Airport SMS Requirements in the U.S. Recent Developments & Next Steps Safety Management Systems (SMS) vs. Security Management Systems (SeMS) 2016 ACI-NA Public Safety & Security Fall Conference Arlington, Virginia October 19, 2016 Contact: Chris Oswald Tel: 202.293.4539 E-mail: coswald@aci-na.org www.aci-na.org
FAA Airport SMS Framework Airport Operations Airport Development FAA Air Traffic Organization Part 139 Federal Grants and Obligations National Airspace System (S)NPRM Order 5200.11 ATO SMS Manual As regulator As service provider As service provider & operator External Internal ATO SMS Source: FAA www.aci-na.org 2
FAA SMS Framework (cont d) External Program Requires SMS programs at many FAA certificated airports Implemented via formal rulemaking process Initial proposed regulations published in October 2010 Revised regulations released as a Supplemental Notice of Proposed Rulemaking (SNPRM) in July 2016; comment period closed in September Accompanying Advisory Circular is out for comment (due November 10) Internal Program Requires SRM/SRA evaluations of many airport capital improvement projects Implemented on June 1, 2011 Implementation guidance published in June 2011 Program now well established www.aci-na.org 3
Airport SMS SNPRM What Changed? Applicability narrowed somewhat Certificated airports with more than 100,000 annual operations Airports that CBP recognizes as ports of entry (includes a number of airports with less than 100,000 ops) Definition of Accountable Executive broadened to enable individuals other than CEOs to serve in this role Documentation timelines extended by 6 months Implementation plan within 18 months of rule SMS Manual or ACM revision within 24 months Greater, but not perfect, acknowledgement of phased implementation timelines www.aci-na.org 4
Airport SMS SNPRM What Hasn t Changed? Required SMS components Safety policy Safety risk management Safety assurance Safety promotion Inclusion of non-movement areas and other Part 139 areas (e.g., fuel farms) in airport SMS program Data protection and liability issues www.aci-na.org 5
ACI-NA SNPRM Comments Developed by a cross-cutting task force with representatives from Ops/Tech, Legal Affairs, and Risk Management Committees Held weekly teleconferences starting in late July to compile comments Worked closely with AAAE s SMS Working Group to ensure industry comments were consistent and complementary Comments submitted on September 15; ACI-NA s and others comments available at: https://www.regulations.gov/docket?d=faa-2010-0997 www.aci-na.org 6
SNPRM: Areas of Agreement Tying applicability of the SMS Rule to those airports where a net safety benefit from SMS can be demonstrated Revised compliance deadlines for airport operators that are required to implement SMS programs and recognition of phased implementation More realistic SMS training requirements Improved definition of the Accountable Executive Recognition of need for flexibility and scalability when it comes to the scope, sizes, and implementation timelines for SMS programs www.aci-na.org 7
A Key Statement in the SNPRM Unlike traditional checklist-driven inspections, a systems-based approach [used to evaluate SMS programs] would verify [that] the certificate holder has processes in place to proactively identify hazards, mitigate risk, and address non-compliance issues. The FAA would evaluate whether the certificate holder has effective SMS policies, processes, and procedures to identify analyze, and mitigate safety hazards and risks. www.aci-na.org 8
Areas of Continuing Concern Applicability to very small international airports Mandatory inclusion of non-movement areas in airport SMS programs Data protection and liability issues More explicit acknowledgement of phased SMS implementation approaches Clearer delineation of roles of airport safety certification inspectors vs. airport SMS staff Division of responsibilities among various SMS programs (Part 121, Part 139, Air Traffic, voluntary programs established by others) www.aci-na.org 9
A Final Comment: Better Foundation for Collaboration Needed Lots of areas where airports and FAA need to collaborate in the rollout of SMS nationwide Oversight approach/expectations Training expectations Implementation plan details Common understanding of various stakeholders roles and responsibilities We need a mechanism for this coordination Federal Advisory Committee? Industry Working Group with regular FAA participation? www.aci-na.org 10
What s Next? Comments on the FAA Airport SMS Advisory Circular (AC) due on November 10 ACI-NA and AAAE will be submitting mutually developed comments Airport operators encouraged to submit comments individually as well ACI-NA and AAAE working with FAA to set up an SMS Industry Day in January 2017 Maybe groundwork for future collaboration Final rule and associated AC expected late Spring/early Summer www.aci-na.org 11
SMS www.aci-na.org 12