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Cross-LOB SRM Guidance Signed 508

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AVP-300-17-003 (Version 2.

0)
April 20, 2018
Guidance for Coordinating Cross-LOB Safety Risk Assessments
AVP-300-17-003

Purpose

The purpose of this document is to provide guidance for conducting safety risk assessments on
issues that cross multiple Federal Aviation Administration (FAA) Lines of Business (LOB)/Staff
Offices when the organizations seek involvement from the FAA Safety Management System
(SMS) Executive Council and/or the FAA SMS Committee. These cross-organizational safety
risk assessments are conducted in accordance with the current version of FAA Order 8040.4,
Safety Risk Management Policy.

Scope

This guidance applies to all FAA organizations seeking FAA SMS Executive Council and/or FAA
SMS Committee involvement in conducting cross-LOB safety risk assessments.

Approval: ___________________________________________________________________
FAA SMS Committee Chair
REVISION HISTORY

Revision Number Description of Change Effective Date


1 Aligned document to FAA Order April 20, 2018
8040.4B (including latest Hazard
Identification, Risk Management &
Tracking (HIRMT) criteria); updated
stakeholder roles and responsibilities;
revised process flow.
Includes review by Aviation Safety SMS
(AVSSMS) Coordination Group and FAA
SMS Committee.
0 Original Document (Version 1.0) March 31, 2016
Table of Contents
Overview ................................................................................................................................... 1

Triggers for Cross-LOB Safety Risk Assessments ............................................................... 1

Stakeholder Roles and Responsibilities ................................................................................ 3

Process for Coordinating Cross-LOB Safety Assessments ................................................. 8

Step 1: Document Potential Issue/Change in HIRMT ............................................................. 9


Step 2: Request Cross-LOB Safety Risk Assessment Team .................................................. 9
Step 3: Determine and Secure OPR ......................................................................................10
Step 4: Transfer HIRMT Responsibilities to OPR ..................................................................10
Step 5: Conduct Initial Planning .............................................................................................11
Step 6: Establish Scope and Draft System Analysis and Risk Acceptance Plan ....................11
Step 7: Determine and Secure SRM Team Members ............................................................12
Step 8: Ensure Management Awareness of Team Membership ............................................14
Step 9: Develop Detailed Schedule and Communicate with SRM Team................................14
Step 10: Conduct SRM ..........................................................................................................15
Step 11: Review and Finalize Safety Risk Assessment Report ..............................................15
Step 12: Develop Proposed Safety Risk Mitigations Addendum ............................................16
Step 13: Obtain Approval of Proposed Mitigations/Risk Acceptance .....................................16
Process for Escalation of SRM-Related Issues ....................................................................17

Step 1: OPR Determines If Issue Meets Escalation Criteria...................................................18


Step 2: OPR Submits Issue to FAA SMS Committee Chair ...................................................19
Step 3: FAA SMS Committee Reviews/Resolves ..................................................................19
Step 4: FAA SMS Executive Council Reviews/Resolves .......................................................19
Overview
Safety Risk Management (SRM) is a core component of the Safety Management System
(SMS). It provides a formalized, proactive approach to system safety in which safety risk is
identified, analyzed, assessed, and controlled to an acceptable level. Before conducting SRM,
an organization first has to determine if the SRM process should be applied. In general, SRM is
conducted when potential and previously unidentified hazards and/or ineffective controls are
discovered through Safety Assurance activities and when making planned changes to the
aerospace system. 1 SRM is used to evaluate the need for, and to develop, safety risk controls in
the aerospace system. Effective SRM requires early and ongoing involvement by appropriate
stakeholders.

Depending on the issue under consideration, the safety risk assessment may be conducted by
an individual or small group within a single organization. Other times, a cross-organizational
team of stakeholders, or SRM Team, should be formed to adequately address the scope and
complexity of the issue.

The purpose of this document is to provide guidance for conducting safety risk assessments on
issues that cross multiple Federal Aviation Administration (FAA) Lines of Business (LOB)/Staff
Offices when the organizations seek involvement from the FAA SMS Executive Council and/or
the FAA SMS Committee. These cross-organizational safety risk assessments are conducted in
accordance with the current version of FAA Order 8040.4, Safety Risk Management Policy.
Please note that organizations often establish SRM Teams without engaging the FAA SMS
Executive Council and/or the FAA SMS Committee. In this case, the organizations’ SRM
processes are employed. Organization-specific SRM processes are consistent with, but may not
be exactly the same as, the process described in the current version of FAA Order 8040.4.

This document describes:

• The triggers that indicate the need for a cross-LOB safety risk assessment;
• Cross-LOB safety risk assessment roles and responsibilities;
• Process steps for coordinating cross-LOB safety risk assessments; and
• A mechanism for escalating disagreements throughout the process.

Triggers for Cross-LOB Safety Risk Assessments


There are two basic triggers that may indicate the need for a cross-LOB safety risk assessment.
The first trigger is an FAA-level safety issue, and the second trigger is a planned change.

1. FAA-Level Safety Issues

An LOB/Staff Office may identify potential FAA-level safety issues for FAA-level cross-LOB
safety risk assessment and escalate them to the FAA SMS Committee for consideration.

1 Aerospace System is defined in this document using the definition in the current version of FAA Order

8040.4, Safety Risk Management Policy: U.S. airspace, all manned and unmanned vehicles operating in
that airspace, all U.S. aviation operators, airports, airfields, air navigation services, pilots, regulations,
policies, procedures, facilities, equipment, and all aviation-related industry.

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FAA-level safety issues are potential hazards or ineffective controls identified from the Safety
Assurance processes and are considered potentially systemic and most effectively treated by
cross-organizational teams. An issue is considered a potential FAA-level safety issue if it could
affect more than one FAA LOB/Staff Office or if its mitigations require more than one FAA
LOB/Staff Office to implement. A benefit to an LOB/Staff Office submitting an issue for
consideration at the FAA level is that the issue is sure to receive the proper executive-level
visibility and support of the FAA SMS Executive Council and FAA SMS Committee.

