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Transport Canada Gap Analysis Checklist Tools

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Transport Canada Aviation SMS Gap Analysis Checklist

Safety Policy (Phase 2)

  • A. * A safety policy is in existence, followed and understood.
  • B. * The organization has based its safety management system on the safety policy and there is a clear commitment to safety.
  • C. * The safety policy is agreed to and approved by the accountable executive.
  • D. The safety policy is promoted by the accountable executive.
  • E. * The safety policy is reviewed periodically for continuing applicability.
  • F. * The safety policy is communicated to all employees with the result that they are made aware of their safety obligations.
  • G. ** The policy is implemented at all levels of the organization.

Non-Punitive Reporting Policy (Phase 2)

  • A. * There is a policy in place that provides immunity from disciplinary action for employees that report hazards, incidents or accidents.
  • B. ** Conditions under which punitive disciplinary action would be considered (e.g. illegal activity, negligence or wilful misconduct) are clearly defined and documented.
  • C. ** The policy is widely understood within the organization.
  • D. ** There is evidence that the organization is applying the policy.

Roles and Resp & Emp Invlvmnt (Phase 2)

  • A. * There are documented roles and responsibilities and accountabilities for the accountable executive and evidence that the SMS is established, maintained and adhered to.
  • B. * The accountable executive demonstrates control of the financial and human resources required for the proper execution of his/her SMS responsibilities.
  • C. * A qualified person has been appointed, in accordance with the regulation, and has demonstrated control of the SMS.
  • D. The person managing the operation of the SMS fulfils the required job functions and responsibilities.
  • E. * Safety authorities, responsibilities and accountabilities are transmitted to all personnel.
  • F. All personnel understand their authorities, responsibilities and accountabilities in regards to all safety management processes, decision and actions.

Communication (Phase 2)

  • A. There are communication processes in place within the organization that permit the SMS to function effectively.
  • B. * Communication processes (written, meetings, electronic, etc.) are commensurate with the size and complexity of the organization.
  • C. * Information is established and maintained in a suitable medium.
  • D. There is a process for the dissemination of safety information throughout the organization and a means of monitoring the effectiveness of this process.

Safety Planning (Phase 2)

  • A. * Safety objectives have been established utilizing a safety risk profile that considers hazards and risks.
  • B. ** Objectives and goals are consistent with the safety policy and their attainment is measurable.
  • C. ** Safety objectives and goals are reviewed and updated periodically.
  • D. ** There is a documented process to develop a set of safety goals to achieve overall safety objectives.
  • E. ** Safety objectives and goals are documented and publicized.

Performance Measurement (Phase 2)

  • A. * There is a documented process to develop and maintain a set of performance parameters that are linked to the organization's goals and objectives.
  • B. ** Procedures have been established and maintained to monitor and measure safety performance on a regular basis.

Management Review (Phase 2)

  • A. * Periodic, planned reviews and reviews for cause of the company's safety management system are conducted to ensure its continuing adequacy and effectiveness as well as a review of company safety performance and achievement.
  • "B. ** The safety management system review includes: * Internal audit results * Activities to verify that employees understand the SMS and their role and responsibilities in it. * Safety objective achievement results * Hazard and occurrence investigation and analysis results * Internal/external feedback analysis and results * Status of corrective and preventive action(s) * Follow-up actions from previous management reviews * Changes that could affect the SMS * Recommendations for improvement * Sharing of best practices across the organization"
  • "C. ** There is a documented procedure defining responsibilities and requirements for planning and conducting internal audits of: *management policies, controls and procedures concerning all safety critical activities; *the implementation and maintenance of SMS requirements established by the organization."
  • D. ** There is a process to evaluate the effectiveness of corrective actions resulting from (A).

ID & Maint. Applicable Regs (Phase 2,3,4)

  • A. * A documented procedure has been established and maintained for identifying applicable regulatory requirements.
  • B. * Regulations, Standards and exemptions are periodically reviewed to ensure that the most current information is available.

SMS Documentation (Phase 2,3 & 4)

  • A. * There is controlled documentation that describes the SMS and the interrelationship between all of its elements.
  • B. ** Documentation is readily accessible to all personnel.
  • C. ** There is a process to periodically review SMS documentation to ensure its continuing suitability, adequacy and effectiveness, and that changes to company documentation have been implemented.
  • D. ** There are acceptable means of documentation, including but are not limited to, organizational charts, job descriptions and other descriptive written material that defines and clearly delineates the system of authority and responsibility within the organization for ensuring safe operation.
  • E. ** The organization has a process to identify changes within the organization that could affect company documentation.

Records Management (Phase 2, 3 & 4)

  • A. * The certificate holder has a records system that ensures the generation and retention of all records necessary to document and support the SMS.
  • B. The system shall provide the control processes necessary to ensure appropriate identification, legibility, storage, protection, archiving, retrieval, retention time, and disposition of records.
  • A. * The certificate holder has a process or system that provides for the capture of information including hazards, incidents, accidents and other data relevant to SMS.
  • B. * The reactive reporting system is simple, accessible and commensurate with the size and complexity of the organization.
  • C. Reactive reports are reviewed at the appropriate level of management.
  • D. * There is a feedback process to notify contributors that their reports have been received and to share the end results of the analysis.
  • E. * There is a process in place to monitor and analyze trends.
  • F. * Corrective actions are generated and implemented to respond to event analysis.

