AI-ORG-SMS-001

AIR INDIA LIMITED

CORPORATE
SAFETY MANAGEMENT SYSTEM MANUAL

(VOL I)

Accepted by DGCA

Issue – 4, Rev. 2, 11 DEC 2020

 AI-ORG-SMS-001

CORPORATE
SAFETY MANAGEMENT SYSTEM MANUAL
(VOL. I)

Accepted by DGCA

Issue – 4, Rev. 2, 11 DEC 2020

 CORPORATE SAFETY AI–ORG-SMS-001
MANAGEMENT SYSTEM MANUAL
CHAPTER 0
PREAMBLE Issue-4 Rev-2 11 DEC 2020
 CORPORATE SAFETY AI–ORG-SMS-001
MANAGEMENT SYSTEM MANUAL
CHAPTER 0
FOREWORD Issue-4 Rev-2 11 DEC 2020

CORPORATE SAFETY MANAGEMENT SYSTEM MANUAL (VOL.I) is a controlled document, the

contents of which shall not be deemed to supersede any instructions contained in the
following documents:

1. DGCA CAR Section 1, Series C Part I, dated 27th July, 2017

2. SSP Circular 02 of 2018 , dated 02nd Jan 2018.
3. ICAO Safety Management System Manual Doc. 9859

This manual is in conformity with DGCA CAR, ICAO Document and the latest IOSA
Standards.

Following two Volumes are integral part of the Corporate Safety Management System
Manual (Corp. SMS Manual):

Volume II – Quality and Safety Audit Manual (QSA)

Volume III – Emergency Management Manual (EMM)

Capt. Nivedita Bhasin

Head of Corporate SMS and QMS

FOR
 AIR INDIA LIMITED
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL

DOCUMENT CONTROL

CHAPTER – 0
 CORPORATE SAFETY AI–ORG-SMS-001
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CORPORATE POLICIES Issue-4 Rev-2 11 Dec 2020

HQ/CMD/20/3105 11th December 2020

CORPORATE SAFETY POLICY

Safety is one of the core business functions of Air India Limited covering all Air Operator
Permit’s, subsidiaries and Strategic Business Unit (SBU) functions. We are committed to
developing, implementing, maintaining and constantly improving strategies and processes to
ensure that all our aviation activities take place under a balanced allocation of organizational
resources, aimed at achieving the highest level of safety performance through a Corporate
Safety Management System (SMS) covering all the AOCs, subsidiaries and Strategic Business
Units (SBUs) and meeting National and International standards, while delivering our services.
All levels of management and all employees are accountable for the delivery of this highest
level of safety performance, starting with the Chairman and Managing Director (CMD)) and
Managing Committee of Air India Limited. All the Directors / SBU Heads / Chiefs / Exec.
Directors/Departmental Heads will appropriately implement and integrate the Safety
Management System (SMS) throughout the Organization to address safety of aircraft
operations.
The Corporate Safety policy will be carried forward by all Functional Heads to all
employees and shall be visible throughout the Organization by means of communiqué’s,
posters, website and other terms of information.
Air India Limited is committed to:
a) Support the management of safety through the provision of all appropriate resources
that will result in an organizational culture that fosters safe practices, encourages effective
safety reporting and communication, and actively manages safety with the same attention
to results as the attention to the results of the other management systems of the
organization.
b) Enforce the management of safety as a primary responsibility of all managers and
Employees.

c) Clearly define for all staff, managers and employees alike, their accountabilities and
responsibilities for the delivery of the organization’s safety performance and the
performance of our safety management system.
d) Establish and operate hazard identification and risk management processes,
including a hazard reporting system, in order to eliminate or mitigate the safety risks of the
consequences of hazards resulting from our operations or activities to a point which is as
low as reasonably practicable (ALARP).
e) Ensure that no action will be taken against any employee who discloses a safety
concern through the hazard reporting system, unless such disclosure indicates, beyond any
reasonable doubt, an illegal act, gross negligence, or a deliberate or willful disregard of
regulations or procedures.
f) Comply with and, wherever possible, exceed, legislative and regulatory requirements
and standards.
g) Ensure that sufficient skilled and trained human resources are available to
implement safety strategies and processes.

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h) Ensure that all staff are provided with adequate and appropriate aviation safety
information and training, are competent in safety matters, and are allocated only tasks
commensurate with their skills.

i) Establish and measure our safety performance against realistic safety performance
indicators and safety performance targets.

j) Continually improve our safety performance through management processes that

ensure that relevant safety action is taken and is effective.

k) Ensure externally supplied systems and services to support our operations are
delivered meeting our safety performance standards.

l) Ensure the promotion of safety awareness among all personnel.