Potential FAA-level issues or concerns that may trigger the need to conduct a safety
assessment include, but are not limited to:
• Safety issues assigned by the FAA SMS Committee;
• Safety issues that are present within the National Airspace System (NAS), although its
safety risk have not been accepted, it is expected to have high risk (e.g., it is identified
as a result of an accident/incident or it is assumed to have high risk);
• Safety issues that have high risk and a potentially systemic outcome (e.g., the outcome
crosses LOBs or the outcome impacts an industry segment rather than an individual
certificate holder);
• Any safety issue on which an FAA organization’s management elects to conduct an
FAA-level assessment;
• Data analyses that point to an issue, concern, or potential hazard in the system (e.g.,
analyses driven by Aviation Safety Information Analysis and Sharing (ASIAS));
• Issues identified by industry or system users; and
• New controls deemed necessary by the FAA as a result of internal FAA safety
recommendations or recommendations from other government entities such as the
National Transportation Safety Board (NTSB) or Congress.

The FAA SMS Committee, and if needed, the FAA SMS Executive Council, approves and
prioritizes FAA-level safety issues for safety risk assessment. Safety risk assessments
approved by the FAA SMS Committee and/or the FAA SMS Executive Council are routed to the
FAA SMS Committee-chartered Safety Collaboration Team (SCT) to perform the safety risk
assessments.

The organization that raised the safety issue is referred to as the Initiating Organization. The
Initiating Organization enters issue information into the Hazard Identification, Risk Management
& Tracking (HIRMT) tool prior to formally requesting an SRM Team at the FAA SMS Committee.
If the FAA SMS Committee (or FAA SMS Executive Council, if necessary) determines the need
for an FAA-level cross-LOB safety risk assessment, the Initiating Organization and the FAA
SMS Committee work together to identify the Office of Primary Responsibility (OPR). Table 1,
Roles and Responsibilities of Key Cross-LOB Safety Assessment FAA Stakeholders, contains
more information regarding the roles and responsibilities of the OPR, and Step 3 in the process
details the identification and selection of an OPR.

The FAA SRM process (current version of FAA Order 8040.4) is designed to ensure that
hazards are identified and the safety risk associated with those hazards is managed to
acceptable levels throughout the aerospace system. Therefore, the SRM process would be
used for FAA-level safety issues to identify hazards and mitigate to an acceptable level the
safety risk of cross-organizational issues that are found to exist as a result of incidents or
negative trends in the system. Issues that are not selected for assessment with FAA SMS
Committee involvement are still tracked in HIRMT and managed by the Initiating Organization,

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and it is expected that the organization would apply its own SRM processes to address the
issue.

2. Planned Changes

Chartered by the FAA SMS Committee, the SCT considers significant planned changes
affecting NAS operations for potential safety risk assessments. Examples of planned changes
include:
• Recommended or proposed aerospace system improvements, including new
technologies; and
• Impending or urgent changes to the aerospace system causing existing safety risk
controls to no longer be adequate.

To prevent these changes from introducing hazards and/or causing potential unacceptable
safety risk to the NAS, the FAA SMS Committee engages the SCT to conduct safety risk
assessments on the significant, cross-organizational planned changes, for which a decision is
yet to be made on funding or implementation. 2 The benefit of doing safety work such as this
early in the planning stages is that decision makers are made aware of potential hazards/safety
risk before they dedicate additional resources to moving further into planning and implementing
a change and any requisite mitigation strategies. The result should be more information for
decision making and more efficient use of resources.

The SCT manages safety risk assessments of these planned changes on behalf of the FAA
SMS Executive Council and the FAA SMS Committee.

Stakeholder Roles and Responsibilities


The aerospace system involves a complex interaction between different technical and
human-centered sub-systems which are operated by many different types of organizations or
stakeholders. A stakeholder is a group or individual that is affected by, or is in some way
accountable for, the outcome of an undertaking; a stakeholder can also be described as an
interested party having a right, share, or claim in a product or service or in its success in
possessing qualities that meet that party’s needs and/or expectations. Table 1, Roles and
Responsibilities of Key Cross-LOB Safety Risk Assessment FAA Stakeholders, details roles and
responsibilities of specific stakeholders in the FAA; more specific roles and responsibilities are
detailed within the document.

Table 1: Roles and Responsibilities of Key Cross-LOB Safety Risk Assessment FAA Stakeholders

Stakeholder Roles and Responsibilities


FAA SMS Executive • Sets the strategic direction for safety management, including SMS
Council and United States (U.S.) State Safety Program (SSP) implementation,
across the FAA
• Provides executive-level guidance and conflict resolution for FAA
safety management-related issues
• Meets at regular intervals to exchange safety information and address
safety issues

2In the Acquisition Management Process, this occurs prior to the Concept and Requirements Readiness
Decision.

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Stakeholder Roles and Responsibilities
• Resolves any issues that the FAA SMS Committee raises, which may
include disagreements or requests for additional resources related to
SRM activities
FAA SMS Committee • Reports to the FAA SMS Executive Council
• Provides assistance to FAA organizations regarding safety
management
• Meets at regular intervals and at the discretion of the FAA SMS
Committee Chair to exchange safety management information
• Approves, or otherwise addresses, FAA-level safety issues
recommended for safety risk assessment
• Recommends FAA-level safety issues to the FAA SMS Executive
Council for allocation of resources to conduct safety risk
assessments, when necessary
• Assigns an OPR for assessing and addressing cross-organizational
issues
• Approves the scope and overarching plan for FAA-level safety
assessments
• Resolves disagreements between FAA organizations regarding safety
management, including disagreements related to SRM
• Escalates disagreements that cannot be resolved at the FAA SMS
Committee level to the FAA SMS Executive Council
Safety Collaboration Team • Provides cross-organizational SRM consultation services to pre-
(SCT) decisional NAS change concepts for the benefit of FAA decision
makers and/or program office SRM
• Oversees the facilitation of subject matter experts that conduct SRM
on planned changes or FAA-level safety issues in accordance with
the current version of FAA Order 8040.4
• Provides periodic status updates regarding SCT activities to the FAA
SMS Committee
• Provides technical expertise for assessment of safety issues
(including FAA-level safety issues) when requested
Office of Accident • Manages the FAA SMS and its supporting policies, processes, and
Investigation and tools in support of the Associate Administrator for Aviation Safety
Prevention, Safety (AVS-1), the FAA SMS Executive Council, and the FAA SMS
Management and Research Committee
Planning Division • Chairs the FAA SMS Committee
(AVP-300) • Develops technical source materials and supporting safety
management guidance
• Manages and supports the Hazard Identification, Risk Management &
Tracking (HIRMT) tool
• Manages the identification of cross-organizational safety issues at the
FAA level on behalf of the FAA SMS Committee
• Coordinates safety risk assessment efforts for FAA-level safety
issues, tracks approved safety risk mitigations, and measures safety
performance for the FAA
• Uses HIRMT to create, track, and close issues; monitor the
implementation status of mitigations; and produce reports for FAA
management to facilitate communication and accountability of safety
issues
• Ensures that the FAA-level safety issue assessment activities are
managed through the SRM/Safety Assurance processes on behalf of
the FAA

