Frequently Asked Questions about SMS
- My organisation already has an SMS described in the exposition that the CAA has previously accepted. Why do I need to submit an implementation plan?
- Do I need to create a separate SMS manual?
- Do I need to submit a manual with my implementation plan?
- What is the relationship between the CAA SMS and the Health and Safety at Work Act?
- Can I be the safety manager and hold other senior person roles?
- What are the senior person training requirements?
- What are the roles and responsibilities in the SMS?
- Where do the 13 elements fit with Part 100?
- What if I need to change my approved SMS implementation date?
- When and what do I need to submit for SMS certification?
My organisation already has an SMS described in the exposition that the CAA has previously accepted. Why do I need to submit an implementation plan?
Expositions submitted to the CAA prior to Part 100 coming into force have been accepted on the basis of demonstrating compliance with the Rules applicable at that time. Thus, while your exposition might well have contained SMS provisions for some time, the CAA will not have assessed their suitability against the new requirements. More importantly, you should note that while documentation is an essential part of an SMS, the assessment of whether your SMS is ‘Present & Suitable’ during the certification process will have a significant focus on capability (people and processes) to ensure that the organisation has the right foundation for an effective SMS that will enhance safety performance.
For this reason, all certificated organisations required to establish, implement, and maintain a system for safety management must submit an implementation plan including a proposed date for implementation and an outline of how this will be achieved.
For organisations that have been voluntarily operating a safety management system, the plan could take the form of a covering letter with the application form CAA 24100-1 stating the references to where the current system is described, that a gap analysis against the current AC100-1 Safety Management (acceptable means of compliance) has been performed, with either details of any changes made or no change required, as appropriate.
No – in fact, a good case could be made for integrating the SMS processes and requirements within your existing exposition rather than creating a ‘stand-alone’ SMS manual. That said, how an operator structures the documentation of its SMS is up to the operator. The crucial points are that it becomes part of the existing exposition for document control purposes and people know where to access the documentation and when it has been updated. You can create a stand-alone SMS manual, combine it with your existing Health and Safety manual, or integrate it into your existing exposition or management system manual. For further guidance refer to section 2.3 of AC100-1 Safety Management.
No. Normally, development of the manual will occur as you address identified gaps as part of your plan. It's important to understand that the gap analysis is conducted on your organisation’s existing management processes and procedures, not a future state manual. This is to ensure that you identify the gaps that must be addressed to fully implement an SMS. If you submit a plan that states you have no gaps, it's likely that you will be asked to provide documentary evidence that SMS processes are in place, such as your process for safety risk management, or setting safety goals and objectives. This is because a plan based upon a flawed gap analysis such as: over-stating the level of SMS maturity, or basing it upon a future state manual, or where the analysis has not taken into account the size of the organisation and the complexity of its products or services, will not have adequately identified the resources and methodical process required to support effective and sustainable SMS implementation. For further guidance refer to section 3 of AC100-1 Safety Management.
There are similarities between management system standards for occupational health and safety (e.g. AS/NZS 4801, 4804, 45001:2018), environmental management (e.g. AS/NZS ISO 14004) and quality management (e.g. AS/NZS ISO9001). This presents Operators with opportunities for integration of their Part 100 SMS in areas such as safety policy, safety committees, safety documentation (e.g. manuals and templates), hazard identification and risk assessment methodologies, safety assurance, and consolidated communication and safety promotion efforts.
In the CAA’s view, the risk and safety management systems required to satisfy the Part 100 requirements are very similar to those you should already have in place to manage your Health and Safety obligations. The main point of difference between Part 100 SMS and the requirements of the Health and Safety at Work Act is that SMS is focused upon aviation safety whereas the requirements of the latter are broader and more explicitly cover occupational health as well as safety.
It depends. The senior person responsible for the system for safety management may, subject to an assessment of their knowledge relevant to the position, consideration of the circumstances of a particular Operator and acceptance by the Director, combine this role with other senior person roles required by the Rules.
In making the assessment of whether a person can be the Safety Manager and hold other senior person roles, the CAA will consider what potential conflicts of interest may exist. An example of conflicting responsibilities in a small organisation might be where the Chief Executive also wishes to be the senior person responsible for the system for safety management (safety manager). There is a potential for conflict of interest, since safety audits or investigations that they conduct, may identify deficiencies in areas of their direct operational responsibility. Having a separate (potentially independent) competent person conduct audits or investigations and form recommendations might be appropriate in that case. Similarly, if a safety manager responsible for safety assurance is also responsible for the control and scheduling of maintenance, performing an audit on their own work would have the potential for conflict of interest.
