Definitions

SMS Documentation - the set of documents arising from the organisation’s safety policy statements to develop and document the Safety Management System in order to achieve its safety objectives. (EUROCONTROL ESARR3)

Documentation - information or meaningful data and its supporting medium (e.g., paper, electronic, etc.). In this context it is distinct from records because it is the written description of policies, processes, procedures, objectives, requirements, authorities, responsibilities, or work instructions. (FAA AC 120-92A)

Records - evidence of results achieved or activities performed. In this context it is distinct from documentation because records are the documentation of SMS outputs. (FAA AC 120-92A)

Safety Documentation

According to the definitions provided above safety documentation includes SMS documentation and safety records.

Purpose

The purpose of the SMS documentation is to document the safety management system (SMS) of the organisation and communicate it internally to staff and externally to the organisations concerned, for example to the regulator. It enables the correct execution of safety procedures and thus the achievement of the organisation’s safety objectives.

Safety records are maintained in order to provide documented safety assurance to all associated with, responsible for or dependent upon the services provided by the organisation, and to the regulator. Safety records are needed to demonstrate that the SMS is operated according to the expectations.

SMS Documentation

An explicit feature of the SMS is that all safety management activities are required to be documented and visible. Formal documentation is required to provide the authoritative basis of the SMS. Also, it is used to clarify the relationship between safety management and the other functions of the organisation, the way in which safety management activities integrate with those other functions and how these activities link to the organisation’s safety policy.

SMS documentation should include or make reference to, as appropriate, all relevant and applicable national and international regulations. It shall include descriptions of: safety mangement processes, procedures and specific templates, such as reporting forms; lines of accountability, responsibility and authority regarding the management of safety, the structure of the safety management organisation and the SMS outputs. The SMS documentation shall contain explicit guidelines for records management, including access, handling, storage, retrieval and preservation.

The most important piece of documentation of an SMS is the SMS manual. The safety management manual (SMM) is a major means for communicating the organisation’s approach to safety to all employees. It should not be a static document. It has to be regularly reviewed to reflect changes in the organisation, procedures, equipment, etc. According to ICAO Doc 9859 - Safety Management Manual the typical content of an SMM includes:

• safety policy and objectives of the organisation
• scope of the safety management system
• safety accountabilities and responsibilities
• key safety personnel
• documentation control procedures
• coordination of emergency response planning
• hazard identification and risk management schemes
• safety assurance
• safety performance monitoring
• safety auditing
• management of change
• safety promotion; and
• contracted activities.

The EUROCONTROL guidance material related to SMS implementation provides further advice how to document the above mentioned safety procedures in the SMM. “Safety procedures should describe in practical and actionable terms what has to be done to comply with the SMS. Each safety procedure should be understandable, actionable, auditable and mandatory. All the SMS safety procedures can be bound together and all staff given access to the complete set, forming a manual. An alternative approach is for departments to have available just those procedures, which are relevant to their own work and this may be the better approach in a larger organisations.”

Documentation Control Procedures

Managing and operating a SMS generates significant amount of information. There is a wide variety of documents and electronically stored data from various sources used or originated by the SMS. A disciplined approach to information and documentation management and strict documentation control are essential for the successful implementation and operation of the safety management system.

Documentation regarding the operation of SMS is best be presented in clear and unambiguous statements, dated with the timestamps of any revisions, maintained in an orderly manner and revised at specified periods as determined by the organisation. The safety documentation is to be approved, as applicable, by the oversight authorities.

Aviation service providers shall establish a documented process to update the SMS documentation when the safety management system is reviewed and modified. The obsolete and outdated documents shall be removed from usage or secured otherwise against unintended use. Successful organisations maintain the current versions of relevant safety documents not only at the safety department but also at other locations, including operational units which play an essential role for the effective functioning of the SMS.

The main goal of documentation (and records) management is to guarantee access, exactness, reliability, security and quick availability of all useful information. To achieve this goal the documentation management and control procedures applied by an organisation should cover document identification, drawing up and presentation, verification, authorisation, distribution, update and filing.

Safety Records

A safety record is any information, which can be used to support a safety claim and demonstrate the degree of acceptability of the safety performance of the services provided by an organisation.

Safety records are to be created and maintained throughout the SMS operation. Appropriate procedures should determine their format and, in each case, specify the form in which records have to be made and who is responsible for ensuring that this is done.

Safety records could be perceived as a negative and bureaucratic element. However, safety records are needed not only to demonstrate that SMS is operating but also to provide data and traceability which can be used to identify and solve actual safety problems.

The information items building the list of safety records in an organisation will depend on the scale and complexity of the operations. As the scale of operation increases more items will be put on this list. Some records may be qualitative, for example training records, safety analyses, etc. Other may be quantitative, for example statistics derived as a result of safety monitoring.

There is a need to identify the safety records to be kept for each SMS process, ensuring that only those critical to safety are maintained. Also, international or national regulations and standards may require specific safety records as a basis for providing regulators with safety assurance. The effort that goes into record keeping should be balanced against the value of data. In particular, special effort should be made to ensure proper recording and documenting of safety assurance processes (safety surveys, safety monitoring).

One should not confuse safety records with recorded operational safety data, such as communications between pilots and controllers. ‘Safety records’ is the documented output of the safety management processes and activities, such as:

• Incident investigation reports
• Safety recommendations, related remedial actions and their follow-up
• Safety assessment reports (safety cases) and supporting material
• Safety surveys reports
• Statistical data related to safety
• Personnel licensing data
• Personnel safety training records
• Minutes of safety meetings;
• Management decisions aimed to improve safety
• Any documented measure taken to control risk and to ensure that adequate levels of safety are maintained.

Safety records should be maintained in sufficient detail to ensure traceability of all safety-related decisions.

Further Reading

ICAO

• ICAO Doc 9859 - Safety Management Manual, Fourth Edition - 2018;
• ICAO Integrated Safety Management website;

EUROCONTROL

• Eurocontrol Safety Regulatory Requirement - ESARR3, Use of Safety Management Systems by ATM Service Providers;
• ESARR Advisory Material/Guidance Document - EAM3/GUI3 ESARR3 and Related Safety Oversight;

Others

• FAA Advisory Circular No.120-92B;
• FAA Advisory Circular No.150/5200-37A, Safety Management Systems for Airports.