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Stakeholder Roles and Responsibilities
• Provides assistance/expertise to FAA organizations regarding safety
risk management and use of HIRMT
Office of Primary • Serves as the organization that manages and tracks the issue or
Responsibility (OPR) change through closure (Note: There is only one OPR assigned to
each safety issue.)
• Leads and manages the safety risk assessment and presents findings
and recommendations to decision makers
• Identifies the appropriate management officials to accept safety risk
and approve mitigations
• Coordinates any necessary approvals and safety risk acceptance
decisions, and enters results and decisions into HIRMT 3
• Updates information in HIRMT, as necessary, to provide status based
on the monitoring plan
• Provides status updates to the FAA SMS Committee
• Includes two main roles —the OPR Manager and the OPR Point of
Contact (POC)
OPR Manager 4 • Accepts/rejects role as OPR on behalf of the responsible organization
• Confirms OPR POC
• Approves assessment scope, draft system analysis, and safety risk
acceptance plan for safety risk assessments (Note: this is completed
outside of HIRMT)
• Signs off on the Safety Risk Assessment Report (via signed memo
with Safety Risk Assessment Report attached) indicating that SRM
Team adhered to the process and the technical content is accurate
and valid
OPR Point of Contact • Leads the SRM Team to complete and document the safety risk
(POC) assessment effort
• Enters information into HIRMT
• Identifies an SRM Team Facilitator and SRM Team members (with
assistance from the FAA SMS Committee)
• Identifies the risk accepter and mitigation owners (with OPR Manager
assistance, as needed)
• Documents the scope of the assessment and drafts the system
analysis and safety risk acceptance plan
• Updates HIRMT after each SRM step
• Ensures that the SRM Team developed the Safety Risk Assessment
Report properly, systematically identified hazards, and assessed the
safety risk appropriately
• Works with the appropriate management official(s) to ensure that the
SRM Team proposed valid safety risk mitigations, which include risk
mitigation implementation and monitoring plans
• Acquires signatures for safety risk mitigation approvals and safety risk
acceptance, following existing organizational processes for approvals
and acceptances, as appropriate

3 The current version of the Guidance for Managing Aerospace System Level Safety Issues in HIRMT
contains further information regarding HIRMT roles and responsibilities.
4 The appropriate management official within the OPR selects the OPR Manager. In general, the OPR

Manager should be the decision maker within the OPR that has the biggest stake in the issue/change,
and he/she would be in the best position to address the issue or is most affected by the proposed
change. Existing organizational roles and responsibilities will likely help to determine the appropriate OPR
Manager.

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Stakeholder Roles and Responsibilities
• Uses the Process for Escalation of SRM-Related Issues (described
later in this document) to escalate the issue if any disagreements
among organizations related to the assessment occur before, during,
or after the SRM Team meets
Initiating Organization • Serves as the organization that identifies a safety issue and raises it
to the FAA SMS Committee for support to conduct a cross-LOB
safety risk assessment. In some cases, the Initiating Organization
becomes the OPR for the safety risk assessment. (Note:
organizations can establish SRM Teams without engaging the FAA
SMS Committee. However, the FAA SMS Committee is a resource to
facilitate the coordination of the assessment and the establishment of
an SRM Team, particularly for those that are cross-LOB.)
SRM Team • Comprises a diverse group of representatives, stakeholders, and
subject matter experts from the various organizations affected by the
safety issue or change 5
• Examines potential safety risk of the issue or change and the causes
of that risk
• Conducts SRM on the issue or change in accordance with the current
version of FAA Order 8040.4
• Determines the appropriate breadth and depth of the safety analysis
based on the presence of, or potential for, hazards and safety risk
• Objectively assesses the safety risk of the issue or change
• Documents the team’s safety findings in a Safety Risk Assessment
Report as an input to decision making
• Develops the Proposed Safety Risk Mitigations Addendum to attach
to the Safety Risk Assessment Report
SRM Team Observer • Attends meetings because they have particular knowledge or
experience related to the issue/change being assessed or they are
trying to gain experience with the SRM process
• Does not participate in SRM Team member discussions or decisions,
unless specifically called upon by the SRM Team to contribute
• Does not participate in Safety Risk Assessment Report reviews or
provide comments regarding the report
SRM Team Facilitator • Works with the OPR to help scope the safety risk assessment and
moderates SRM Team deliberations
• Requests briefings and collects all available and relevant safety
information regarding the issue or change, as necessary, before the
SRM Team convenes
• Provides all relevant information about the safety issue or change to
SRM Team members prior to the SRM Team kickoff meeting
• Notifies all identified SRM Team members of meetings and
coordinates logistics for the meetings
• Ensures the SRM Team complies with the SRM process
• Limits his or her influence on the safety risk assessment
• Guides participants in objectively examining and identifying potential
safety hazards and mitigating the safety risk associated with those
hazards
• Engages the team to develop a thorough safety risk assessment by
soliciting expert advice and building consensus whenever possible

5The SRM Team may include stakeholders external to the FAA. Step 7: Determine and Secure SRM
Team Members, provides more information regarding external stakeholders.

