Implementing SMS in Germany

With the November 2005 date looming for meeting ICAO’s requirement for the implementation of SMS, Henning Pfisterer of Munich Airport gives an update on how the Germany airport industry is fulfilling these requirements.

The ICAO requirement for the implementation of Safety Management Systems (SMS) at certified airports – an ICAO standard that takes effect in November 2005 – is probably one of the most significant changes in the regulatory framework for the operation of airports in recent years.

The German federal government and the very complex structure of German aviation regulation dictates that airport licensing and certification here is delegated to the 16 state aviation authorities. These state aviation authorities are also in charge of the supervision of the airports.

Taking this into account, the German Federal Aviation Authority and the Department of Aviation and Space in the German Ministry of Transport, Building and Housing have been highly interested in creating a uniform and comparable standard for SMS at all German airports. Thus these agencies supported the initiation of a joint research project conducted by Munich Airport in cooperation with Berlin’s Technical University. The focus of this project is the development of guidelines and structures for the implementation of SMS that should be applicable to every airport, regardless of size, structure or general developments.

The project has already produced an important new publication, the Handbook on Safety Management Systems at Airports in Germany.

During the ongoing research work some central problems became evident:

1. The scope of an aerodrome SMS was not clearly defined
2. Identification of a main task – the development of a uniform and for every airport applicable way
3. Safety management structures developed for other industries and aviation spheres like Air Traffic Services, manufacturers or operators are not equally / universally applicable in an airport environment

The scope of SMS

Existing documentation from ICAO and other sources provides methodological guidance and describes the key elements of SMS, but still lacks a robust definition for the scope of an aerodrome SMS. In addition to being prone to risks specific to airport operations, airports are also affected by a range of risks comparable to those affecting a medium-sized city with major industrial areas and activities.

The crucial question asked by the study was whether or not an SMS should cover all of the risks associated with the operation of an airport, above and beyond those related to aviation, aircraft handling and airport operation. The German definition follows the concept of allocating safety competence areas according to different legal frameworks. Therefore the airport SMS only covers risks directly related to air transport or aerodrome operation. SMS encompasses specifically those risks and the procedures regulated by air transport legislation, regulations, recommendations and air transport industry standards which are controlled by relevant civil aviation authorities or industry bodies. The relevant legal framework for SMS is primarily defined by ICAO SARPS, national air transport legislation, the aerodrome license, IATA recommendations, ACI best practices, JAR-OPS and other national aviation guidelines.

General industrial risks which are not specific to the airport or aviation industry and which are regulated by other legal frameworks than those of aviation do not fall under the sphere of SMS. Occupational health and safety issues and fire safety prevention in buildings are regulated by different legal frameworks and are not subject to the direct control and integration in the SMS. The airport SMS only provides interfaces to relevant departments dealing with these general industrial risks. The guidance manual produced by the project contains a clear definition of the scope of SMS at an airport.

Uniform applicability vs. airport diversity

The primary objective of the project – with regards to the complex aviation regulatory system in Germany – has been to create an airport SMS featuring specifications applicable at every airport. The objective was to be as precise as possible in the drawing up of these specifications, but still remain general enough to allow compatibility with differences among several airports in respect to size, passenger volume and mix of traffic as well as individual organisational structures.

Compared to other aviation bodies, airports can vary widely in size and organisational structure. For example, operations at airports are handled by a variety of companies and organisational types (government vs. private industry). Particularly airports face the further organisational challenge of key elements of their process chains – for example, air traffic control – being provided by government authorities or state-run entities. The cooperation between these organisations and airports is often not regulated on a contractual basis.

In contrast to SMS in other industries, an airport SMS must therefore encompass many organisational barriers and has to integrate many organisations, including government authorities, in a comprehensive, systematic approach.

Therefore, the Technical University of Berlin and Munich Airport have together developed an infrastructure and process-oriented model of airport operations which contains every process relevant to safety. In the process, both partners identified more than 1, 400 safety-relevant processes stemming from and pertaining to airport operations.

This approach enables the airport operator to develop its own airport SMS, integrating all companies and organisations working at the airport. It also assures that no relevant safety-related process would be accidentally overlooked or completely missed during the development of the individual SMS.

According to this and in contrast to many other publications dealing with SMS in the aviation or other industries, the German guide is clearly tailor made to fit the needs of the airport industry.

The German handbook on SMS

In order to ensure that the results of the research work are applicable at the practical level, the research team has invested huge amounts of effort to ensure close communication with various airport organisations, as well as federal and state aviation authorities and other experts.

