SSP IMPLEMENTATION .1 State safety responsibilities and accountabilities Accident and incident investigation
11-4 Safety Management Manual SMM
11.4.5 Safety management principles affect most activities of a State’s civil aviation authority, starting with
rulemaking and policy development. Rather than pursuing only the causes of the most recent accident, SSP rulemaking is based on comprehensive analyses of the State’s aviation system. Regulations are based on identified hazards and
analysis of the safety risks of the consequences of hazards. The regulations themselves provide frameworks for risk control, when integrated into the service provider’s SMS.
11.4.6
State safety assurance. A description of how the State will ensure that safety management within the State
and the operation of the service provider’s SMS follow established controls regulatory compliance, how realistic implementation of the SSP ALoS will be achieved, though a combination of safety measurement by the State and safety
performance measurement by service providers, and how the actual performance of the service provider’s SMS safety performance will be demonstrated safety performance measurement. This includes the establishment of the necessary
arrangements oversight, inspections, audits, safety data analysis and so forth necessary to verify compliance and measure performance.
11.4.7
SSP oversight activities. SSP oversight activities, beyond rulemaking, are supported by analysis, and the
resource allocation priorities of the State’s civil aviation authority are based on the safety risks of the consequences of the hazards identified through analysis. Certification and continuing operational safety decisions are based on
assessments of performance of the service provider’s processes, products andor services. Flowing forward from the regulations that address defined hazards, compliance decisions are based on whether a service provider’s SMS
addresses the hazard in regulations within the service provider’s specific operational environment. The State safety assurance processes are used to obtain confidence in the service provider’s safety management capability as
demonstrated in assessments of its SMS. 11.4.8
State’s safety promotion. A description of the arrangements by the State to ensure that safety training,
communication and dissemination of safety information take place. Under an SSP, this is a dual-track promotion; both within the State’s aviation organizations as well as among the service providers it oversees. This includes the
establishment of the necessary means to provide training and communicate safety information. 11.4.9
None of the above changes the role of the State and its aviation organizations regarding the establishment of the State’s regulations and standards, or the requirement for State civil aviation personnel to possess high levels of
knowledge and skills. On the contrary, it requires additional skills in areas such as safety risk analysis, system evaluation, and management system assessment, as well as in the many new technologies essential for the aviation
industry to achieve its production objectives. This makes it incumbent on the State to provide for these competencies through training, recruitment and human resource management.
11.4.10
In developing the SSP, safety management principles provide a conceptual platform for parallel development of the SSP by the State and the SMS by service providers. An SSP developed from, and based upon,
safety management principles bridges the gap that would otherwise inevitably develop between the internal and external safety processes within the State’s civil aviation organizations and the internal safety processes of service providers
see Figure 11-1. As part of the SSP, the State promulgates SMS requirements for service providers requiring them to demonstrate their safety management capability up front, rather than waiting for accidents, incidents, or non-compliance
with safety standards. This allows both the State and service providers to get ahead of safety risks. SMS requirements under the SSP also provide a structured framework allowing the State and service providers to interact more effectively
in the resolution of safety concerns. In this way the shared, interactive nature of the SSP and the SMS comes to fruition.
11.5 SSP IMPLEMENTATION 11.5.1
SSP implementation is facilitated by identifying the processes associated with each of the four components of an SSP discussed in the previous paragraphs. These processes can then be turned into discrete
elements of each component of an SSP and, similar to the SMS framework discussed in Chapter 8, the combination of
Chapter 11. State Safety Programme SSP 11-5
elements and components becomes the framework for an SSP. The availability of such a framework provides a principled guide for SSP implementation. ICAO has developed guidance for the development of an SSP framework in
order to facilitate SSP implementation, and the ICAO SSP framework is included in Appendix 2 to this chapter. Appendix 5 to this chapter presents guidance on an SSP implementation plan.
11.5.2
An example of the SSP developed by one State, the State safety programme for the United Kingdom, published through the UK Civil Aviation Publication CAP 784, can be accessed through the UK CAA website:
www.caa.co.uk .
11.6 THE ROLE OF THE SSP IN SUPPORTING SMS IMPLEMENTATION 11.6.1
One of the objectives of an SSP is to generate a context that supports the implementation of an SMS by service providers. The service provider’s SMS cannot perform effectively either in a regulatory vacuum or in an
exclusively compliance-oriented environment. In such environments, service providers will only implement and demonstrate, and the State authorities will only assess, the tokens of an SMS. A service provider’s SMS can flourish
only under the enabling umbrella provided by an SSP. The SSP is therefore a fundamental enabler of the implementation of an effective SMS by service providers. For this reason, within the scope of the overall implementation
of an SSP presented in Appendix 5, four steps, two globally and two specifically, aim at supporting SMS implementation by service providers.
Figure 11-1. SMS bridges the gap between the safety processes of the State and those of the service provider
SSP SSP
SSP
State Service
providers
SSP SMS
Safety performance
ALoS
11-6 Safety Management Manual SMM
11.6.2 The first step, overall, to be taken by a State in implementing its SSP is to conduct a gap analysis, in order
to ascertain the existence and status of maturity, within the State, of the elements of an SSP. An example of a gap analysis for an SSP is included in Appendix 3 to this chapter. Following the gap analysis, the State is in a position to
draft the national legislation and operating regulations governing the functioning of the SSP. Included among these will be the SMS requirements for service providers.