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Stakeholder Roles and Responsibilities
• Cultivates discussion among team members about potential hazards,
risks, and mitigations
• Performs or delegates the functions of timekeeper in order to manage
start times and breaks
• Coordinates review of Safety Risk Assessment Report and Proposed
Safety Risk Mitigations Addendum within SRM Team and delivers
final report and addendum to OPR
• Works with SCT Secretariat to coordinate peer review of Safety Risk
Assessment Report and Proposed Safety Risk Mitigations Addendum
within SCT Core membership
• Mediates and assists SRM Team members in working through
differences of opinion
• Remains neutral to the outcome
Technical Writer 6 • Records meeting notes
• Documents SRM Team findings and proposed safety risk mitigation
strategies
• Assists the SRM Team with writing the Safety Risk Assessment
Report and Proposed Safety Risk Mitigations Addendum
• Develops the necessary reports and communications materials to
deliver the results to management
• Assists Facilitation Team, as needed, during all phases of conducting
the safety risk assessment
Risk Accepter 7 • Provides signature to certify acknowledgement and acceptance of the
safety risk associated with the issue/change that is expected to
remain once mitigations or NAS changes are fully implemented
• Agrees to follow and execute a comprehensive monitoring plan to
verify the predicted residual safety risk
Risk Mitigation Implementer • Provides approval signature representing commitment to implement
the safety risk mitigations in accordance with the associated controls
identified in the Proposed Safety Risk Mitigations Addendum

The remainder of this document describes the process for coordinating cross-LOB safety risk
assessments for FAA-level safety issues and planned changes, which involve the FAA SMS
Committee and/or FAA SMS Executive Council.

6 The term Technical Writer does not imply that an OPR must use a job series 1083 employee to

complete these tasks. Instead, it refers to a person given the role of note taker and documenter.
7 The person authorized to accept risk on behalf of the organization varies based on the level of risk being

accepted. Refer to the Safety Risk Acceptance Criteria for Issues or Changes That Cross LOBs/Staff
Offices table in the current version of FAA Order 8040.4, Safety Risk Management Policy for more
information.

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Process for Coordinating Cross-LOB Safety Assessments
Figure 1, Process for Coordinating Cross-LOB Safety Risk Assessments, depicts the process
flow described in this document.

Trigger: Planned Trigger: FAA-level Request for Signed FAA


Change Safety Issue Approval of Proposed
Proposed Safety Risk
Issue Step 13: Obtain Approval of
Mitigations Briefing Mitigations
Summary Proposed Mitigations and Risk
Template Addendum
Document Acceptance if Needed (OPR with
Template help from FAA SMS Committee/
Step 1: Document Potential
Proposed Safety SCT as needed)
Issue/Change in HIRMT
Guidance for (Initiating Organization, with help Risk Mitigations HIRMT Updates
Managing from AVP-300 as needed) Addendum
Aerospace Signature Memo
System Level Template
Safety Issues
in HIRMT Proposed
Proposed Safety Step 12: Develop Proposed Safety Risk
Risk Mitigations Safety Risk Mitigations Addendum Mitigations
Request for Step 2: Request Cross-LOB Addendum (SRM Team/OPR) Addendum
Cross-LOB Safety Risk Assessment Team Template
SRM Team (Initiating Organization, with help
Briefing from AVP-300 as needed)
Template Safety Risk Final FAA
Assessment Step 11: Review and Finalize Safety Risk
Report Signature Safety Risk Assessment Report Assessment
LOB or S/O Safety Memo Template (OPR) Report
Management
Processes
Followed
FAA SRM HIRMT Updates
Decision to Guidance: The 5-
No Establish Cross-LOB Step Process
SRM Team
(FAA SMS Committee)
FAA Safety Risk
Assessment
OPR Request Report Draft FAA
Memo Template Template Safety Risk
Yes Assessment
Report
Comment
Step 3: Determine/Secure OPR Matrix
(FAA SMS Committee) Step 10: Conduct SRM
Template (SRM Facilitation Team)

Document in
Record of HIRMT
Comments and
Other Opinions
Step 4: Transfer HIRMT Template
Responsibilities to OPR OPR
(AVP-300) Acceptance
Documented Safety Risk
in HIRMT Assessment
Issue/Change
Summary Schedule Step 9: Develop Detailed Briefing
Briefing Template Template Schedule and Communicate with Package to
SRM Team (OPR, with help from SRM Team
SRM Team Facillitator as needed)
Step 5: Conduct Initial Planning
FAA SRM
(OPR, with help from SCT as
Process Briefing
needed)
Step 8: Ensure Management
Awareness of Team Composition
Resource (OPR/FAA SMS Committee
Request Memo Chair)
5M Model SRM Team
Template
Template Composition
Step 6: Establish Scope of Document to
Assessment, Draft System Step 7: Determine/Secure Team SCT/FAA SMS
Analysis & Risk Acceptance Plan SRM Team Members (OPR, with help from Committee Chair/
(OPR, with help from SCT as Composition SCT as needed) Appropriate
needed) Document Management
Approval for
No Template Official(s)
Assessment
Scope, Draft
System Analysis &
Risk Acceptance
Plan Template Approval of Yes
Scope, Draft System Analysis,
Risk Acceptance Plan
(OPR)

Figure 1: Process for Coordinating Cross-LOB Safety Risk Assessments

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Step 1: Document Potential Issue/Change in HIRMT
HIRMT is the FAA’s official tool for collecting, managing, and reporting on Aerospace System
Level (ASL) safety issues containing hazards and risk mitigations. A safety issue that meets one
or more of the following criteria is considered an ASL issue and must be reported in and
managed through HIRMT:

1. The safety issue is tracked and managed by the FAA SMS Committee;
2. The safety issue is present in the NAS 8, its safety risk has not been accepted, and it is
expected to have high risk (e.g., it is identified as a result of an accident or incident or it
is assumed to have high risk but an assessment has not been completed);
3. The safety issue has high risk and has a potentially systemic outcome (e.g., the outcome
crosses LOBs or the outcome impacts an industry segment rather than an individual
certificate holder); and/or
4. Any safety issue that an FAA organization’s management elects to track in HIRMT. 9

Since the FAA SMS Committee tracks and manages FAA-level safety issues and planned
changes (criterion #1 above), they are considered ASL issues. Therefore, HIRMT will be used to
document and track FAA-level safety issues and planned changes that are considered for
cross-LOB safety risk assessment by the FAA SMS Executive Council and/or the FAA SMS
Committee.

As stated in the Triggers for Cross-LOB Safety Risk Assessments section, the organization that
raised the safety issue is referred to as the Initiating Organization. In this step, the Initiating
Organization, with assistance from AVP-300 if necessary, enters a description for the required
fields of the potential FAA-level safety issue or planned change into HIRMT. 10 The Issue
Summary Document Template can be used to gather the issue information. Once the Initiating
Organization enters the information into HIRMT, it informs the FAA SMS Committee chair and
requests time to brief the issue to the FAA SMS Committee.

