Safety Documentation
Liberty University
AVIA 409 - Safety Management Systems
Professor: Andrew Walton
2022
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.
