Why Policies and Procedures Matter

Many smaller organizations are not concerned with identifying their processes or documenting procedures. Policies are easy; procedures, not so much. In fact it’s not uncommon to find a Part 135 operator’s General Operations Manual (GOM) or General Maintenance Manual (GMM) full of policy statements, but lacking in clearly defined procedures. This might work as long as the organization or department remains small and has no turnover. But as soon as growth occurs or key personnel leave, tribal knowledge is lost, and the absence of documented procedures becomes a latent condition that can contribute to an aircraft incident or accident.

This hazardous mindset is fueled by the common perception that documented policies and standard operating procedures (SOPs) are merely stagnant references in seldom-used documents, which underestimates their importance. To understand their importance, policies should be seen as controls and procedures as essential Safety Attributes. These are qualities of a properly designed system, based on system safety principles.

Processes, Policies, and Procedures Defined

Processes exist within various functional areas (FAs) of an organization. For example, in the functional area of Flight Operations, Training of Flight Crewmembers is a process; so is Flight Crewmember Flight-Duty-Rest Time. Likewise, in the FA of Technical Operations (aka Maintenance), processes include Maintenance Planning and Monitoring, Maintenance Tools & Parts Control, and Maintenance Quality Assurance, among others. Processes include the programs, actions, and specific activities performed by departments within each functional area that support the organization’s aviation system.

Policies contain high-level principles or requirements that each department within the organization must follow, as set forth by management. When these policies pertain to safety-critical operations, they are considered risk controls in the SMS.

Procedures should exist within each process to ensure successful process outputs. FAA defines procedures as: “Methods or practices that include checks and restraints that are written or unwritten, regulatory or nonregulatory, designed into a process that a certificate holder uses to accomplish a desired result.” Note that this definition includes ‘unwritten’ for the benefit of very small, single-pilot operators. For all but the smallest certificate holders, procedures must be documented to assure their consistent application over time.

Why They Matter

Documented processes, policies, and procedures support the System Analysis requirement of Part 5 to support hazard identification. They also serve as risk controls for safety-critical activities in flight operations, cabin operations, maintenance, ground support, and other functional areas. Well-defined policies and procedures mitigate the risk associated with various hazards by reducing the likelihood that these hazards will be realized as unwanted events.

Supervisors, key 119 managers, and executives/business owners cannot effectively understand the inner workings of each functional area without a clear view of the policies and procedures that guide front-line staff in performing their duties. What’s more, procedures are one of seven safety attributes that form the basis of FAA’s Safety Assurance System (SAS) and are used by inspectors to evaluate how effectively a certificate holder (such as a Part 135 operator or Part 145 repair station) manages risk and ensures repeatable safety performance. As such, documented procedures are viewed as a “safety benchmark” and evidence of a company’s commitment to an effective risk compliance management system.

Steps to Improvement

Organizations seeking more robust policies and procedures can begin by conducting informal internal assessments using FAA’s SAS Data Collection Tools (DCTs). If current documentation is inadequate, key 119 managers should begin by prioritizing safety-critical operations and identifying where essential risk controls and other safety attributes are missing. SOPs in flight ops, critical maintenance procedures (RIIs), and ground support activities such as fueling and ground de-icing should be at the top of the list. They will also need to assess whether they have sufficient internal expertise and resources to lead the documentation effort. DCTs are not easy to interpret, but they provide the necessary guidance to help your operation achieve the highest level of safety.

The next step is to determine monitoring capabilities. Monitoring of operational processes is required by 14CFR Part 5, Subpart D. Are policies, procedures, and processes being followed and used in daily operations? Are they incorporated into training curricula for new hires? Do they factor into organizational decision-making and strategic planning efforts? Monitoring should answer these questions. Are policies and procedures being examined during auditing of operational processes/systems and internal evaluations? If an SMS report is received of a safety-critical policy or procedure not being followed, investigation is required under Part 5 §5.71(a)(6).

Developing new procedures or updating existing policies or procedures should be treated as a revision of existing systems under § 5.51(b).  This requires application of the Safety Risk Management (SRM) process under Part 5. The SRM process helps with a clear understanding of the risks (i.e., unwanted events) that various controls are designed to mitigate. Having this insight is necessary to generate justifiable risk assessments, understand the effectiveness of current compliance programs, and highlight opportunities for improvement.

Lastly, organizations should examine how they convey new policies and procedures, including explanations of why safety procedures are introduced or changed in accordance with §5.93(d). This “why” should include a brief discussion of identified hazards and the risk(s) or unwanted event(s) the new or changed safety procedures are designed to mitigate.

Robust policies and procedures are essential to effective aviation risk management.  By improving their manual system with these and other safety attributes, aviation organizations can enhance the effectiveness of their regulatory compliance and safety risk management efforts. They can also improve business performance by ensuring successful process outputs.

For busy managers, this means less crisis management and fewer “fires to put out”. I should know, having spent almost 20 years as Director of Operations for a Part 121/135 cargo carrier with high turnover of young pilots, WWII-era large aircraft, and all-weather scheduled operations…

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