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Frequently Asked Questions

Q1.Why has ICAO developed and adopted a new Annex on safety management?

Identification of hazards, assessment and mitigation of risks nowadays become a standard practice in many industrial areas as one means to reduce incidents and accidents. In parallel, the new era of computers and monitoring systems now allows to collect a huge amount of safety data, which, when correctly analyzed, can be transformed in what we called “safety intelligence” and/or precursors to better address and monitor these risks. Finally, with air traffic projected to double in the next 15 years, current and emerging safety risks also need to be addressed proactively to ensure that this significant capacity expansion is carefully managed and supported through strategic regulatory and infrastructure developments.
The ICAO High-level Safety Conference (HLSC – ICAO doc9335) held in 2010 provided the impetus for the development of a new Annex dedicated to Safety Management. The Conference concluded that safety management processes under the direct responsibility of  States that are critical to civil aviation safety should be contained in a single Annex: 

–       Including the State Safety Programme (SSP) framework and the 8 critical elements of a safety oversight system;

–       Covering general and business aviation activities; and

–       Retaining the safety management system (SMS) requirements specific to one area of activities in individual Annexes.

The safety management provisions, gradually introduced since 2001 in six different Annexes and now compiled in Annex 19, first edition, better address safety risks by:

-   Highlighting the importance of safety management at the State level;
-   Enhancing safety by consolidating safety management provisions applicable to multiple aviation domains;
-   Facilitating the evolution of safety management provisions;
-   Further promoting the implementation of Safety Management System (SMS) and State Safety Programme (SSP) provisions;
-    Encouraging the collection, sharing and protection of safety information; Promoting safety culture; and
-   Establishing a process to analyze feedback received regarding Annex 19 and safety management implementation.

Q.2 Which changes in ICAO Safety Management Standards and Recommended Practices (SARPs) have been introduced with the adoption of Annex 19 Safety Management?

In response to HLSC 2010 recommendation 2/5, the ICAO Air Navigation Commission recommended that the first edition of Annex 19 consolidate existing safety management provisions. Therefore Annex 19, first edition, comprises mainly the transfer of existing safety management provisions previously in Annexes 1, 6, 8, 11, 13 and 14, with the following changes highlighted below:

- SMS framework is now also applicable to aircraft Design and Manufacturing
- The four components of the SSP are elevated to the status of “Standard” (3.1.1)

- The State Safety Oversight provisions are now applicable to all service providers.
- Chapter 5 in Annex 19 contains provisions for the safety data collection, analysis, exchange and protection.

Q3.Whom is Annex 19 applicable to?

Firstly, the Standards and Recommended Practices (SARPs) contained in Annex 19 shall only be applicable to safety management functions related to, or in direct support of, the safe operation of aircraft. Secondly, Chapter 3 of Annex 19, 1st Edition outlines safety management responsibilities directly applicable to the State, including the SMS requirements be implemented by the following service providers (as described in the relevant Annexes):

- Approved training organizations;
- Operators of aeroplanes or helicopters authorized to conduct international commercial air transport;
- Approved maintenance organizations providing services to operators as described in bullet 2;
- Organizations responsible for the type design or manufacture of aircraft;
- Air traffic services (ATS) providers, and;
- Operators of certified aerodromes.

International general aviation operators, conducting operations of large or turbojet aeroplanes are also required to implement an SMS. Beside the above, any organization, willing to implement an SMS , may do so on a voluntary basis.

Q4.How does a service provider address contractors and sub-contractors in their SMS?

[SMM 5.3.18; 5.3.24; C5, App 4, 3.2, paragraph 3]
Note: Here “service provider” refers to the list here above (i.e. question 3)
While it may not be mandatory for a service provider to include all contractors and sub-contractors under their SMS, an effective SMS should factor in the risks associated with having other entities perform tasks and services that may impact the service provider's performance. For contractors and sub-contractors that have their own SMS, a link should be formally established between the reporting systems to facilitate integration. For contractors and sub-contractors who do not have an SMS, it would be beneficial if their relevant employees are provided appropriate training that could facilitate their input to the service provider's reporting system.