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CORPORATE POLICIES Issue-4 Rev-2 11 Dec 2020

HQ/CMD/20/3107 11th December 2020

CORPORATE QUALITY POLICY

AIR INDIA LIMITED covering all AOCs, subsidiaries and Strategic Business Units are
committed to providing our customers with the highest level of product and service quality
derived from a Quality and Safety Management system whose foundation lies in a culture of
safety, quality, customer satisfaction and continuous improvement.
AIR INDIA LIMITED will ensure compliance with relevant statutory quality, safety and
environmental requirements which will be reviewed regularly. We will actively pursue
improving quality, through programmes that enable each employee to do their job “Right
the First Time” and “Every Time” thus fulfilling our customers expectations without
compromising the safety and quality of our operations.
Quality Performance is a commitment to excellence by each employee. It is
achieved by teamwork and a process of continuous improvement.

The objectives of the Quality Management System are:

a) To maintain an effective Quality Management System complying with international
standards and regulatory requirements.
b) To ensure compliance with relevant statutory, quality and safety requirements.
c) Providing a safe and secure operation as the first and most fundamental obligation to our
customers and employees, as well as to the communities we serve.
d) To achieve and maintain a level of quality and safety which enhances the Company's
reputation with customers. Constantly meeting customer expectations is both our
collective duty and foundation of our success.
e) To endeavour, at all times, to maximize customer satisfaction.
f) To implement innovative methods of management taking advantage of best practices in
Air Transport.
g) To ensure the existence of necessary facilities, workplaces, equipment and supporting
services as well as work environment to satisfy operational safety, quality, security and
continual improvement.
h) To commit to environmental protection and sustainable development, by use of modern
technology and optimization of our operation, by striving to reduce the negative impacts
of air transport on the environment and the society.
Every employee has an inherent responsibility for an ongoing commitment to quality and to
the promotion of a quality culture.

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CORPORATE POLICIES Issue-4 Rev-2 11 Dec 2020

HQ/CMD/20/3108
11th December2020

CORPORATE SECURITY POLICY

Air India Limited covering all its AOCs, SBUs and subsidiaries’ are
uncompromisingly committed to ensure Security and to Safeguard its passengers, staff,
crew, cargo/mail, customer assets and facilities from any detriment, damage or injury as
well as prevent the aircraft from unlawful seizure, hijacking, etc. Air India Limited will
abide by all Regulatory Directives on security and try to exceed requirements by periodically
reviewing its policy for continual relevance to have a culture that has security a fundamental
operational priority.

Air India limited will allocate organisational resources aimed at highest level of
security through a Security Management System with continual improvement.

Air India Limited is committed to

(i) Establish and maintain safe workplaces and practices;

(ii) Establish security objectives and security performance standards consequent security
enhancement and risk prevention strategies

(iii) Include security and risk considerations into business developments and operational
changes;

(iv) Proactive incorporation of and adherence to security principles and controls into
standard operating procedures;

(v) Provide personnel with the necessary skills through training to ensure that they gain
and maintain the required competencies;

(vi) Develop awareness through education to ensure personnel have a common

understanding of aviation security and the nature of potential hazards and threats;

(vii) Promote the reporting incidents and potential hazards and threats on a non-punitive
basis;

(viii)Promote security awareness and establish security culture.

(ix) Openly disseminate security related information, and provide two-way

communication channels between management and personnel;

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CORPORATE POLICIES Issue-4 Rev-2 11 Dec 2020

(x) Enlist the support of all personnel in developing solutions to eliminate unsafe
conditions and practices.

(xi) Ensure vigilant application by each individual in conducting their duties, adhering to
standard operating procedures and regulatory requirements;

(xii) Ensure all operational managers, pilots, crew members, mechanics, dispatchers,
operational and company staff, have a clear understanding of the airline security
programme and work together as a team to ensure the strict adherence to all aviation
security measures and requirements.

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CORPORATE POLICIES Issue-4 Rev-2 11 Dec 2020

HQ/CMD/20/3106 11th December,2020

CORPORATE ENVIRONMENT POLICY

Air India Limited, covering all its Airline Operating Permits, subsidiaries and Strategic
Business Units, as a part of it’s corporate social responsibilities, is committed to address all
environment issues with particular regard to preserving and protecting the environment. Air
India, through its "Environment Management System", will abide by all applicable laws and
regulations and continually improve environment management practices and exceed the
requirements by periodically reviewing our policy and improving our environmental related
performance.

