The FAA Safety Assurance System (SAS) will replace all FAA oversight programs for more than 13,000 certificate holders by the year 2018. The System Approach for Safety Oversight (SAS) Program Office is responsible for SAS. SAS is not a separate safety standard and does not impose additional requirements on certificate holders. SAS provides aviation safety inspectors with standardized protocols to evaluate certificate holder programs required by regulations to be approved or accepted. It is an automated approach to determine that a certificate holder is able to operate safely under the prescribed regulations and standards.
The configuration of an operator's operating profile is determined by their configuration data (vitals) and desired operations specifications. The SAS process produces a scoped operating profile along with DCT's. The trigger for this process is an initial certificate or a change request for:
Configuration Data Initial PASI Scoped ED DCT's |
Changes to Scope of Operations Manuals - Operations, Training, or Maintenance Minimum Equipment List (Revisions) |
The scoped operating profile is used by the Data Collection Tool (DCT) to generate questions whose response determines compliance with the regulations and guidance. Knowledge of this process and policy is fundamental to understanding SAS automation and a successful outcome. SAS, along with the automated analysis within DCT, supports the subsequent approval or acceptance of new or revised manuals; or, the issuance of new or revised operations specifications.
There are five steps in the SAS process:
Operators are mainly involved in Configuration and Data Collection.
Configuration: The Configuration is performed by the FAA principal inspectors with the operator to enter the vitals (operator specific data) the operator's profile.
Data Collection: Data Collection is performed by the operator, much like a compliance statement, to identify compliance and the location in the manual system where the procedures or records are specified. It is an automated process. The data is verified by the FAA principal inspectors. Success results in acceptance, approval, or issuance of the desired item.
Initial Certification: Submit an application package to the certificate-holding district office (CHDO) through the use of the SAS external portal. The applicant will have access to Module 1 for configuration data and to Module 4 for Element Design DCTs (ED DCTs). The CPM will be notified of configuration change requests as they are submitted through the SAS external portal.
FAA-Initiated Change: The FAA may amend OpSpecs or require program revisions when safety in the public interest requires such action. Amendments or revisions can result from significant changes to the certificate holder’s operating environment or safety concerns. If the certificate holder does not use the SAS external portal, the PI must enter the configuration data into the automation with a change request.
Certificate Holder-Initiated Change: The request may be submitted in a letter form or through the use of the SAS external portal. If the external portal is used, the certificate holder will have access to Module 1 for configuration data and to Module 4 for ED DCTs (if required). Regardless of who initiates the change, the certificate holder must submit documentation for the FAA to evaluate the impact of the change.
Although the use of the SAS external portal is not required for existing certificate holders, it is highly recommended. If the certificate holder cannot or does not use the SAS external portal, the PI must enter the configuration data into the automation with a change request.
Revisions may be required to the operator's manual system and the process repeated.
After the principal inspector or certification program manager approves or accepts the change, the operating profile is considered finalized and the vitals are updated. However, if the change affected a change in operations specifications, then the principal inspector or certification project manager will need to update the operations specifications using WebOpss. Once all the changes have been made, the principal inspector or certification project manager should validate the changes in the operating profile and the configuration data.
The scope of data that is collected by the Data Collection Tool can be extensive. The data is organized into subsystems (categories) called the Master List of Functions. The DCT generates between 30 and 100 questions per subsystem. An example of the Master List of Functions for a Part 135 10 or more operator is presented below. A full 135 operator with 9 or less passenger seats has many of the same subsystems but fewer questions per subsystem.
An example of an ED DCT set of questions for a small 10 or more operator is presented below. The number of DCT's associated with this operator is 37. Not all the DCT's in the Master List of Functions are applicable because of the small size and scope. The maximum number of questions for a DCT associated with this operator is 138. It is possible to have well over 500 questions for a full 135 10 or more operator.
Summary Information
Purpose (Certificate Holder Responsibility): To train and qualify flight crewmembers.
Objective (FAA Responsibility): Determine if the CH will be able to; (1) Comply with regulations; (2) Train and qualify flight crewmembers.