The problems of incorporating applicability to different organisational structures and characteristics of individual airports have primarily been surmounted by using Munich Airport as a reference model. As Europe´s eighth largest hub airport, Munich Airport has a very complex organisational structure comprised of the operating company, numerous subsidiary and on-site companies, authorities and organisations, which thus provides an excellent database for the cross-referencing of data. All recommendations have also been assessed for compatibility by discussions with aviation specialists from other airports; specifically by taking Frankfurt Airport as an example of a larger airport than Munich, and Nuremberg as an example of a smaller airport. Project results have also been tested for their universal applicability during consultations with the German Airports Association (ADV) and the Technical and Operational Safety Committee of the Airports Council International (ACI).

All results and conclusions have been reviewed and agreed upon by German state and federal aviation authorities to assure the acceptance within the relevant icensing and supervisory bodies.

Thus the content of the handbook, including an agreed schedule for implementation of the SMS in Germany, has received unanimous approval by federal and state aviation authorities. The handbook will be the standard and binding guide for the implementation of SMS at the different aerodromes.

According to the handbook´s definition, a SMS is basically characterised by the following core elements:

1. A clear safety policy for the aerodrome
2. The installation of a safety manager at an appropriately high level within the airport organisational level and give this manager clearly defined responsibilities
3. The installation of safety committees
4. Process identification, documentation and allocation of responsibilities
5. Hazard identification and risk management
6. Occurrence reporting and investigation
7. Internal auditing
8. Change management
9. Safety training
10. The definition of safety performance targets
11. Review and performance monitoring
12. Emergency planning

An airport operator’s SMS should seamlessly interact with the SMS of other key players in aviation safety, such as the SMS of airlines and ATC. It should also provide an interface between the airport operating company and aviation safety authorities such as the Federal CAA, airport licensing authorities and the federal air accident investigation authority.

Developing risk assessment models

Particularly in respect to hazard identification and risk assessment, it has become evident during this project that methodologies from manufacturing industries, for example JAR 25, are not applicable to the airport industry. This is firstly because hazard probability assessments are more meaningful in an airport environment when they are based on aircraft movement figures rather than flight hours, the latter of which are often used in other documentation. Secondly, the statistical data for probability calculations in the airport industry are not as readily available as in other industries.

Thus risk assessment in an airport environment should preferably be based on mature judgment rather than statistics. Still, the process of risk management must involve all of the relevant key players of a certain process in a systematic, transparent and documented approach and must be subject to constant review. Thorough and sound documentation systems and a systematic occurrence reporting and investigation process are the instruments to gather the necessary statistical data for future probability calculations.

Committees and contracts

The handbook provides guidance on how to take into account the wide range of safety issues and key players at major airports and proposes a structure that allows for several airport safety committees instead of just one. The manual provides readily-available concepts for the installation of the following committees:

• Runway Safety Committee
• Ramp Safety
• Emergency Planning
• Snow/Adverse Weather
• Obstacle and Construction

Beside that, the handbook also suggests suitable ways of integrating external organisations into the airport’s SMS with relevant clauses in the airport’s user regulations or in contractual clauses. It also contains a job description for the safety manager and provides recommendations on how to integrate the safety management function in the airport’s organisational structure.

The German SMS handbook is designed to provide the structural and implementation plan for the safety management manuals to be produced by each individual airport as part of its aerodrome manual. And where applicable, the manual also discusses alternative means of compliance.

From the very beginning of the project, it was understood that the results of the research project should be made available to every aerodrome. Only in this way would every aerodrome in Germany be able to benefit from the outcome and be able to design its own SMS fast enough to meet deadline constraints set out in ICAO Annex 14.

Due to high interest expressed by many airports and aviation authorities from other countries, an English translation of the handbook is on the way in order to make the research results available to an international audience.

Henning Pfisterer

Henning Pfisterer, Airport Safety Manager and Airport Duty Officer for Munich International Airport, has in 12 years gained extensive experience in various functions of airport operations. As Airport Safety Manager he deals with a range of issues such as emergency planning, development and implementation of a SMS, incident and accident reporting and the investigation and certification of aerodromes. Beside his operational duties he has been involved in consultancy projects in Athens, Brussels and Madrid and is also an Aviation Supervision Official for the Regional CAA of Upper Bavaria and an Accident Investigation Official for the German Federal Bureau of Air Accident Investigation. Henning holds an MSc. Degree in Airport Planning and Management from Loughborough University, U.K.