11.6.3
An early step in implementing an SSP is to develop a training programme for the personnel of the State authority. The training programme should have two basic objectives. The first objective is to provide knowledge of safety
management concepts, including the ICAO SARPs contained in Annexes 1, 6, 8, 11, 13 and 14, and related guidance material. This aspect of training applies to the SSP, overall. The second objective is to develop knowledge to accept and
oversee the implementation of key components of an SMS, in compliance with national regulations and relevant ICAO SARPs. This aspect of training aims at supporting SMS implementation.
11.6.4
The first step in implementing an SSP specifically aimed at supporting SMS implementation is the development of SMS requirements for service providers, as well as guidance material for the implementation of SMS.
Guidance on the development of a State’s regulation on SMS is included in Appendix 1 to Chapter 10. Such guidance uses as reference the components and elements of the ICAO SMS framework discussed in Chapter 8. This manual and
the ICAO SMS and SSP training courses are sources of information for the development of guidance material. 11.6.5
The second step in implementing an SSP specifically aimed at supporting SMS implementation is the revision of the civil aviation oversight authority’s enforcement policy. This step deserves special mention.
11.6.6 The essence of both the SSP and the SMS is to get ahead of safety risks through the development of
safety management capabilities within the State as well as industry, rather than waiting for accidents, incidents or events of non-compliance. One essence of management, as discussed in various parts of this manual, is measurement, since it
is not possible to manage what cannot be measured. Measurement, in turn, requires data. It follows that safety data collection, analysis and exchange are at the heart of the interactive nature of the SSP and the SMS discussed in
11.4.10. 11.6.7
During the course of normal safety management activities under the SSP and SMS, respectively, the State and service providers will exchange safety data. The service provider’s safety data received by the State will be property
data, a part of which the State will convert into aggregate data. A significant amount of all these data will reasonably refer to safety concerns identified through the normal course of the service provider’s SMS processes. If the civil aviation
oversight authority’s response to these data is enforcement action, the safety management process in the State will grind to a halt. It is therefore essential that, as part of the SSP, the civil aviation oversight authority revise its
enforcement policy to ensure continuous flow and exchange of proactive and predictive safety management data with service providers who operate in an SMS environment. The following guidelines are proposed for such revision:
a service providers should be allowed to deal with certain safety concerns internally, within the context of their SMS;
b service providers should provide the State with a clear definition of the safety concern, including deviations andor minor violations, and a mitigation plan for its resolution, that satisfies the State;
c the mitigation plan should include timelines, so that the State can monitor satisfactory progress of mitigation activities; and
d gross negligence, reckless conduct and wilful deviations should be dealt with through established enforcement procedures.
Appendix 4 to this chapter presents guidance on the development of a State’s enforcement policy and enforcement procedures in an SMS environment.
Chapter 11. State Safety Programme SSP 11-7
11.6.8 A summary of the role of the SSP in supporting SMS implementation and proposed actions is shown in
Figure 11-2.
Figure 11-2. A summary of the role of the SSP in supporting SMS implementation
— — — — — — — — —
STEP 1 STEP 2
STEP 3 STEP 4
•
Conduct a gap analysis of the SSP, in
order to ascertain the existence and status
of maturity, within the State, of the elements
of an SSP.
•
Develop an SMS training programme
for staff of the State’s safety oversight
authority.
• •
Develop SMS regulations for service
providers. Prepare guidance
material for the implementation of
SMS.
•
Revise the State’s enforcement policy.
11-APP 1-1
Appendix 1 to Chapter 11 FRAMEWORK FOR THE STATE
SAFETY PROGRAMME SSP
Note.— Within the context of this appendix the term “service provider” refers to any organization providing aviation services. The term includes approved training organizations that are exposed to safety risks during the provision
of their services, aircraft operators, approved maintenance organizations, organizations responsible for type design andor manufacture of aircraft, air traffic service providers and certified aerodromes, as applicable.
This appendix introduces a framework for the implementation and maintenance of a State safety programme SSP by a State. The framework consists of the following four components and eleven elements:
1. State safety policy and objectives 1.1 State safety legislative framework
1.2 State safety responsibilities and accountabilities 1.3 Accident and incident investigation
1.4 Enforcement policy 2. State’s safety risk management
2.1 Safety requirements for service providers SMS 2.2 Agreement on service providers safety performance
3. State’s safety assurance 3.1 Safety oversight
3.2 Safety data collection, analysis and exchange 3.3 Safety-data-driven targeting of oversight of areas of greater concern or need
4. State’s safety promotion 4.1 Internal training, communication and dissemination of safety information
4.2 External training, communication and dissemination of safety information. A brief description of each element follows.
11-APP 1-2 Safety Management Manual SMM
1. STATE SAFETY POLICY AND OBJECTIVES 1.1 State safety legislative framework
The State has promulgated a national safety legislative framework and specific regulations, in compliance with international and national standards, that define how the State will conduct the management of safety in the State. This includes the
participation of State aviation organizations in specific activities related to the management of safety in the State, and the establishment of the roles, responsibilities and relationships of such organizations. The safety legislative framework and
specific regulations are periodically reviewed to ensure they remain relevant and appropriate to the State.