Air India is committed to implement Green Initiative measures through effective

implementation of programme that:

• reduce carbon emission, reduce noise and other pollution, reduce fuel consumption,
reduce consumption of natural resources.

• Provide sufficient resources to meet environmental objectives by continual measuring,

monitoring, reporting and improving upon environmental performance.

• Set performance targets wherein objectives are achieved through training and the
implementation of work instructions and practices.

Air India’s goal is to be an organization whose practices make it one of the most
environmentally sensitive company in the aviation industry through an approach that
safeguards and enhances the quality of life of its employees, customers and protects the
environment.

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CORPORATE POLICIES Issue-4 Rev-2 11 Dec 2020

HQ/CMD/20/3109 11th December,2020

CORPORATE SOCIAL RESPONSIBILITY

Corporate Social Responsibility has been the hallmark of Air India right from the day
the company was formed by JRD TATA when he said

QTE “No success in material terms is worthwhile unless it serves the

needs or interests of the country and its people. In a free enterprise, the
community is not just another stakeholder in business but is in fact the very
purpose of its existence". UNQTE

With this legacy, Air India Limited covering all its AOC’s, subsidiaries and SBUs is
committed to Corporate Social Responsibility through following :

 Creating shared value concept by building interdependency of corporate success with

social welfare.

 Triple Bottom Line concept of measuring Corporate Performance in terms of

economic impact, social impact and environmental impact.

 Incorporating CSR strategy directly into the business strategy through ‘Fair Trade’.

Air India’s goal is to build a society with sustainable growth in terms of human index,
social awareness and education, ethical consumerism along with business.

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MANAGEMENT SYSTEM MANUAL CHAPTER - 0
CORPORATE POLICIES Issue-4 Rev-2 11 Dec 2020

INTENTIONALLY LEFT BLANK

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 CORPORATE SAFETY AI–ORG-SMS-001
MANAGEMENT SYSTEM MANUAL CHAPTER - 0
DISTRIBUTION LIST Issue-4 Rev-0 01 JUN2018

SL CONTROLLED COPY HOLDERS COPY NO.

NO.
1. Director General of Civil Aviation SMSM 01
2. Chairman & Managing Director SMSM 02
3. Director Operations SMSM 03
4. Director-Finance SMSM 04
5. Emergency Response Director SMSM 05
6. Director-Commercial SMSM 06
7. Director-Personnel SMSM 07
8. Head – Corporate QMS SMSM 08
9. Head – Corporate SMS SMSM 09
10. Head – Corporate DMS SMSM 10
11. ED-Security SMSM 11
12. ED-Ground Handling SMSM 12
13. ED-Finance SMSM 13
14. ED-IT SMSM 14
15. ED-Personnel SMSM 15
16. ED-Western Region SMSM 16
17. ED-Eastern Region SMSM 17
18. ED-Northern Region SMSM 18
19. ED-Southern Region SMSM 19
20. ED-Commercial SMSM 20
21. ED-Cargo SMSM 21
22. ED-Customer Services SMSM 22
23. ED-Corporate Affairs SMSM 23
24. ED-Medical Services SMSM 24
25. ED-MMD SMSM 25
26. GM - IOCC SMSM 26
27. ED-Flight Safety SMSM -AI-02
28. ED-Operations SMSM -AI-03
29. ED-Engineering SMSM -AI-04
30. ED-Training SMSM -AI-05
31. CEO – Air India Express SMSM -IX-01
32. COO- Air India Express SMSM -IX-02
33. Chief of Flight Safety SMSM -IX-03
34. Chief of Operations SMSM -IX-04
35. Chief of Engineering SMSM -IX-05
36. Chief of Finance SMSM -IX-06
37. Chief of Personnel SMSM -IX-07
38. Chief of Training SMSM -IX-08
39. CAM-ENGG SMSM -IX-09
40. Nodal Officer-ER-AICL SMSM -IX-10

40. CEO – Alliance Air SMSM -CD-01

41. COO-Alliance Air SMSM -CD-02
42. Chief of Flight Safety SMSM -CD-03
43. Chief of Operations SMSM -CD-04
44. Chief of Engineering SMSM -CD-05
45. Chief Financial Officer SMSM -CD-06

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 CORPORATE SAFETY AI–ORG-SMS-001
MANAGEMENT SYSTEM MANUAL CHAPTER - 0
DISTRIBUTION LIST Issue-4 Rev-0 01 JUN2018

SL CONTROLLED COPY HOLDERS COPY NO.

