PDCA cycle for the management of these processes.
A SMS may be considered to be a 3 level system consisting of: the management level; the department level; and the personnel level:
Management level
The commitment to implement the SMS comes from the ‘Accountable Manager’, who is also responsible for establishing policies and goals and deciding the organisation and allocation of responsibilities.
The senior management is responsible for ensuring that a safety culture is inculcated throughout the company. This will gradually be achieved through ensuring well informed staff, the encouragement for reporting of occurrences and safety concerns, the ability of the organisation to learn from experience and fair and just treatment of employees,.
Although the scope of JAR-OPS limits these requirements to Flight operations, there is an obvious need to interface with other SMS’ within the company. An interface document could show how this will be achieved with parts of the organisation such as maintenance, sales and marketing, as well as contractors and customers where applicable. It should be made clear how all interact as they influence each other in the respect of safety.
Department level
All departmental processes and activities in flight operations, training and ground operations should be evaluated to establish their direct influence on safety. If these processes could influence safety, they should be the subject of a risk assessment, as part of the overall departmental Risk Management system. This applies in particular to the development of procedures, routines and working practices.
A suitable risk analysis tool should be developed, that is adapted to the size and complexity of the tasks to be analysed.
The single most important element of the risk management process is hazard identification.
As it is not humanly possible to foresee all relevant hazards in the initial planning stage, it is of the utmost importance to ensure that actual experiences are fed back to those responsible for the procedure for evaluation and analysis. Properly executed, this will form new input to the risk analysis and the result might lead to consequential adjustments to the procedure, equipment or training requirements in a continuous improvement process. There are numerous sources for this type of information (see e.g. the ICAO Safety Management Manual).
Occurrences and other experience should be investigated and analysed in sufficient depth to determine root causes in order to establish if preventive measures may be implemented, not just to prevent recurrence, but also prevent other occurrences from the same root cause.
Experience is an essential part of risk management and should provide a basis for decisions to improve procedures, training or equipment, as well providing safety information to staff.
Personnel level/performance of tasks
Application of risk management should ensure that safety critical activities are only conducted in accordance with established procedures, by personnel possessing sufficient competence and utilising adequate equipment for the job.
The presence of a positive company safety culture should encourage personnel to adhere to established procedures and provide an open reporting mentality. Feedback from front line personnel is of utmost importance. This could take the form of occurrence reporting as well as reporting of safety concerns and other relevant experiences from normal operations. There are numerous tools available to collect experience (see e.g. the ICAO Safety Management Manual).
Personnel should be given tools and training to aid in situational awareness and decision making by observing, evaluating and taking proper actions to ensure safety during the performance of their tasks.
Terminology
There are significant differences in the terminology used with respect to SMS, partly because there is no international standard for SMS available.
It is important to establish a common terminology standard by clearly defining all relevant terms used in the operator’s own SMS."
Safety Management can be seen as the operator’s systematic implementation of Risk management in the planning, control and supervision of all relevant processes to ensure safe operations.
Risk Management should be associated with all safety-related processes from decisions made by senior management to those made in the cockpit. It should be applied to main, support and production processes and it should be an integral part of the safety culture.
The requirement for a Safety Management System replaces and goes beyond the present requirement for an accident prevention and flight safety programme.
Risk Management
Risk is often defined in terms of a combination of the consequences of an event and their likelihood. Risk Management is directed towards realizing potential opportunities whilst managing adverse effects.
A Risk Management process is the systematic application of the operator’s policies, procedures and practices to: establishing context, identifying hazards, analysing, evaluating, and treating risk, monitoring the effect of actions taken and reviewing the process.
A Risk Management process includes standard management elements, such as:
top level commitment, establishment of policies and goals, provision of adequate resources - both organisational and fiscal, allocation of responsibilities and fostering a positive safety culture.
Risk Management is applied to establish a solid basis for planning the operations or activities and for taking decisions. Risk Management enables the operator to achieve pro-active rather than re-active management. This is achieved by collecting and analysing available information to identify hazards and impose risk controls when planning for operations rather than dealing with them after operations have commenced and things have gone wrong.