Supplemental Information: 135.293(b), 135.301(a), 135.323(a), 135.323(b), 135.323(c), 135.323(d), 135.327, 135.329(a), 135.329(b), 135.329(c), 135.329(d), 135.329(e), 135.330(a), 135.330(b), 135.331, 135.331(a), 135.331(b), 135.331(c), 135.331(d), 135.341(b), 135.345(a), 135.345(b), 135.347(a), 135.347(b), 135.347(c), 135.351(a), 135.351(b), 135.351(c), 135.63(a), 135.63(b), 44703(h), 44703(i), 44703(j)
FAA Order 8900.1: 8000.88, 8900.1 Vol 3 Ch 18 Sec 4, 8900.1 Vol 3 Ch 18 Sec 5, 8900.1 Vol 3 Ch 19, 8900.1 Vol 3 Ch 19 Sec 10, 8900.1 Vol 3 Ch 19 Sec 2, 8900.1 Vol 3 Ch 19 Sec 3, 8900.1 Vol 3 Ch 19 Sec 4, 8900.1 Vol 3 Ch 19 Sec 5, 8900.1 Vol 3 Ch 19 Sec 6, 8900.1 Vol 3 Ch 19 Sec 9, 8900.1 Vol 3 Ch 23 Sec 1, 8900.1 Vol 3 Ch 31, 8900.1 Vol 4 Ch 1 Sec 5, 8900.1 Vol 4 Ch 2 Sec 5, 8900.1 Vol 4 Ch 2 Sec 9,
OpSpecs: B030, B035, B040, B045, B046, B059, C061, C063, C071, C072, C073, C076, C079, C081, C300, C384, H104, H112
Advisory Circular (AC): AC-120-51, AC-120-67, AC-120-68, AC-91-70, AC-91-85
Questions | Answers | Response |
---|---|---|
1. Do the policies or procedures identify the person who is responsible for the quality of procedures associated with this Element? | ○ Yes | |
2. Are the duties and responsibilities documented for the individuals who have management responsibility and authority for this Element? | ○ Yes | |
3. Do the policies or procedures identify who has authority to:
| ○ Yes | |
4. Does the Operator document the procedures for delegating authority associated this Element? | ○ Yes | |
5. Are there documented process measurements to evaluate whether the Operator's policies, procedures, and controls are achieving the desired results?
| ○ Yes | |
6. Do the Operator's process measurements include the following requirements to assess this Element's performance;
| ○ Yes | |
7. Does the Operator require the documentation of process measurement results? | ○ Yes | |
8. Does the Operator describe how the process measurement results will be used to improve the Operator's ability to achieve the desired results? | ○ Yes | |
9. Does the organization that conducts the process measurements have direct access to the person with responsibility for this Element? | ○ Yes | |
10. Do the procedures require the Operator to retain records for flight crewmembers for a period of 5 years according to the PRIA, 49 USC 44703(h) through (j)? | ○ Yes | |
11. Do the procedures specify that a crewmember completing recurrent training, a test, or a flight check in the month before or the month after the calendar month in which that training, test, or check is required, he or she is considered to have taken or completed it in the calendar month in which it was required? | ○ Yes | |
12. Do the procedures specify that the Operator will not implement any training under 14 CFR Part 135 Subpart H until FAA initial and final approval, as appropriate, is obtained? | ○ Yes | |
13. Do the procedures specify that the Operator has a training program that satisfies the following requirements of 14 CFR Part 135 Subpart H:
| ○ Yes | |
14. Do the procedures specify that instructors, supervisors, and check airmen, as applicable, must certify the proficiency and knowledge of the crewmember in the crewmember's record upon completion of:
| ○ Yes | |
15. Do the procedures specify that the Operator have a written and current crewmember training program curriculum for each type of aircraft, including ground and flight training required by 14 CFR Part 135 Subpart H? NOTE:Each curriculum must include: -A list of principal ground training subjects, including emergency training subjects that are provided; -A list of all the training devices mockups, systems trainers, procedures trainers, or other training aids that the Operator will use; and -Detailed descriptions or pictorial displays of the approved normal, abnormal, and emergency maneuvers, procedures and functions that will be performed during each flight training phase or flight check, indicating those maneuvers, procedures, and functions that are to be performed during the inflight portions of flight training and flight checks. | ○ Yes | |
16. Do the procedures specify that the Operator will not use a person as a flight crewmember after March 22, 2013 unless that person has completed approved initial crew resource management training with the Operator? | ○ Yes | |