NO.
46. Chief of Personnel SMSM -CD-07
47. Chief of Training SMSM -CD-08
48. CAM-ENGG SMSM -CD-09

49. CEO, AIESL SMSM -MRO-01

50. ED-Engineering, AIESL SMSM -MRO-02
51. Safety Manager (SMS)-MRO SMSM -MRO-03

52. Air India (AIATSL) SMSM -AIATSL-01

53. COO – AIATSL SMSM -AIATSL-02
54. Safety Manager (SMS)-AIATSL SMSM -AIATSL-04

Note:

1) Corporate Safety Management Manuals are available on the Corporate DMS website, which
can be downloaded and printed for reference. Any printed copy must be crosschecked with
the latest updated version on the DMS and stamped as a “Controlled Copy” with the
correct “Copy Number” as per the Distribution List, when a new Revision is uploaded on
DMS, and a fresh print is taken, the old printed copy must be destroyed and only the latest
updated version should be available as a “Controlled Manual”.

2) The electronic version available on Corporate DMS website will always have the latest
Revision and therefore will be the Master Control copy.

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 AI–ORG-SMS-001
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL
CHAPTER - 0
RECORD OF REVISIONS Issue-04 Rev-2 11 Dec 2020

RECORD OF REVISION

Issue No. Revision No. Date of Revision Date Entered By

Entered
ISSUE 4 REV 0 01 JUN 2018
ISSUE 4 REV 1 15 JUN 2019
ISSUE 4 REV 2 11 DEC 2020

RR-1
 CORPORATE SAFETY AI–ORG-SMS-001
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TITLE PAGE CHAPTER 5

INNER PAGE CHAPTER 1 5-1 01.06.2018 0
DGCA APPROVAL / 1-1 01.06.2018 0 5-2 01.06.2018 0
ACCEPTANCE LETTER 1-2 01.06.2018 0 5-3 01.06.2018 0
PREAMBLE 1-3 01.06.2018 0 5-4 01.06.2018 0
FOREWORD 1-4 01.06.2018 0
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LEP2 11.12.2020 2 3-28 01.06.2018 0 7-2 11.12.2020 2
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DEF 2 01.06.2018 0 4-5 01.06.2018 0 7-9 11.12.2020 2
DEF 3 01.06.2018 0 4-6 01.06.2018 0 7-10 11.12.2020 2
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7-13 11.12.2020 2 9-19 11.12.2020 2
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 AIR INDIA LIMITED
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL

SMS REGULATORY REQUIREMENTS

CHAPTER – 2
 CORPORATE SAFETY AI–ORG-SMS-001
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SMS REGULATORY REQUIREMENTS Issue-4 Rev-2 11DEC2020

2.1 SMS Regulatory Requirement

The manual is prepared in compliance of the Requirements laid down in Rule 29-D of the
Indian Aircraft Rules, 1937, DGCA Civil Aviation Requirement, Section-1, Series C, Part-I,
Issue-II, dtd 27th July 2017, SSP Requirements and ICAO Doc. 9859 and is in accordance
with National and International standards (IOSA and ISAGO).

The manual also conforms to the requirements laid down in SSP Circular no. 02 of 2018,
dated 02nd January 2018.

Currently Air India Limited is complying of the SMS regulations/standards and the
compliance timeframe as specified in Appendix B of the CAR.

Significance and Implications of SMS to Air India Limited:

Air India Limited has developed its own policies and systems to reduce risk, which
includes implementing systems for reporting and correcting shortcomings. More
importantly, the SMS programme shall reduce direct or indirect costs that could have
been incurred without the implementation of safety management system.

Despite the fact that SMS is an important advance in safety management, it can only be
effective through its implementation. Through SMS it is ensured that all risks are covered
within the organization as a single system, rather than having multiple competing Safety
Management entities. Safety is seen holistically, so that it cannot interfere with the
prioritization of improvements.

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SMS REGULATORY REQUIREMENTS Issue-4 Rev-2 11DEC2020

2.2 SMS IMPLEMENTATION PLAN

Air India Ltd, as part of the SMS documentation, develops, adheres to and maintains
an SMS implementation plan as per the SSP requirements. Even after implementation
of Phase-IV of DGCA CAR, SMS implementation plan to increase effectiveness at
stations and departments is monitored.

The SMS implementation plan is the approach the organization adopts for managing
safety in a manner that meets the organization’s safety objectives.

