Published By: Transport Canada Civil Aviation
Published By: Transport Canada Civil Aviation
*TP14343E*
(revised 06/2005)
This Implementation Procedures Guide has been developed to assist organizations with the implementation of
their Safety Management System (SMS). The guide is designed to address a phased implementation approach
and is based on the issuance of Exemptions. The phased approach will allow organizations the time they need to
implement safety management in a planned, systematic way. It will also allow Transport Canada civil aviation safety
inspectors a means to effectively manage the workload associated with this program.
This guide will also provide information to assist organizations with the selection of an accountable executive.
Not all organizations are required to implement safety management systems at the same time. Organizations that
are subject to SMS regulations at a later date are encouraged to begin work on their programs early. Transport
Canada will assist organizations wherever possible, however, the priority will be directed to organizations that are
required through regulatory amendments, to implement a safety management system.
1.1 Purpose
This implementation procedures guide has been developed with a dual purpose, the first is to provide information to Air
Operators and Approved Maintenance Organizations (AMO) who are required to implement a Safety Management System
(SMS) and the second is to provide information that will assist those organizations with the selection and appointment of
an accountable executive.
The guide will offer information on the conduct of a gap analysis and creation of a project plan. It will also expand on
Transport Canada’s phased-in approach for SMS implementation through the issuance of exemptions. Several forms and
examples are also included and can be used or amended to suit the needs of individual organizations.
This guide is intended as information only, if there is a discrepancy between this guide and the applicable regulations,
standards or exemption, the regulation, standard or exemption will take precedence.
1.2 Background
In Flight 2005: A Civil Aviation Safety Framework for Canada, Transport Canada committed to the implementation of
safety management systems in civil aviation organizations. Safety management is a principal element of a sound aviation
management program and a prime factor in the achievement of the goals set out in Flight 2005: the reduction of accidents
and incidents and an increased level of public confidence in Canada’s air transportation system. The aim is to improve safety
through proactive management rather than reactive compliance with regulatory requirements.
Transport Canada, through the Canadian Aviation Regulatory Advisory Council (CARAC), has developed a series of rule
changes to introduce the regulatory requirements for SMS in civil aviation organizations. These rules will be published in the
Canada Gazette II in a staggered fashion. Rules affecting certificate holders in Subpart 73 of Part V and Subpart 705 of Part
VII are expected to come into force in 2005. The remaining rules for Part IV, V and Part VII are expected to come into force
in 2007. This guide will provide information for the implementation of all the proposed SMS regulations.
Safety management involves organizational as well as cultural change. Transport Canada believes that a phased-in approach to
SMS implementation is appropriate, providing a manageable series of steps for organizations to follow. Four implementation
phases have been identified; each phase involves the introduction of specific SMS components and elements. Exemptions will
be issued to permit the phased implementation approach.
As you read this guide it is important to remember that the implementation of SMS depends on the date the regulations
come into force. The exemption and the four implementation phases are all predicated on the date of publication of the
regulations. Please refer to the Regulatory Affairs website http://tcinfo/CivilAviation/RegServ/Affairs/menu.htm for further
information on when specific regulations will come into force.
Organizations applying for an Air Operator or AMO Certificate on or after the date the SMS regulations come into force
must incorporate all the SMS components and elements as part of their initial application for certification. Existing certificate
holders or new entrants, whose application is dated and accepted by Transport Canada prior to the date the SMS regulations
come into force, will have the opportunity to utilize the exemption.
Post certification audits for new entrants will be scheduled by the applicable Transport Canada Centre/Office of Primary
Interest and will include an assessment of the SMS.
Transport Canada has developed a SMS framework that is outlined in Table A. This framework follows the same structure
as the Transport Canada SMS model, previously published in TP 13881 E. The framework lists six components and
corresponding elements.
Table A – This table is included for information purposes and as a reference for Phases 1 through 4.