17. Does the Operator have an approved crew resource management training program that includes initial and recurrent training? NOTE:The cirriculum must include: - Authority of the pilot in command; - Communication processes, decisions, and coordination, to include communication with Air Traffic Control, personnel performing flight locating and other operational functions, and passengers; - Building and maintenance of a flight team; - Workload and time management; - Situational awareness; - Effects of fatigue on performance, avoidance strategies and countermeasures; - Effects of stress and stress reduction strategies; and - Aeronautical decision-making and judgment training tailored to the operator's flight operations and aviation environment. | ○ Yes | |
18. Do the procedures specify that the training program contains a basic indoctrination curriculum for newly hired crewmembers that includes instruction in:
| ○ Yes | |
19. Do the procedures specify that the training program provides ground training, flight training, instruction, and practice to ensure each crewmember:
| ○ Yes | |
20. Do procedures specify the emergency training curriculum provide required training with respect to each aircraft type, model, configuration, required flight crewmember, and kind of operation conducted, as appropriate to each crewmember and the Operator? | ○ Yes | |
21. Does the Operator's emergency training curriculum provide instruction in at least the items in 135.331(b)? | ○ Yes | |
22. Do the procedures specify that each crewmember must perform the following emergency drills using the proper emergency equipment and procedures unless the Administrator finds that, for a particular drill, the crewmember can be adequately trained by demonstration:
| ○ Yes | |
23. Do procedures specify that the emergency training curriculum ensures crewmembers complete the following general emergency training curriculum segment during initial training and once every 12 months during recurrent training:
| ○ Yes | |
24. Do the procedures specify that the emergency training curriculum for crewmembers who serve in operations above 25,000 feet requires instruction in:
| ○ Yes | |
25. Do the procedures specify that initial, transition, recurrent, upgrade, and differences training for pilots must include flight and practice in each of the maneuvers and procedures in the approved training program curriculum? | ○ Yes | |
26. Do the procedures specify that initial equipment, transition, differences (as applicable), and upgrade ground training include applicable 135.345(a) general subjects? | ○ Yes | |
27. Do the procedures specify that if the Operator's approved training program includes a course of training utilizing an aircraft, simulator or other training device that the training program requires each pilot to complete the following as applicable:
| ○ Yes | |
28. Do the procedures specify that the recurrent training program ensures that each crewmember is adequately trained and currently proficient with respect to the type of aircraft and the crewmember position involved? | ○ Yes | |
29. Do the procedures specify that the recurrent ground training curriculum for crewmembers includes:
| ○ Yes | |
30. Do the procedures specify that the recurrent flight training for pilots must include flight training in the maneuvers or procedures specified in 14 CFR Part 135 Subpart H?
| ○ Yes | |
31. Do the procedures specify training for IFR Navigation using GPS/WAAS RNAV Systems? | ○ Yes | |
32. Do the procedures specify training for Class I navigation in the U.S. Class A airspace using area or long range navigation systems? | ○ Yes | |
33. Do the procedures specify training for operations in areas of magnetic unreliability? | ○ Yes | |
34. Do the procedures specify training for flight control guidance systems for automatic landings in operations other than CAT II and III? | ○ Yes | |
35. Do the procedures specify training for instrument departure and arrival operations using area navigation system? | ○ Yes | |
36. Do the procedures specify training for instrument departure and arrival operations using area navigation system? | ○ Yes | |
37. Do the procedures specify training for engine-out departure procedures with approved 10-minute takeoff thrust time limits? | ○ Yes | |
38. Do the procedures specify training for contact approaches? | ○ Yes | |
39. Do the procedures specify training for NDB, NDB/DME, VOR, and VOR/DME instrument approach procedures using substitute means of navigation?