The SMS implementation plan explicitly addresses the coordination between the SMS of
the airline and the SMS of other organizations the airline interfaces with during the
provision of services.

The SMS implementation plan is in accordance with the requirements of CAR Section 1,
Series C Part 1, Appendix B as also safety-related standards/requirements of other
agencies like IATA, SAFA, etc. and includes the following:

i. safety policy and objectives;

ii. system description;
iii. gap analysis;
iv. SMS components;
v. safety roles and responsibilities;
vi. hazard reporting policy;
vii. means of employee involvement;
viii. safety performance measurement;
ix. safety training;
x. safety communication; and
xi. management review of safety performance.

All personnel are made aware of the significance and implications of the CAR during SMS
trainings, through newsletters, posters, etc.

The SMS implementation plan is endorsed by senior management of the organization.

Establishment of Safety Management System provides the high level requirements to

fulfil the Airline SMS responsibilities related to or indirect support of the safe operation of
aircraft.

The compliance of the CAR leads to the Establishment of the SMS in Air India Limited
The CAR specifies the minimum acceptable requirement for the establishment of SMS
and lays down the Aviation safety related processes, procedures and activities followed
for establishment of SMS by Air India Limited

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 AIR INDIA LIMITED
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL

SCOPE AND
INTEGRATION OF THE
SAFETY MANAGEMENT SYSTEM

CHAPTER – 3
 CORPORATE SAFETY AI–ORG-SMS-001
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CHAPTER - 3
SCOPE & INTEGRATION OF SMS Issue-4 Rev-2 11 Dec 2020

3.1 SCOPE & INTEGRATION OF SMS

Air India Limited is an extensive Flight Service Provider in India with a fleet of Airbus
A320 family (A319/A320/A321) and B-747, B-777 and B-787.
The Organization has SBUs namely, AIESL for Maintenance (MRO as per CAR 145) and
AIATSL for Ground Handling.

The subsidiaries and the AOCs are integrated with the Corporate SMS. Air India
Express operates a fleet of B-737 and Alliance Air operates ATR 42 and ATR72 and
ensures regional connectivity.
Air India Limited has a Safety Management System (SMS) that is implemented and
integrated throughout the organization to address the safety of aircraft operations. The
scope of Corporate SMS includes all AOCs (Air India, Air India Express, Alliance Air and
SBUs of MRO, Ground Handling, etc. as well as subsidiaries. This includes all areas of
work, departments, workshops and facilities of the organisation.

Since Air India Limited holds more than one approval / certificate, Air India along with
the AOCs and the Subsidiaries follow the standardized Corporate SMS across its
multiple activities which is accepted by DGCA.
SMS is designed and implemented to:
i. Identify safety hazards in operations;
ii. Ensure remedial action is implemented to control safety risks;
iii. Provide for ongoing monitoring and assessment of safety performance;
iv. Make continual improvement to the level of safety in operations.
SMS is designed and implemented in accordance with the DGCA / SSP requirements.
The elements of SMS are implemented through the Corporate SMS and SMS of each
AOC, which is through each Department having its own internal SMS. This structure
reflects the size and complexity of our organization.
3.1.1 The corporate SMS which includes Air India, Air India Express, Alliance Air and SBUs of
MRO and Ground Handling, etc. have developed and established the SMS which must be
maintained and adhered to in accordance with CAR Section 1, Series C Part 1 wherein
the SMS framework has incorporated the four components and twelve key elements, as
follows:

i. Safety policy and objectives which shall consist of the Management commitment,
Safety accountability and responsibilities, Appointment of key safety personnel,
Coordination of emergency response planning and SMS documentation.
ii. Safety risk management which shall consist of Hazard identification and Safety risk
assessment and mitigation
iii. Safety assurance which shall consist of Safety performance monitoring and
measurement, The Management of change and Continuous improvement of the SMS
iv. Safety promotion which shall consist of Training and education and Safety
communication
3.1.2 Each AOC and SBU-MRO and SBU-Ground Handling will include SMS as an integral part
of all the departments, facilities and workshops, operational and non-operational areas.

All processes, operations and equipment will be eligible for the ‘Hazard Identification and
Risk Management programme’ (HIRM).

Corporate SMS works in an integrated manner with QMS and SeMS, and is administered
across the organization including contractors.

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The QMS and SMS are integrated in their SMS functions. Hazards reported by the SeMS
and QMS form a part of the Hazard Register and are discussed jointly during the SAG
meetings for remedial action and continuous improvement of SMS. The SMS
requirements are adopted by all departments and AOCs and SBUs and the processes are
mentioned in the manuals of the respective areas/departments, AOCs, SBUs.

