Chapter 13- SMS records management

 1 Definitions
 2 Purpose
 3 SMS Documentation
 4 Documentation Control Procedures
 5 Safety Records

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.