Table A - SMS Framework
Component Element Phase
Safety Management System Compliance Document, Gap Analysis, Project Plan 1
1. Safety Management Plan 1.1 Safety Policy 2
1.2 Non-Punitive Reporting Policy 2
1.3 Roles, Responsibilities & Employee Involvement 2
1.4 Communication 2
1.5 Safety Planning, Objectives and Goals 2
1.6 Performance Measurement 2
1.7 Management Review 2
2. Document Management 2.1 Identification and Maintenance of Applicable Regulations 2,3,4 **
2.2 SMS Documentation 2,3,4 **
2.3 Records Management 2,3,4 **
3. Safety Oversight 3.1 Reactive Processes 2
3.2 Proactive Processes 3
3.3 Investigation and Analysis 2
3.4 Risk Management 2
4. Training 4.1 Training, Awareness and Competence 2,3,4 **
5. Quality Assurance 5.1 Operational Quality Assurance 4
6. Emergency Preparedness 6.1 Emergency Preparedness and Response 4
** The Document Management and Training components are common to all phases and are implemented as they
apply to the other components or elements in that phase.
Upon publication of the SMS regulations in the Canada Gazette Part II, Transport Canada will issue exemptions effectively
delaying the requirement for organizations to comply with these new rules. The exemptions will provide all the information
needed for organizations to determine who is affected by the SMS regulations and when they are required to comply with
the stated conditions.
The initial implementation of SMS will only apply to air operators whose operating certificate was issued under Subpart 705
and AMOs whose maintenance organization certificate was issued with aircraft ratings for types operated under Subpart 705.
Additional exemptions will be issued at a later date to bring the remaining air operators and AMOs into compliance with
forthcoming SMS regulations.
The exemptions will specify that affected organizations must implement a SMS in accordance with the stated conditions. The
implementation of the SMS requirements has been divided into four phases with each phase having specific requirements as
detailed below.
1.5.1 Phase 1
During this phase, and no later than the time specified by the Minister in the exemption, affected organizations are
required to complete a copy of the Compliance Document (Appendix A) and forward this to their Principal Maintenance
Inspector (PMI) or Principal Operations Inspector (POI) as applicable. Completion of the compliance document will satisfy
the requirements of CAR 106.02(1)(b)(c) and is an essential element of the SMS implementation process ensuring that all
affected organizations are aware of their regulatory responsibility.
The compliance document will identify the accountable executive. It will also identify the person within the organization
who is responsible for implementing the SMS and will contain a statement committing the organization to implementing
that system. In some organizations, the accountable executive and the person responsible for implementation of the SMS
may be the same person.
The project plan will be jointly agreed to between Transport Canada and the organization implementing the SMS. To
be effective, the project plan will include milestones for critical items such as dates for development and submission of
policies and procedures, training of staff and review by Transport Canada. These milestone dates are important, as principal
inspectors will use them to plan their implementation responsibilities and commitments. It is acknowledged that project
plans will require some flexibility, both TC and the affected organization must agree to any changes provided they do not
permit extension beyond the time limitations of any phase. Last minute changes made to the plan may not be accommodated
by Transport Canada due to workload or other priorities.
The compliance document, gap analysis and project plan shall be completed and submitted as a package within the time
limitations specified in the exemption. Transport Canada will review the submission and provide a response within 90 days.
Transport Canada’s endorsement of the compliance document will indicate review of the gap analysis and agreement with
the project plan.
1.5.2 Phase 2
During this phase, and no later than the time specified by the Minister in the exemption, certificate holders must demonstrate
to the satisfaction of Transport Canada, that they have the following SMS components/elements in place:
(a) The Safety Management Plan component (including all elements);
(b) The following elements of the Safety Oversight component:
(i) Reactive Processes
(ii) Investigation and Analysis
(iii) Risk Management
(c) Training for personnel assigned duties under the SMS that are relevant to
the components and elements referred to in (a) and (b).
(d) Documented policies and procedures that are relevant to the SMS
components and elements referred to in (a), (b) and (c).
During this phase, and no later than the time specified by the Minister in the exemption, in addition to meeting the
requirements of Phase 2, certificate holders must demonstrate to the satisfaction of Transport Canada that they have the
Proactive Process element of the Safety Oversight component in place. This requirement will also include documented
policies, procedures and training for personnel assigned duties under the SMS.
1.5.4 Phase 4
During this phase, and no later than the time specified by the Minister in the exemption, in addition to meeting the
requirements of Phases 2 and 3, certificate holders must demonstrate to the satisfaction of Transport Canada, that they have
the following components in place:
(a) Operational Quality Assurance
(b) Emergency Preparedness and Response
(c) Training for personnel assigned duties under the SMS that are relevant to
the components and elements referred to in (a) and (b).