Step 2: Request Cross-LOB Safety Risk Assessment Team


In this step, the Initiating Organization that is requesting cross-organizational resources to
support an FAA-level SRM activity uses the Request for Cross-LOB SRM Team Briefing
Template to formally request an SRM Team at the FAA SMS Committee. The briefing should
include:
• Description of issue/change;
• List of stakeholders (internal and external to the FAA);
• Summary of safety assessments/analyses conducted to date including
o A description of the tools or methods that were used to identify and analyze the
issue, and
o Any other group(s) that worked on or is currently working on addressing the
issue;

8 Changes being processed through the NAS Change Proposal (NCP) may be considered to be present
in the NAS, if they are in the live test and evaluation phase.
9 The organization should consider the risk and visibility of a safety issue when determining if it should be

entered into HIRMT.


10 To become a user and be granted access to HIRMT, individuals are required to complete the HIRMT

user training. For more information regarding HIRMT and to obtain access to the tool, please refer to the
HIRMT site on the FAA intranet at https://hirmt.faa.gov or contact the HIRMT Help Desk at 9-natl-hirmt-
helpdesk@faa.gov.

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• Data/information that is available to support a safety assessment (e.g., accidents and/or
incidents directly related to the issue);
• Preliminary safety risk assessment and evaluation of impact of the issue/change on the
aerospace system;
• Request for resources (including specific expertise necessary to conduct the SRM
activity);
• Proposed milestones and schedule for the SRM Team;
• Any other information that is pertinent and would help decision makers to decide
whether to sponsor an FAA-level cross-LOB SRM activity; and
• Next steps, assuming approval (including any further approvals necessary (e.g., FAA
SMS Executive Council)).

The Initiating Organization uploads the briefing template into the HIRMT tool as supporting
documentation and works with AVP-300 to be added to the agenda of an upcoming FAA SMS
Committee meeting to present the briefing. The FAA SMS Committee determines whether or
not to provide resources to establish an FAA-level SRM Team. If the FAA SMS Committee
decides resources should be provided, it will task the SCT with establishing an SRM Team.

Step 3: Determine and Secure OPR


Once decision makers approve the establishment of an FAA-level SRM Team, the next step is
to determine and secure the appropriate OPR that will be responsible for managing the
assessment activities on behalf of the FAA. In general, the candidate OPR would typically be
the organization that has the largest stake in the issue or change and/or is in the best position to
address the issue.

The FAA SMS Committee, with assistance from the Initiating Organization, identifies the
appropriate candidate OPR for FAA-level safety issues and planned changes. First, the FAA
SMS Committee Chair informally reaches out to the appropriate manager in the candidate OPR,
provides an overview of the project and OPR roles and responsibilities, achieves OPR interest
(ideally), and provides notice that a formal request memo will be sent to OPR management. The
FAA SMS Committee Chair may delegate this initial contact to the appropriate manager in the
Initiating Organization, SCT Leadership, or another member of the FAA SMS Committee.

Once initial contact with the candidate OPR has been made, SCT Leadership uses the OPR
Request Memo Template to formally request confirmation of the OPR, the OPR Manager, and
the OPR POC.

The FAA SMS Committee also tasks the SCT to manage the safety risk assessment of the
FAA-level cross-LOB safety issue. SCT Leadership reaches out to the OPR POC to offer
assistance with the SRM process and HIRMT.

Step 4: Transfer HIRMT Responsibilities to OPR


In this step, AVP-300 documents the OPR role and the safety issue within HIRMT and routes
the HIRMT safety issue file to the pre-determined OPR organization for acceptance. AVP-300
will include a copy of the accepted OPR request template as documentation. At this point,
HIRMT responsibilities have been transferred to and accepted by the OPR within HIRMT. The
OPR is now responsible for reporting the status of the identified safety issue in HIRMT,
throughout the lifecycle of the issue.

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Step 5: Conduct Initial Planning
Initial Planning is necessary to document what the SRM Team is trying to accomplish and
define a timeline for the assessment so that a high-level plan can be communicated to
stakeholders.

In this step, the OPR POC, with assistance from the SCT if needed, documents a brief
description of the issue/change, describes the preliminary scope of the assessment, and
identifies stakeholders and participating organizations. The OPR POC develops a schedule that
includes high-level milestones for planning, conducting, documenting, and obtaining approvals
for the safety risk assessment and uses the Issue/Change Summary Briefing Template to
document this information. The template is used as a summary outreach briefing when
requesting participation on the SRM Team.

The OPR POC, with assistance from the SCT, then identifies the SRM Team Facilitator(s) and
Technical Writer.

Step 6: Establish Scope and Draft System Analysis and Risk Acceptance Plan
The OPR POC (with assistance from the SCT, and/or the SRM Team Facilitator, as needed)
documents the scope of the assessment and drafts the system analysis and risk acceptance
plan. The OPR POC (with participation from the SCT, as needed) meets with the SRM Team
Facilitator to plan the SRM Team meetings. Preparation meetings are used to define:

• The proposed issue/change;


• The draft system state(s) in which the issue/change is/will be operational;
• Assumptions (not existing controls) that may influence the analysis;
• The components of the 5M Model;
• Sources of relevant data/information related to the issue/change; and
• A draft safety risk acceptance plan.11

The purpose of the system analysis step is to understand and describe the system to the extent
necessary to identify potential hazards. It is a comprehensive approach to examining an issue
or change in terms of what it affects and what is affected by the issue or change. The OPR POC
can use the 5M Model to capture the information needed to bound and describe the system and
aid in the hazard identification process. When defining the components of the 5M Model (see
5M Model Template), the OPR adheres to the following guidelines:

• Mission: Define the purpose of the NAS change proposal or system/operation being
assessed, in detail. There should be agreement on the language for the issue or change
that the SRM Team is tasked to assess. Ensure that the language is unambiguous,
concise, and clearly reflective of the issue or change.
• huMan: Define the human operators, maintainers, and affected stakeholders. First,
identify organizations that are affected by the issue or change, and then proceed to
identify subject matter experts from each of those organizations. There may be times
when it is not feasible to obtain participation from some or part of the identified
stakeholders. In those cases, other avenues of collecting input or data may be used,
such as telephone interviews, worksheets, surveys, etc.