| ○ Yes | |
40. Do the procedures specify training for RNP SAAAR operations?
| ○ Yes | |
41. Do the procedures specify that the flight crew must be qualified per the Operator's approved training program for the system and procedures being used before conducting any extended overwater operations using single long range communication system authorized by OpSpec B045? | ○ Yes | |
42. Do the procedures specify that the flight crew must complete the Operator's approved training program on reduced vertical separation minimum operating practices and procedures except when under the supervision of an appropriately trained check airman? | ○ Yes | |
43. Do the procedures specify that the flight crew must complete an approved training and testing program applicable to the equipment, routes, and procedures unique to operations in Canadian Minimum Navigation Performance Specification airspace, except when under the supervision of an appropriately trained check pilot? | ○ Yes | |
44. Do the procedures specify that the flight crew must successfully complete the Operator's approved training program curriculum segment(s) for auto flight guidance system operations at the minimum engagement altitude(s)? | ○ Yes | |
45. Do the procedures specify that before conducting IFR operations using vertical navigation, the flight crew must be trained in accordance with the Operator's approved training program for the navigation systems and instrument procedures being used? | ○ Yes | |
46. Do the procedures specify that the PIC and the SIC must complete the Operator's approved training for IFR lower than standard takeoff operations prior to conducting such operations? | ○ Yes | |
47. Do the procedures specify that the Operator must not conduct any special, non-CFR Part 97 instrument approach or departure procedures unless the approved training program provides training in the equipment and special procedures to be used? | ○ Yes | |
48. Do the policies and procedures include a requirement to comply with the OpSpecs, including clearly identified excerpts, references, mandatory compliance requirements, and other information that will keep employees informed of the impact on their duties and responsibilities with this Element? | ○ Yes | |
49. Do the policies and procedures include the duties and responsibilities for personnel involved with this Element?
| ○ Yes | |
50. Are the policies and procedures:
| ○ Yes | |
51. Since the last Design Assessment on this element, did the certificate holder perform the Safety Risk Management (SRM) process for any of the following conditions:
| ○ Yes | |
52. Did the certificate holder ensure that risk acceptance decisions involving this element or activity were approved by management personnel authorized by the certificate holder? | ○ Yes | |
53. Did the certificate holder conduct a system analysis of this element or activity considering all of the following:
| ○ Yes | |
54. Did the certificate holder consider interfaces between this element or activity and other element processes that may present hazards? | ○ Yes | |
55. Did the certificate holder complete the hazard identification process on this element or activity? | ○ Yes | |
56. Did the certificate holder conduct risk analysis and assessment for identified hazards involving this element or activity? | ○ Yes | |
57. Did the certificate holder develop, resource, and implement risk controls, including the necessary procedures, for hazards involving this element or activity where risk was assessed as unacceptable? | ○ Yes | |
58. Does the certificate holder have safety assurance processes that will provide continuous monitoring and measurement of risk control performance and effectiveness for this element or activity? | ○ Yes | |
59. Do the Operator's documented controls achieve the intended results which include, but are not be limited to, ensuring:
| ○ Yes | |
60. Where interfaces exist in this Element, are the procedures written with enough detail to preclude a breakdown or discontinuity in the activity? | ○ Yes |
The operator must answer Yes, No, nor NA in the Answers column. The operator must reference the location in the operator's manual system in the right column. Additional questions may be generated based on an operator's response. Upon successful completion, the FAA POI or CPM will verify the operator's answers. The analysis, assessment, and action is performed by the FAA POI or CPM. A successful outcome results in accepting or approving a manual or issuing operations specifications. The estimated time for an experienced operator to complete the DCT's is about 300 hours (10 or more), 150 hours (9 or less), and 75 hours (single-pilot operator).