In such cases it may be appropriate to use an independent person, either employed directly or contracted by the organisation, to maintain system integrity.
For further guidance refer to section 2.1.4 of AC100-1 Safety Management.
Part 100 requires training that ensures all personnel are competent to fulfil their safety responsibilities. The training should be commensurate with the size, nature and complexity of an organisation. Therefore each organisation should establish the training needs for personnel based on their safety responsibility. The suitability of a nominated Safety Manager will be assessed during the SMS certification process.
To assist organisations develop training needs assessments for individual personnel refer to section 2.12 and (for Safety Managers) Annex E in AC100-1 Safety Management.
The Chief Executive: is responsible for establishing the SMS, allocating resources to support and maintain the SMS, and leading the safety culture for an effective SMS.
The Safety Manager: is a senior person responsible for facilitating and administering the organisation's SMS.
All staff: must be aware of, and understand their safety responsibilities e.g. identifying hazards and reporting them.
Further guidance on managerial roles may be found at the following links:
To provide for scalability, the rule is written around the ICAO SMS Framework of 4 Components (pillars): Safety Policy and Objectives, Safety Risk Management, Safety Assurance and Safety Promotion. These components are further broken down into 13 elements which are supported within AC100-1 Safety Management as an acceptable means of compliance and guidance material. The 13 element structure continues through to the evaluation tool form 24100/02. Depending upon the size, nature and complexity of activities undertaken by the organisation, it might be appropriate to structure the SMS and related documentation around the four components – understanding that the 13 elements will still be present in some form within those components....so do all of the questions / sub-elements of the evaluation tool have to be answered?
No. Each element in the tool starts with an overall description paragraph and finishes with an effectiveness statement. This is then broken down into the sub-elements that provide more detailed indicators that may be considered singly or as an aggregate, depending upon the complexity of the process being considered. If, for example, due to scalability as described in the first part of the question, it is appropriate for an organisation to have a simple risk management process (e.g. appendix 9 from SMICG document SMS for Small Organizations), that could satisfy the high level description and effectiveness statements for both elements 4 (hazard identification) and 5 (risk management). Use of the ‘how it is achieved’ column in the evaluation tool will help explain how the process(es) meet the requirement without necessarily needing every sub-element to be answered individually.
Any material changes proposed to an approved implementation plan by an organisation must be documented and submitted on form 24100/03 to the CAA for consideration. A material change in this context is any change that could impact upon the organisation’s ability to demonstrate acceptable performance by the date initially set for implementation. For further guidance refer to section 3.1.2 of AC100-1 Safety Management. It must be remembered that the implementation date is set by the Director, based upon consideration of a number of factors, including resourcing or scheduling impacts on the organisation or the Authority, or both....so what happens if we don’t complete SMS certification by the due date?
It will depend on the circumstances that led to the delay. An operator is required to achieve SMS certification and in that process demonstrate that the capability and performance of their SMS is at a maturity level of ‘present’ and ‘suitable’ (refer to section 3.1 of AC100-1 Safety Management) by the date set for certification. Failure to achieve certification by the due date will result in the CAA carefully considering why the requirement was not met. Significant and consistent slippage of task due dates in an Operators’ implementation plan will also trigger this consideration.
At one extreme, failure to achieve certification or significant slippage of due dates in the implementation plan might be due to factors entirely beyond the control of the operator. At the other end of the continuum it may be that the failure raises significant doubts about the capability and/or capacity of the operator to meet safety regulatory standards. Each case would be considered on its merits and appropriate action taken. This could range from simply setting a new due date through to taking administrative action against the aviation document.
As for most certification activity, to allow sufficient time for CAA to review the exposition and supporting document then perform a site visit (approximately one month prior to the implementation date), it's required that the following is submitted at least 60 days prior to the date set for implementation:
- Application for Amendment to Certificate Forms (Amendment form applicable to Organisational Certificate Rule Part & Senior Person change(s))
- Completed CAA SMS Evaluation Tool
- Amended Exposition / manuals
- Rules Matrices – Part 100 and associated organisational certification rules
Documentation should be sent to the appropriate CAA operational unit applicable to your organisation. Further guidance may be found in section 3.3 of AC100-1 Safety Management, by contacting your CAA operational unit, or via email to the SMS team: firstname.lastname@example.org.