11 The draft risk acceptance plan must meet the risk acceptance criteria in FAA Order 8040.4.

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• Machine: Define the equipment used in the system that is related to the issue or
change, including hardware, firmware, software, human-to-system interfaces, system-to-
system interfaces, and avionics.
• Management: Define the documents that are relevant to the issue or change (e.g.,
directives, policies, Standard Operating Procedures, Letters of Agreement).
• Media: Define the environment in which the system is operated and maintained (i.e., the
elements of the NAS that are affected by the issue or change).

The safety risk acceptance plan includes the safety risk acceptance criteria (such as a risk
matrix and the severity and likelihood definitions that will be used), designation of authority to
make the required safety risk decisions involved, and assignment of the relevant decision
makers. FAA Order 8040.4 allows flexibility to account for existing LOB/Staff Office processes
and structure. Therefore, the OPR can choose to use criteria other than the severity and
likelihood definitions and risk matrix in 8040.4. The draft risk acceptance plan specifically
describes the criteria the team will use to determine risk acceptability, as well as the levels of
management that are expected to accept the risk.

After the assessment scope, draft system analysis, and draft safety risk acceptance plan are
complete, the OPR POC forwards them to the OPR Manager for review and approval, as
applicable (see Approval of Assessment Scope, Draft System Analysis and Risk Acceptance
Plan Briefing Template). The OPR documents that the assessment scope, draft system
analysis, draft safety risk acceptance plan, and approval are complete by uploading the
completed templates to the safety issue record in HIRMT noting OPR Manager’s approval.

Once the OPR Manager’s acceptance is obtained, the OPR POC and SRM Team Facilitator
coordinate to develop a briefing package to provide to the SRM Team members (see Step 9).

Step 7: Determine and Secure SRM Team Members


SRM Teams should include representatives from the various organizations affected by the issue
or change. It is important that the team be diverse and include stakeholders and experts who
are expected to be involved in various capacities throughout the SRM process, while
maintaining the right amount of participants to ensure the team can be efficiently managed.
Team members should be given authority by their management to speak on behalf of their
organization.

The OPR POC (with assistance from the SCT, if needed) identifies the skills and expertise
required to conduct the safety risk assessment. Though the size and makeup of the cross-LOB
SRM Team will vary according to the type and complexity of the issue/change, the following
types of experts should be considered for involvement on the team (note that this list is not all-
inclusive):

• Employees directly responsible for the issue or change being analyzed/assessed;


• Employees with current knowledge of and experience or operational proficiency with the
issue or change;
• Hardware or software engineering or automation experts to provide knowledge on
equipment performance;
• Air traffic controllers and pilots;
• SRM specialist (facilitator) to guide the methodology;
• Human factors specialist;
• Medical specialist;

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• Quality Assurance expert to help ensure the safety performance measures are
auditable/measurable; and
• Employees skilled in collecting and analyzing hazard and error data and using
specialized tools and techniques (e.g., operations research, data, human factors, failure
mode analysis).

As stated previously, in order to conduct a thorough assessment, it is important to have all


necessary expertise on the SRM Team. At times, this means that the FAA might request
participation from entities outside the agency, including product/service provider organizations
for which the FAA has oversight responsibility. In such cases, the OPR should consult with the
appropriate official or organization in the FAA regarding data protection and Freedom of
Information Act (FOIA) requirements. This is especially advisable if the SRM Team will have
access to data/information that is not publicly available. In addition, the OPR should confer with
the FAA Office of the Chief Counsel (AGC) to avoid any potential legal/statutory issues. Note
that coordinating participation from external stakeholders may require additional time and
documentation.

To ensure the quality of participation from team members, it is important that all team members
have a basic understanding of SRM prior to commencing the SRM Team meetings. The OPR
POC verifies that all FAA team members have reviewed the FAA SRM Overview Briefing
(FAA27000023) in the electronic Learning Management System (eLMS) as a prerequisite for
participating on the team. A similar overview should be provided to any external team
participants.

The OPR POC determines expectations of team members regarding level of effort required to
support the team. Expectations include:

• Face-to-face meetings: Estimate how many meetings the SRM Team is expected to
attend in person, the location(s) of the meetings, and the duration of the meetings
required to accomplish the team objectives.
• Teleconferences: Estimate the frequency of expected teleconferences, duration of the
calls, and timeframe they are expected to occur (e.g., every two weeks for 1 hour, June-
October 2018).
• Work outside of meetings: Estimate the type (e.g., collection of data) and amount of
work that the team member will be expected to complete in between the meetings and
teleconferences (e.g., It is anticipated that the team member will spend 10 hours per
week devoted to this activity outside of the face-to-face meetings and teleconferences.).

In addition to expectations about the level of effort, the OPR POC identifies any other factors
that organizations may consider when selecting team members and specific participant roles,
which may include:

• The team member’s ability to represent his/her organization’s perspective;


• The team member’s objectivity sufficient to consider safety risk outside of his/her
LOB/Staff Office;
• The team member’s ability to consider safety risk at a LOB/Staff Office level and system
level;
• The impact on the organization of a team member being away from normal duties;
• The team member’s ability to interface with other organizations; and
• The balance of personality traits of all team members.

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Next, the OPR POC reaches out to existing contacts within organizations (e.g., Aviation Safety
Safety Management System (AVSSMS) Coordination Group, FAA SMS Committee), provides
the contacts with an overview of the project, and requests recommendations for people who
might be a good fit for the team. The outcome of this coordination is a list of possible candidates
for each team member position.

The OPR POC then informally reaches out to the candidates and provides them with an
overview of the project and expectations of team members. If the candidate is interested in
participating on the team, the OPR POC works with the candidate to informally reach out to the
candidate’s manager, provide an overview of the project, and discuss expectations of the team
member and the team member’s management. If the manager agrees that the candidate should
participate on the team, the OPR POC notifies the manager that a formal request memo will be
sent to acquire the team member’s participation.

The OPR POC formally requests team member participation by emailing a completed Resource
Request Memo Template to managers of all recruited team members. 12 The OPR POC then fills
out the SRM Team Composition document that contains names and experience levels of SRM
Team members. The OPR POC then sends the SRM Team Composition document to the SCT,
the FAA SMS Committee Chair, and appropriate managers within the stakeholder
organizations. The OPR POC uploads the completed SRM Team Composition document in
HIRMT for documentation purposes.