(d) Documented policies and procedures that are relevant to the SMS
components and elements referred to in (a), (b) and (c).
Transport Canada has developed a Safety Management Systems Assessment Guide, TP 14326E, which will assist organizations
in conducting their gap analysis. This guide lists all the SMS components and elements and includes criteria linked to the
appropriate regulation or standard. The SMS Assessment Guide will be appended to the Inspection & Audit Manual, TP
8606, and will form the basis of Transport Canada’s on going SMS evaluations.
A comprehensive gap analysis form is included in this guide as Appendix B. The form combines the criteria from the SMS
Assessment Guide, TP14326E, as well as the applicable references to the regulations and standards for Parts I, V & VII.
Organizations can use this format as a template to conduct their gap analysis or they can create their own provided they refer
to the SMS Assessment Guide for the appropriate criteria for each component and element.
Each gap analysis question is designed for a “yes” or “no” response. If you respond with a “yes” answer you are indicating
that your organization already meets the criteria for that particular SMS component or element. A “No” answer indicates
that a gap exists between the stated criteria and your organization’s policies, procedures or processes. If the response is ‘”yes”,
the next column of the gap analysis form can be used to indicate where (in company documentation) the requirement is
addressed. If the response is “no”, the same column can be used to indicate how and/or where the policy, procedure or process
will be further developed to bring the organization into compliance with the requirement.
Once the gap analysis is complete and fully documented, the items you have identified as missing or deficient will form the
basis of your project plan. Organizations may format their project plan to suit their individual needs, however, a spreadsheet
format or MS Project type layout is recommended for ease of viewing and tracking. Each item will be assessed to determine
how the organization will create or modify policies, procedures or processes to incorporate the required SMS components
and elements. Components and elements can be grouped into larger projects and assigned to project manager(s) who will
oversee the development and implementation of that project. Each component, element or project should be assigned
Once complete, the compliance document, gap analysis and project plan will be submitted to your POI/PMI no later
than the time specified in the exemption. These documents will be reviewed in accordance with the requirements of the
exemption and the applicable SMS regulations and standards.
Circumstances that necessitate change(s) to the project plan must be communicated as soon as possible to the assigned
principal maintenance or operations inspector to gain agreement and ensure timely submission of required material. Periodic
progress reporting is a key component of this process.
Coincident with the introduction of SMS regulations, organizations will also be required to appoint an accountable executive.
The accountable executive will be a single, identifiable person within each organization who will assume full responsibility
for the organization’s ongoing compliance with the CARs (ref CAR 106). It is imperative that the correct person is identified
as the accountable executive, and that the individual understands the roles and responsibilities associated with that position.
This is not intended to be a position title without accountability.
Appendices D and E provide a flow chart and series of questions respectively, to assist with the selection process. The flow
chart identifies several organizational structures that will lead to a corresponding accountable executive. Once this person is
determined, the questions following the flow chart will confirm the selected person is the correct choice. All questions must
receive a ‘yes’ answer for the candidate to be acceptable. Should any of the questions result in a ‘no’ answer, the selection
process must start again with a new candidate. The organizational structures included in the Appendix are intended to
cover the majority of situations that will be encountered. Should there be an organizational structure that does not result
in the clear selection of an accountable executive, an appropriate candidate will be selected in consultation with Transport
Canada. The nomination of the Accountable Executive will be validated during the next inspection, regulatory audit or safety
management system assessment.
Note: Regulations requiring the appointment of an accountable executive are separate from those requiring a SMS. Information
on the accountable executive is included here to offer organizations a comprehensive package for implementing their SMS
and selecting their accountable executive.
This is not to imply that the regulatory requirements within each certificate will be combined. Each certificate must continue
to comply with its regulatory requirements, however both certificates can be subject to a single SMS.
Organizations that do not take advantage of the exemption(s) must be in full compliance with the applicable safety management
regulations within 30 days of publication in the Canada Gazette II. Contact your POI/PMI as soon as possible to ensure your
programs, including approved documentation, are compliant with the applicable SMS requirements. Organizations that are
found to be non-compliant following an assessment will be subject to normal administrative action.