Proactive Processes (Phase 3)

  • A. * The certificate holder has a proactive process or system that provides for the capture of information identified as hazards and other data relevant to SMS and develops a hazard register.
  • B. * The proactive reporting process is simple, accessible and commensurate with the size and complexity of the organization.
  • C. Proactive reports are reviewed at the appropriate level of management.
  • D. * There is a feedback process to notify contributors that their proactive reports have been received and to share the end result of the analysis.
  • E. There is a process in place to monitor and analyze trends.
  • F. * Corrective actions are generated and implemented in response to hazard analysis.
  • G. The organization has planned self-evaluation processes, such as regularly scheduled reviews, evaluations, surveys, operational audits, assessments, etc.
  • "H. ** The organization conducts hazard analyses and builds a safety case for changes that may impact their operations for example : * introduction of new aircraft type * change in route structures * change in key personnel * mergers * management/bargaining agent agreements"
  • I. ** The organization has a clearly defined interval between hazard analyses.
  • J. ** The organization will develop a safety risk profile that prioritizes hazards listed on the hazard register

Investigation and Analysis (Phase 2)

  • A. * There are procedures in place for the conduct of investigations.
  • B. * Measures exist to ensure that hazards, incidents and accidents are reviewed and where required, investigated. 573.32(c), 705.153(c)
  • C. * There is a process to ensure that hazards, incidents and accidents are analyzed to identify contributing and root causes.
  • D. ** When identifying contributing and root causes, the organization considers individual human factors, the environment, supervision and organizational elements
  • E. ** The organization has a staff of competent investigators commensurate with its size and complexity.
  • F. ** Results of the analysis are communicated to the responsible manager for corrective action and to other relevant managers for their information.
  • G. ** There is a process to capture information from an investigation that can be used to monitor and analyze trends.
  • H. ** There is evidence that the organization has made every effort to complete the investigation and analysis process in the established timeframe.

Risk Management (Phase 2)

  • A. * There is a structured process for the management of risk that includes the assessment of risk associated with identified hazards, expressed in terms of severity and probability of occurrence and where applicable the level of exposure.
  • B. * There are criteria for evaluating the level of risk and the tolerable level of risk the organization is willing to accept.
  • C. * The organization has risk control strategies that include risk control, risk acceptance, risk mitigation, risk elimination and where applicable a corrective action plan.
  • D. * Corrective actions resulting from the risk assessment, including timelines, are documented.
  • E. * The organization has a process for evaluating the effectiveness of the corrective actions.

Trng, Awareness & Competence (Phase 2,3,4)

  • A. * There is a documented process to identify training requirements so that personnel are competent to perform their duties within the SMS.
  • B. * There is a validation process that measures the effectiveness of the SMS training.
  • C. * The SMS training includes initial, recurrent and update training, as applicable.
  • D. The certificate holder's safety management training is incorporated into indoctrination training upon employment.
  • E. * SMS Training includes human and organizational factors.
  • F. There is emergency preparedness and response training for affected personnel.

Operational Quality Assurance (Phase 4)

  • A. A quality assurance program is established and maintained, and the program is under the management of an appropriate person.
  • B. There exists an operationally independent audit function with the authority required to carry out an effective internal evaluation program.
  • C. The organization conducts reviews and audits of its processes, its procedures, analyses, inspections and training.
  • D. The organization has a system to monitor for completeness of the internal reporting process and the corrective action completion.
  • E. The quality assurance system covers all functions defined within the certificate(s).
  • F. There are defined audit scope, criteria, frequency and methods.
  • G. There is a selection/training process to ensure the objectivity and competence of auditors as well as the impartiality of the audit process.
  • H. There is a procedure to record verification of action(s) taken and the reporting of verification results.
  • I. The organization performs a periodic Management review of safety critical functions and relevant safety or quality issues that arise from the internal evaluation program.
  • J. * There is a documented procedure for reporting audit results and maintaining records.
  • K. * There is a documented procedure outlining requirements for timely corrective and preventive action in response to audit results.
  • L. ** There is evidence that the quality assurance program has itself been subjected to internal audits.
  • M. ** Competence to perform duties is evaluated.

Emerg Preparedness & Response (Phase 4)

  • A. The organization has an emergency preparedness procedure, appropriate to the size, nature and complexity of the organization.
  • B. The Emergency preparedness procedures have been documented, implemented and assigned to a responsible manager.
  • C. The emergency preparedness procedures have been periodically reviewed as a part of the management review and after key personnel or organizational change.
  • D. * The organization has a process to distribute the ERP procedures and to communicate the content to affected personnel.
  • E. The organization has conducted drills and exercises with all key personnel at intervals defined in the approved control manual.

SMS Implementation Plans and Gap Analysis Checklists Download Excel TC Gap Analysis Template

“As of November 23, 2006 States shall require, as part of their safety programme, that an [operator, maintenance organization, ATS provider, certified aerodrome] implements a safety management system (SMS) accepted by the State that, as a minimum:
  • Identifies safety hazards.
  • Ensures that remedial action necessary to maintain an acceptable level of safety is implemented.
  • Provides for continuous monitoring and regular assessment of the safety level achieved.
  • Aims to make continuous improvement to the overall level of safety.”

On June 22, 2006, AC 120-92 was published establishing the guidelines for the use of safety management systems (SMS) in the aviation industry. This AC is non-regulatory in nature and intended to provide guidance to aviation industry participants (air carrier certificate holders, program managers, operators, repair stations, etc.) in the development and/or use of an SMS.

At the core of the IS-BAO is a company Safety Management System (SMS). The IS-BAO requires that flight departments implement an SMS. The goal of the SMS is to manage safety risks effectively.
Guidelines have been developed to assist business aircraft operators to:
  • identify the hazards and categorize the risks related to their operations,
  • develop and document mitigations,
  • track and measure the results of their activities.

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