Step 8: Ensure Management Awareness of Team Membership


It is important to ensure that LOB/Staff Office leadership is aware of who in the organization is
participating in the safety risk assessment.

For FAA-level safety issues and planned changes, the FAA SMS Committee Chair presents
high-level milestones, an associated schedule, and the SRM Team Composition document to
the FAA SMS Executive Council for awareness.

Step 9: Develop Detailed Schedule and Communicate with SRM Team


Once the SRM Team members are secured, the OPR POC (with assistance from the SRM
Team Facilitator) develops a detailed schedule using the Safety Risk Assessment Schedule
Template.

The OPR POC and the SRM Team Facilitator meet to prepare and develop a briefing package
for the SRM Team kickoff meeting. The briefing package includes:

• A briefing on the agenda for the meeting;


• A summary of the goals and objectives for the SRM Team;
• An overview of the FAA SRM Process (see FAA SRM Process Briefing);
• SRM Team ground rules;
• The assessment method(s) by which the SRM Team will identify hazards; and
• A draft of the system analysis and a description of the safety issue or change proposal, if
available (from Step 6).

12 For external stakeholders, the OPR POC uses the External Stakeholder Resource Request Template.

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The SRM Team Facilitator provides the briefing package, in addition to the meeting invitation
and directions to the meeting, to the SRM Team sufficiently in advance of the initial meeting.

Step 10: Conduct SRM


The SRM Team conducts the safety risk assessment in accordance with the current version of
FAA Order 8040.4 by following the 5-Step SRM Process (see FAA SRM Guidance: The 5-Step
Process).

HIRMT is intended to be used as a process tool to guide teams through the SRM steps and to
aid in safety risk assessment documentation as they progress through the SRM process. As the
team progresses through SRM, the OPR POC enters information and uploads relevant
supporting documentation into HIRMT after each SRM step.

Typically, the SRM Team completes all five SRM steps while convened together for a few days
to conduct the safety risk assessment. However, the results are organized and delivered to
management in two separate documents. SRM steps one through four (System Analysis;
Identify Hazards; Analyze Safety Risk; Assess Safety Risk) are delivered in a Safety Risk
Assessment Report and approved by management prior to delivering the results of SRM step
five (Control Safety Risk) in a Proposed Safety Risk Mitigations Addendum. The reason for two
separate documents is so management can focus on first agreeing that the risk was
characterized and assessed appropriately. After agreement on the evaluation of risk,
management can then focus on whether the proposed mitigations are appropriate.

In this step, the SRM Team, with assistance from the SRM Team Facilitator and Technical
Writer, produces the draft Safety Risk Assessment Report (see FAA Safety Risk Assessment
Report Template). The results of the safety risk assessment should be presented to the team to
verify that the SRM Team members’ discussions have been correctly recorded.

Once the draft Safety Risk Assessment Report is complete, the SRM Team reviews it and
reaches concurrence (desired) on the results. SRM Team members provide comments on the
draft Safety Risk Assessment Report to the OPR POC using the Comment Matrix Template.
The OPR POC leads a sub-team to resolve team comments. Comments and resolutions are
provided back to the commenters.

The SRM Team should strive to reach consensus, but there may be instances in which not all
SRM Team members agree on the results of the safety risk assessment. In those cases, the
team documents the results of the assessment, records the comments and other opinions, and
delivers the results to the decision maker. Records of comments and other opinions are
appended to the Safety Risk Assessment Report, if necessary, using the Record of Comments
and Other Opinions Template.

The SRM Team Facilitator mediates and assists SRM Team members in working through
differences of opinion. He or she should be able to remain neutral during these discussions, and
recognize, acknowledge, and use differences of opinion to help the SRM Team consider
different points of view.

Step 11: Review and Finalize Safety Risk Assessment Report


Once the OPR POC deems the Safety Risk Assessment Report complete, a peer review is
conducted to assure the report is complete and accurate and that the appropriate process was
followed during the development of the report. Individuals, other than those who have

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conducted the SRM activity, should perform the peer reviews. These individuals should have
similar expertise as the SRM Team members.

Following peer review, the SCT designates an FAA senior technical expert(s) to review the draft
Safety Risk Assessment Report for completeness and accuracy and to assure that the
appropriate process was followed. 13 A statement is added to the Safety Risk Assessment
Report to attest that a peer review was conducted. For example, “[insert name of technical
reviewer(s)] reviewed the Safety Risk Assessment Report and concurs that the appropriate
process was followed and the report appears to be complete and accurate.”

Approval/Finalization of Safety Risk Assessment Report

After the peer review is conducted, the OPR POC approves the Safety Risk Assessment
Report. 14 Safety Risk Assessment Report approval indicates that the report was developed
properly, that hazards were systematically identified, and that safety risk was appropriately
assessed. Safety Risk Assessment Report approval does not constitute acceptance of the
safety risk associated with the issue/change or approval to implement the mitigations/change.

Approval signatures are not part of the Safety Risk Assessment Report. Instead, the signatures
are recorded separately on a memo with the Safety Risk Assessment Report attached. To
finalize the Safety Risk Assessment Report, the OPR Manager signs the memo accompanying
it, indicating agreement that the findings are valid and accurate and the process was followed
(see Safety Risk Assessment Report Signature Memo Template). The OPR POC uploads the
Safety Risk Assessment Report and applicable signature pages into HIRMT for documentation
purposes.

Step 12: Develop Proposed Safety Risk Mitigations Addendum


After the Safety Risk Assessment Report is approved and applicable signatures are obtained,
the SRM Team finalizes and delivers the proposed safety risk mitigations, with accompanying
implementation and monitoring plan, to be attached to the Safety Risk Assessment Report as
an addendum (see Proposed Safety Risk Mitigations Addendum Template). For efficiency, the
SRM Team might develop, document, and finalize the proposed safety risk mitigations
concurrently with Safety Risk Assessment Report development; however, the addendum is
delivered to decision makers separately to ensure that the assessment is reviewed and
approved independently from the proposed safety risk mitigations.

Once the SRM Team finalizes the Proposed Safety Risk Mitigations Addendum, the OPR
forwards the addendum to the appropriate management official(s) to confirm that valid safety
mitigations were proposed, and that an effective implementation and monitoring plan was
prepared (see Step 13).