Risk Management should also be used for channelling experience back into revised planning when required. It is also a process that should be employed to evaluate the safety effect of changes applied to an organisation.
It is not possible to eliminate all risk from an activity, only to minimise it. In the management process, risks need to be assessed and treated to the extent possible to obtain a risk level which is acceptable. To determine the acceptable risk level is, in principle the responsibility of the management, and will be influenced by factors external to the company. Laws, regulations, ethics and the society in general influences acceptable risk, as well as factors such as insurance premiums and passenger’s perception are major influences on acceptable risk.
Balancing the safety benefits of risk control against feasibility and cost to implement, can lead to other criteria, such as the principle of As Low As Reasonably Practical (ALARP) instead of quantitative risk acceptance criteria.
As part of Risk Management, there is a need to address the improbable event of an accident. The Emergency response plan may be seen as the operator’s preparation to reduce further consequences once an accident or incident has happened.
Establishment of a Safety Management System
Safety critical processes need to be determined. Operators who have implemented an ISO 9000:2000 based Quality Management System should already have the processes defined, and need only to apply the risk management process to the PDCA cycle for the management of these processes.
A SMS may be considered to be a 3 level system consisting of: the management level; the department level; and the personnel level:
Management level
The commitment to implement the SMS comes from the ‘Accountable Manager’, who is also responsible for establishing policies and goals and deciding the organisation and allocation of responsibilities.
The senior management is responsible for ensuring that a safety culture is inculcated throughout the company. This will gradually be achieved through ensuring well informed staff, the encouragement for reporting of occurrences and safety concerns, the ability of the organisation to learn from experience and fair and just treatment of employees,.
Although the scope of JAR-OPS limits these requirements to Flight operations, there is an obvious need to interface with other SMS’ within the company. An interface document could show how this will be achieved with parts of the organisation such as maintenance, sales and marketing, as well as contractors and customers where applicable. It should be made clear how all interact as they influence each other in the respect of safety.
Department level
All departmental processes and activities in flight operations, training and ground operations should be evaluated to establish their direct influence on safety. If these processes could influence safety, they should be the subject of a risk assessment, as part of the overall departmental Risk Management system. This applies in particular to the development of procedures, routines and working practices.
A suitable risk analysis tool should be developed, that is adapted to the size and complexity of the tasks to be analysed.
The single most important element of the risk management process is hazard identification.
As it is not humanly possible to foresee all relevant hazards in the initial planning stage, it is of the utmost importance to ensure that actual experiences are fed back to those responsible for the procedure for evaluation and analysis. Properly executed, this will form new input to the risk analysis and the result might lead to consequential adjustments to the procedure, equipment or training requirements in a continuous improvement process. There are numerous sources for this type of information (see e.g. the ICAO Safety Management Manual).
Occurrences and other experience should be investigated and analysed in sufficient depth to determine root causes in order to establish if preventive measures may be implemented, not just to prevent recurrence, but also prevent other occurrences from the same root cause.
Experience is an essential part of risk management and should provide a basis for decisions to improve procedures, training or equipment, as well providing safety information to staff.
Personnel level/performance of tasks
Application of risk management should ensure that safety critical activities are only conducted in accordance with established procedures, by personnel possessing sufficient competence and utilising adequate equipment for the job.
The presence of a positive company safety culture should encourage personnel to adhere to established procedures and provide an open reporting mentality. Feedback from front line personnel is of utmost importance. This could take the form of occurrence reporting as well as reporting of safety concerns and other relevant experiences from normal operations. There are numerous tools available to collect experience (see e.g. the ICAO Safety Management Manual).
Personnel should be given tools and training to aid in situational awareness and decision making by observing, evaluating and taking proper actions to ensure safety during the performance of their tasks.
Terminology
There are significant differences in the terminology used with respect to SMS, partly because there is no international standard for SMS available.
It is important to establish a common terminology standard by clearly defining all relevant terms used in the operator’s own SMS."