Q5.By implementing SMS, does that mean a service provider is no longer required to comply with prescriptive regulations?

[SMM 2.16]
No, SMS does not replace existing system of regulatory control. Safety management is an additional layer to better identify hazards, control risks and improve safety. Compliance to established national regulations (based on ICAO SARPS) remains the foundation on which SSPs and SMSs should be implemented. The concept of performance or risk based management in Annex 19 does not absolve States from addressing the existing provisions in other Annexes, which remains fundamental to aviation safety. SSP-SMS implementation is truly a collaborative process between regulator and service provider. It is an enhancement which goes beyond prescriptive regulations and compliance.

Q6.Which guidance material is available to support the implementation of Annex 19 by the States and the Service Providers?

The SMM, third Edition 3, which supports the implementation of new Annex 19, contains detailed guidance and tools for SSP and SMS implementation. Further details can be found at http://www.icao.int/safety/SafetyManagement/Pages/Guidance-Material.aspx
In addition, a selection of links to safety management material can be found at http://www.icao.int/safety/SafetyManagement/Pages/CommunicationandPromotion.aspx .

Q7. What support is available to assist service providers in implementing a safety management system?

[SMM 4.2, element 2.2 and 4.2]
A fundamental principle of SMS implementation’s success is that the organizations build their SMS themselves. The CAA should guide service providers in finding their own effective SMS and safety performance levels. This is being done through SMS educational forums, guidance materials, SMS facilitation workshops, voluntary self-assessment exercises and on-site trial assessments by CAA. The CAA will also liaise with each service provider for the review and agreement of the SMS safety performance indicators in accordance with Annex 19 Attachment A, 2.2. 

Q8. What is the relationship between SMS and QMS? 

[SMM 2.9; 5.4.2 ]
SMS differs from QMS in that SMS focuses on the safety, human and organizational aspects of an operation i.e. “safety satisfaction”. Quality management focuses on the product (service) of an operation i.e. customer or “specification satisfaction”. Safety management results in the design and implementation of organizational processes and procedures to identify hazards and control/mitigate risks in aviation operations. Quality management techniques provide a structured process for ensuring that organizational processes and procedures achieve their intended product (service) specifications or customer expectations. SMS is partly built upon the same procedural principles and objectives as QMS. An organization’s safety policy and objectives should be integrated with its quality policies. Conversely, the coverage of quality policies should be fundamentally based upon quality in support of safety. Safety objectives should receive primacy where conflicts are identified. QMS is the main supporting structure for a SMS. QMS is in some cases provides a foundation for SMS. SMS can be looked at as an enhanced QMS. Refer SMM (3rd edition) on Integration of Management systems and SMS-QMS integration. 

Q9. Does the SMS manual require CAA approval?

[SMM 5.3.18; 5.3.24; C5, App 4, 3.2, paragraph 3]
Note: Here “service provider” refers to the list here above (i.e. question 3)
Annex 19, Chapter 4 states that the SMS of the organization shall be made acceptable to the State(s) responsible for the organization’s approval. This does not mean that the SMS or its manual should receive an approval independent of the organization’s existing CAA approval process. In principle, the SMS manual should be treated no differently from the organization’s other CAA approved or accepted documentation.
The SMS manual should be subject to the agreement of the State/CAA as part of the SMS assessment and acceptance process (eg SPIs within the SMS manual will require CAA agreement).  It may be a standalone manual or a dedicated section of an appropriate CAA approved Organization Exposition Manual or Procedures Manual.  For instance an  aircraft operator having its own maintenance and training services may have one integrated SMS manual covering the three types of activities or prefer to have its SMS functions addressed separately in each domain with a coordination function.
Amendments to the SMS manual or equivalent  should follow the same principle.
Note: 1.5.3 of Appendix 2 of Annex 19, Framework for Safety Management Systems (SMS), does require the service provider to develop and maintain an SMS manual and 1.4.4 of Annex 14 still requires that the aerodrome manual include a SMS. The SMM further suggests that the SMS document may be a stand-alone document or it can be a distinct ―SMS section/chapter - within an existing organization exposition manual. Where details of the organization’s certain SMS processes are already addressed in existing documents, appropriate cross referencing to such documents may be sufficient but  it is up to the State to determine if this should or can be integrated with existing documents.  