Step 13: Obtain Approval of Proposed Mitigations/Risk Acceptance


The OPR determines who needs to approve the mitigations and accept safety risk. If the OPR
cannot make that determination, the OPR works with the FAA SMS Committee and/or the SCT
to determine the appropriate management official(s) to approve mitigations or accept safety risk.

13 The FAA SMS Committee acknowledges that affected stakeholders may require an independent peer

review within their respective organizations.


14 The FAA SMS Committee acknowledges that affected stakeholders may require additional approvals

based on their organizational requirements. For example, in the ATO, the ATO Chief Safety Engineer
would also approve the Safety Risk Assessment Report.

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If there is disagreement with the OPR regarding mitigations or safety risk acceptance, then the
item is raised to the FAA SMS Committee. If the FAA SMS Committee cannot resolve the
disagreement, it is then elevated to the FAA SMS Executive Council for decision.

The OPR POC is responsible for coordinating mitigation approvals and safety risk acceptance.
The OPR POC briefs the appropriate management official(s) for the Risk Accepter and Risk
Mitigation Implementer(s) to request approval of the proposed safety mitigations and safety risk
approvals (see Request for Approval of Proposed Mitigations Briefing Template).

The OPR POC then obtains the appropriate signatures for each mitigation and acceptance of
safety risk by the appropriate organizations on a memo that accompanies the final Safety Risk
Assessment Report and Proposed Safety Risk Mitigations Addendum (see Proposed Safety
Risk Mitigations Addendum Signature Memo Template). By signing the memo, the Risk
Accepter certifies acknowledgment of and acceptance of the safety risk associated with the
issue/change that is expected to remain once the safety risk mitigations and/or change(s) are
implemented. The Risk Accepter’s signature also indicates a commitment to follow the
documented monitoring plan to verify the predicted residual safety risk. Signature by the Risk
Mitigation Implementer(s) indicates commitment to implement the safety risk mitigations/controls
in accordance with the associated Proposed Safety Risk Mitigations Addendum.

Once approvals and signatures are obtained, the OPR POC uploads the templates and
applicable signatures into HIRMT for documentation purposes. Note: if there is disagreement on
the mitigations or the responsibility for implementing them, the issue can be escalated according
to the process outlined in the following section, Process for Escalation of SRM-Related Issues.

Process for Escalation of SRM-Related Issues


Chapter 2, Section 1.j of the current version of FAA Order 8040.4, Safety Risk Management
Policy, states:

A safety issue may affect multiple LOBs and/or Staff Offices. Under such circumstances,
all affected FAA organizations must be part of the process. Effective SRM requires early
and ongoing involvement by appropriate members of all affected FAA organizations. In the
event that a disagreement arises among FAA organizations regarding SRM that cannot be
resolved, the issue should be raised for resolution to the FAA SMS Committee.

Based on this requirement in the policy, the following process was developed to escalate an
issue related to SRM to the appropriate levels of FAA and/or LOB/Staff Office management.
This process can be used for issues with SRM sponsored by the FAA SMS Committee or SRM
conducted by organizations independent of the FAA SMS Committee, as long as the issue
meets the criteria in Step 1.

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Figure 2: Possible Steps When Escalating SRM-Related Issues

Step 1: OPR Determines If Issue Meets Escalation Criteria


If there are any disagreements among organizations related to the safety risk assessment
before, during, or after the SRM Team meetings, the OPR POC should first determine if the
issue should be elevated to the FAA SMS Committee. All attempts should be made to resolve
the issue at the OPR/LOB level; however, there may be times when it needs to be escalated. In
order to be escalated, the issue needs to meet all four of the following criteria:

1. Crosses FAA organizations;


2. Contains hazards that are high risk, are medium risk with uncertainty about the risk, or
are based on numerous assumptions;
3. Is an active issue (e.g., awaiting response from product/service provider; awaiting results
of investigation; gathering further information through an FAA-sponsored study); and
4. Has some disagreement surrounding it that is causing the issue to remain unresolved.
Some examples are:

• Disagreement on mitigations
• Failure to implement mitigations
• Disagreement on the process or methodology used
• Disagreement on safety risk assessment
• Disagreement as to whether to apply resources
• Disagreement over ownership of hazard and/or controls

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Step 2: OPR Submits Issue to FAA SMS Committee Chair
If the issue meets the four criteria in Step 1, the OPR POC works with his/her representative on
the FAA SMS Committee to complete the Safety Issue Escalation Template, which is submitted
to the FAA SMS Committee Chair. For each new issue submitted, the FAA SMS Committee
Chair reviews the submittal to ensure that it meets the minimum escalation criteria.

Step 3: FAA SMS Committee Reviews/Resolves


The FAA SMS Committee Chair brings the issue to the attention of the FAA SMS Committee.
Depending on the urgency of the issue, this can be done at a regularly scheduled FAA SMS
Committee meeting or at a special meeting called to discuss the issue.

The OPR POC works with his/her representative on the FAA SMS Committee and the FAA
SMS Committee Chair to make sure that the right subject matter experts are brought in for the
discussions with management if more information is needed on a particular issue. The FAA
SMS Committee discusses the submission with the appropriate experts within the LOBs/Staff
Offices to assist in resolving the issue. The FAA SMS Committee decides whether the
disagreement can be resolved at the FAA SMS Committee level or if it needs to be escalated to
the FAA SMS Executive Council. The FAA SMS Committee makes every attempt to resolve the
issue. If the OPR is not present at the meeting, the FAA SMS Committee Chair notifies the OPR
POC of the resolution or decision to escalate further.

Step 4: FAA SMS Executive Council Reviews/Resolves


If the FAA SMS Committee cannot reach a resolution, the FAA SMS Committee Chair raises the
unresolved issue to the FAA SMS Executive Council for resolution. Depending on the urgency
of the issue, this can be done at a regularly scheduled FAA SMS Executive Council meeting or
at a special meeting called to discuss the issue.

The FAA SMS Committee Chair ensures that the LOBs/Staff Offices involved provide
appropriate subject matter experts needed for discussions at the FAA SMS Executive Council
meeting. The FAA SMS Committee Chair communicates the results of the FAA SMS Executive
Council meeting with the FAA SMS Committee members and OPR, who in turn share the
information with their organizations.

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