The FAA’s latest oversight initiative, the Safety Assurance System (SAS), is a risk-based system used for certificate issuance, surveillance, and management for Part 121, 135, and 145 applicants and certificate holders.
How does SAS impact your organization? What do you need to know to “comply” with SAS?
SAS involves six Safety Attributes. They are, as described by the FAA:
• Responsibility: A clearly identifiable, qualified, and knowledgeable individual who is accountable for management of activities and their ultimate accomplishment.
• Authority: A clearly identifiable, qualified, and knowledgeable individual who can direct, control, or change procedures and make key decisions.
• Procedures: Documented methods to carry out activities that translate the “what” into the “how”.
• Controls: Parts of the system, including hardware, software, special procedures, checklists, and supervisory practices designed to keep processes on track to achieve attended results.
• Process Measurement: The certificate holder’s process to measure and assess its processes to identify and/or correct problems or potential problems.
• Interfaces: The certificate holder identifies, documents, and has a method to evaluate the impact of changes on related processes.
SAS considers certificate holders of similar capabilities and authorizations as “Peer Groups”. For example, Part 135 operators will be Peer Group 135B, 135C, etc., depending on whether your certificate is a 9 or less or 10 or more.
Each Peer Group is given a Master List of Functions (MLF), which identifies the critical tasks, as determined by the FAA, for that type of organization.
The MLF for your Peer Group is basically your cheat sheet to successful SAS’ing. Take a look at the tasks identified on the MLF and consider the six Safety Attributes for each of those activities.
Some inspectors drop off a giant stack of DCTs for an operator and request the operator complete them. Give yourself plenty of time for this task. Other inspectors give the operator a few DCTs at a time.
There are a couple of ways to approach the DCTs. One is to do a complete re-write of your manuals, identifying the MLF tasks and addressing each of the six Safety Attributes. I only recommend this route if you are already planning a major overhaul of your manuals. Otherwise, you can probably identify many of the Safety Attributes for MLF tasks in your existing manuals – even if worded slightly differently – and provide references for those sections. If you have a mature, functioning SMS, the SMS likely covers some of the process measurement, control, and interface items.
SAS is not a passing fad within in the FAA. It is here to stay. The agency recently launched the SAS Portal, through which they intend for operators to post manuals for their inspectors, inspectors to conduct DCTs for operators, and both parties to complete other general SAS-related tasks.
If you haven’t been handed a bunch of DCTs yet, it’s only a matter of time. When the inspector drops an encyclopedia-sized batch of documents on your desk, don’t panic but be prepared for some work. You’ve just been SAS’d.