Q10. How would a small organization with limited operations implement an SMS?

An objective review of the spirit/intent of each of the 12 SMS framework’s  elements show that they can be complied even by small organizations. At the simplest level, the CEO can possibly be the certifying person, SMS manager, the Operations manager, Finance manager, the QM, etc. (provided he can convince the regulator of his certifying competency, amongst others). There is no SARP which requires a minimum number of personnel for an organization. An example of a small maintenance organization (AMO) with an SMS: an AMO which consists of a workshop servicing of a certain aircraft battery.
-       He compiles safety/ quality data pertaining to his (customer’s) batteries –reports on operational incidents, failures during final shop testing, technical warranty claims, etc. His own occurrence/ warranty investigation reports are on file, with mandatory reports submitted to the CAA as required. ·       
-        He compiles 3 Safety Performance Indicators (SPIs) from these 3 report types (database) and monitor their trend. He sets alert/target values for each SPI. ·       
-        He performs Risk mitigation on any servicing/ operational Hazards identified (by himself, customer or industry) relevant to his battery. He takes follow up or corrective actions when any of his battery SPIs bust an alert level or fails to meet his own SPI improvement targets.
-        He has a simple safety policy statement about his battery servicing business.
-        He has a simple contingency plan which includes provision to send his batteries to another AMO, in case of capacity or technical problems beyond his capability. ·       
-        He has compiled a 10 page SMS document which describes his own SMS processes (which satisfy the basic intents of the regulator’s SMS elements).
-        His SMS document has been endorsed/accepted by his CAA. 

Q11. How is occupational or workplace safety related to the SMS SARPS in Annex 19?

[SMM 2.9; 2.13.12; 5.4.2]
The ICAO safety management Standards and Recommended Practices (SARPs) contained in Annex 19 are only applicable to safety management functions related to, or in direct support of, the safe operation of aircraft. The SMM addresses primarily SMS in relation to aviation safety (air transportation system and its relevant service providers). Paragraph 2.13.12 of the SMM emphasizes the scope of hazards and risk management to “aviation safety-related operations and processes”. Nevertheless, the outcomes of aviation safety may sometimes be related to occupational or workplace safety. As such, the organization should ensure that any relevant aspects of occupational/workplace safety (as with any other management systems) are integrated into SMS where appropriate. Refer to SMM 2.13.12 on necessary distinction between work place hazards from aviation hazards.  

Q12. Should human factors be part of SMS and SSP? If so, how should this be reflected in the SMS Manual?

Although Annex 19 does not address “Human Factors” (HF) specifically, HF is pertinent to the Hazard Identification and Risk Mitigation (HIRM) process within SMS/ SSP. Refer to SMM 2.15.6 (extract below) Quote 2.15.6 Human Factors and Risk Management Given that mature SSPs and SMSs target both human and organizational factors, a specific analysis process is a component of any mature, effective risk management system. In the course of any hazard identification and risk mitigation exercise involving human elements, it is necessary to assure that existing or recommended defences have taken human factors (HF) into consideration. Where necessary, a supplementary HF analysis may be conducted to support that particular risk mitigation exercise/team. A HF analysis provides an understanding of the human error impact on the situation and ultimately contributes to the development of more comprehensive and effective mitigation/ corrective actions. A human error model is the basis of the analysis process and it defines the relationship between performance and errors and categorizes errors to permit the root hazards to be more readily identified and better understood. This understanding ensures the adequate completion of a root cause analysis. Individual actions and decisions, viewed out of context can appear to be virtually random events, escaping its due attention. Human behavior; is not necessarily random. It usually conforms to some pattern and can be analysed and properly understood. Ultimately, this important HF perspective results in a more comprehensive and in-depth mitigation process. Human factor analysis ensures that the organization‘s risk mitigation process, when identifying root, contributory or escalation factors, that human factors and their associated circumstantial, supervisory and organizational impacts are duly taken into consideration. Unquote  

Q13. What would be the additional functions and responsibilities of the entity within the State tasked with establishing the SSP? 