Due to the anticipated increase in workload expected with SMS implementation, Transport Canada’s priority will be directed
toward those organizations that utilize the exemption and phased implementation method. As such, organizations are strongly
encouraged to take full advantage of the exemption
The Civil Aviation SMS Assessment Protocol has been developed to give Transport Canada a tool for systematically evaluating
the state of Safety Management Systems. It is not meant to be an inspection or compliance audit, but rather, the assessment
focuses on the effectiveness and efficiency of a management system and makes judgments on its performance. Civil Aviation
Safety Inspectors will use the tool for the review and acceptance of each organization’s SMS. This protocol can also be used
by affected organizations to “self assess” their program prior to review by Transport Canada. The assessment protocol can
be found using the website link provided below under Guidance Material and will be added to the Inspection and Audit
Manual (TP 8606).
Transport Canada has published additional guidance material to assist organizations with their SMS program. This information
is available on the Transport Canada website at http://www.tc.gc.ca/civilaviation/SMS/menu.htm
Organizations are encouraged to review this site with emphasis on the following;
• Safety Management Systems, TP 13739 http://www.tc.gc.ca/
civilaviation/SystemSafety/Pubs/tp13739/menu.htm
• Safety Management Systems for Flight Operations And Aircraft Maintenance Organizations – A guide
to implementation, TP 13881 http://www.tc.gc.ca/civilaviation/maintenance/SMS/menu.htm
• Safety Management Systems for Small Aviation Operations, TP 14135 (http://
www.tc.gc.ca/civilaviation/general/Flttrain/SMS/Intro.htm)
• Regulatory Affairs http://tcinfo/CivilAviation/RegServ/Affairs/menu.htm
• Safety Management Systems Assessment Guide, TP 14326
• Inspection and Audit Manual, TP 8606 http://www.tc.gc.ca/civilaviation/maintenance/aarpf/menu.htm
Part 1 of this form may be used to satisfy the notification and acceptance requirements of CAR 106.02(1)(b) & (c).
Organizations required to implement a SMS will also complete Parts 2 & 3 of this form.
This compliance document, or a similarly worded form, the gap analysis and project plan, must be submitted within the time
specified in the exemption, to the organization’s principal operations or maintenance inspector for review.
Part 1
A flow chart and question list is included as Appendices D & E, of this guide. They can be used to assist your
organization in identifying the accountable executive. The chart and questions are designed to ensure that a
person, and not a position, is identified as the accountable executive.
________________________________________________________________________________________
(name, position titl e and signature)
________________________________________________________________________________________
(name on certificate(s))
Part 2
________________________________________________________________________________________
(provide name and position title)
Part 3
________________________________________________________________________________________
(company name)
________________________________________________________________________________________
Accountable Executive
In accordance with the conditions of the Exemption, the information contained on this document, the gap
analysis and project plan have been reviewed. Endorsement by Transport Canada indicates agreement with the
attached project plan.
Signed: __________________________________________________________________________________
(For Minister of Transport) Date
Safety Management Response If yes, state where the requirement is addressed, If no, record SMS
System Requirements (Yes/No) processes that need further development
Component 1, Safety Management Plan - Element 1.1, Safety Policy
Is a safety management
system with defined
components established,
maintained and adhered to?
(CAR107.02)
Is the safety management
system appropriate to the
size and complexity of the
organization? (CAR107.04)
Is there a safety policy in
place? (CAR 107.03, 573.31,
705.152)
Has the organization based
its safety management system
on the safety policy?
(CAR 107.03)
Is the safety policy approved
by the accountable executive?
(CAR 573.31, 705.152)
Is the safety policy promoted
by the accountable executive?
(CAR 573.31, 705.152)
Is the safety policy reviewed
periodically? (CAR 107.03)
Is the safety policy
communicated to all
employees with the intent
that they are made aware
of their individual safety
obligations? (CAR 107.03,
573.31, 705.152)
Component 1, Safety Management Plan - Element 1.2, Non-Punitive Safety Reporting
Is there a policy in place
that provides immunity
from disciplinary action for
employees that report safety
deficiencies, hazards or
occurrences? (CAR 573.31,
705.152)
Component 1, Safety Management Plan - Element 1.3, Roles & Responsibilities
Has an accountable executive
been appointed with
responsibility for ensuring
that the safety management
system is properly
implemented and performing
to requirements in all areas of
the organization?
(CAR 106.02)