[SMM 4.4.3 (e)]
The SSP framework could be used as a reference for the tasks and responsibilities assigned, with caution exercised to ensure that any potential conflicts of interest are avoided. This may be addressed by establishing a separate unit if the State wishes to do so. The personnel assigned to this unit should have knowledge of safety management, including the conduct of hazard identification, risk assessment and the implementation of appropriate mitigation strategies as well as occurrence reporting and analysis. Interfaces and coordination with the bodies implementing the SSP in every operational domain should be correctly addressed.   

Q14. (State) I have already filed differences against the safety management provisions in Annexes 1, 6, 8, 11, 13 and 14. As Annex 19 is the compilation of the safety management provisions from these Annexes, do I still need to file differences to Annex 19?

[SMM 5.3.18; 5.3.24; C5, App 4, 3.2, paragraph 3]
Yes, the State will have to file differences against Annex 19, if any, because most of the safety management provisions in Annexes 1, 6, 8, 11, 13 and 14 are transferred in Annex 19 and will no longer exist in these Annexes*. In addition, Annex 19 contains some new provisions as explained in question n'2.
The EFOD System will be updated to include Annex 19 provisions and to reflect the consequential amendments to other Annexes* from 15 July 2013 to allow States to begin identifying and notifying their differences to ICAO.
States will be expected to review any difference(s) currently filed to overarching safety management SARPs in Annexes 1, 6, 8, 11, 13 and 14, Volume I, to determine if the difference(s) should be filed to provision(s) as transferred* into Annex 19.
In order to support this task, Attachment D to State Letter AN 8/3-13/30**  contains a mapping of safety management provisions from the existing Annexes to Annex 19. In addition, for each State, a special report of the differences currently filed to safety management provisions, based on Attachment D, will be generated and made available on the Universal Safety Oversight Audit Programme (USOAP) website, https://soa.icao.int/usoap/ . When filing differences, States should ensure that all aviation sectors (aviation training organizations, air operators, approved maintenance organizations, air traffic services providers, certified aerodromes and international general aviation operators) are properly considered. This is particularly important for Chapters 3 and 4 of Annex 19. * As a result of the transfer of the safety management provisions in Annex 19, consequential amendments to Annexes 1 (Amdt.171), 6 - Part I (Amdt.37), II (Amdt.32) and III (Amdt.18), 8 (Amdt.104), 11 (Amdt.49), 13 (Amdt.14) and 14 (Amdt.11) Volume 1 have been proposed. ** Attachment D to State Letter AN 8/3-13/30 can also be found at http://www.icao.int/safety/SafetyManagement/Pages/SARPs.aspx  
   

Q15. How can I get Annex 19 and the SMM?

1. For ICAO Member States' Civil Aviation Administration and governmental bodies/agencies involved in non-commercial aviation activities: Please see http://portal.icao.int/instructions.htm
2. For non-contracting States or others: Annex 19 - Safety Management and the Safety Management Manual (SMM) - Doc 9859 are available for purchase in hard copy or electronic format through ICAO's Online Store at http://store1.icao.int/ or via email at sales@icao.int .  

Q16. Whom should I contact if I have additional questions regarding Safety Management?

All questions and feedback regarding Safety Management should be addressed to: SafetyManagement@icao.int  

Q17. When a State (CAA) incorporates a enforcement decision aid as part of its (SSP-SMS environment) enforcement policy and procedures, would it be necessary that the use of such an enforcement decision aid be legislated? (i.e addressed in its Legislative provision on enforcement penalties and administrative actions).

It is common for regulatory Authorities to be normally empowered to use their discretion whether to pursue penalty or administrative actions. In such an environment, the adoption of an enforcement decision aid is simply a tool to facilitate such normal discretionary power that the CAA already has. Thus, the CAA’s adoption of such an enforcement decision aid may not need to be addressed in the Legislative provision on penalty or administrative actions. The final decision is within the purview of each State.