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3.2 POLICY

The safety management system for all AOCs / SBUs / Subsidiaries shall include:

1. a safety policy on which the system is based;

2. a process for setting goals for the improvement of aviation safety and for measuring
the attainment of those goals;

3. a process for identifying hazards to aviation safety and for evaluating and managing
the associated risks;

4. a process for ensuring that personnel are trained and competent to perform their
duties;

5. a process for the internal reporting and analysing of hazards, incidents and accidents
and for taking corrective actions to prevent their recurrence;

6. a document containing all safety management system processes and a process for
making personnel aware of their responsibilities with respect to them;

7. a quality assurance program;

8. a process for conducting periodic reviews or audits of the safety management system;
and

9. any additional requirements for the safety management system that are prescribed in
DGCA CAR.

3.2.1 The safety management system shall be accepted by DGCA.

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3.3 CONCEPT OF SAFETY

Safety Management is a core business function just as financial management, HR

management, etc. The Safety Management System is a systematic approach to
managing safety, including the necessary organizational structures, accountabilities,
policies and procedures. Three core aspects of a SMS are:

Systematic – Safety management activities are in accordance with a pre-determined

plan, and applied in a consistent manner throughout the organization.

Pro-active – An approach that emphasizes hazard identification and risk control and
mitigation, before events that affect safety occur.

Explicit – All safety management activities are documented and visible.

3.3.1 As per ICAO Doc. 9859, depending on the perspective, the concept of safety in aviation
may have different connotations, such as:

i. zero accidents or serious incidents — a view widely held by the travelling public;
ii. freedom from hazards, i.e. those factors which cause or are likely to cause harm;
iii. attitudes of employees of aviation organizations towards unsafe acts and
conditions;
iv. error avoidance; and
v. regulatory compliance.

INTRODUCTORY CONCEPTS

An SMS can be likened to a toolbox. It is a toolbox that contains the tools that an
aviation organization needs in order to be able to control the safety risks of the
consequences of the hazards it must face during the delivery of the services for which
the organization is in business. In many cases the organization itself generates the
hazards during service delivery. It is important to acknowledge that an SMS itself is
neither a tool nor a process. An SMS is the toolbox, where the actual tools employed to
conduct the two basic safety management processes (hazard identification and safety
risk management) are contained and protected. What an SMS does for an organization
is to provide a toolbox that is appropriate, in size and complexity, to the size and
complexity of the organization.

As a toolbox, an SMS ensures that when specific tools are needed for hazard
identification and safety risk management:

i. the right tools for the task at hand are available for the organization to use;
ii. the tools and task are properly related;
iii. the tools are commensurate with the needs and constraints of the organization;
and
iv. the tools can be easily found within the tool box, without unnecessary waste of
time or resources.

This perspective is important, because an SMS simply is a protective shell that ensures
proper and timely storage, availability and utilization of the tools needed to deliver
specific safety management processes in the organization. Without the proper tools
inside, an SMS is only an empty shell.

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3.4 REQUIREMENTS OF SMS

All requirements as per DGCA CAR Section 1 – General Series ‘C’ Part I of 27th July
2017 and IOSA standards shall be complied with as given below:-

3.4.1 Air India Limited shall have an SMS that is implemented and integrated throughout the
organization to ensure management of the safety risks associated with aircraft
operations. The scope of Corporate SMS includes all AOCs (Air India, Air India Express,
Alliance Air and SBUs of MRO, Ground Handling, etc. as well as subsidiaries.)
SMS framework specifies the four major components and Eleven elements that make
up the basic structure of SMS. The SMS shall be designed and implemented to:

i. Identify safety hazards in operations;

ii. Ensure remedial actions is implemented to control safety risks;
iii. Provide for ongoing monitoring and assessment of safety performance;
iv. Make continual improvement to the level of safety performance.

3.4.2 Air India Limited shall designate a manager who is responsible for the implementation,
maintenance and day-to-day administration of the SMS throughout the organization on
behalf of the Accountable Executive and senior management. The Chiefs of Flight
Safety, for the respective AOCs are the designated Managers of SMS. The Safety
Officers for the SBUs are the designated Managers of SMS. The Chiefs of Flight Safety
& Safety Officer/Manager work in coordination with the Corporate SMS Office.

The requirement for a Manager that focuses on the administration and oversight of the
SMS on behalf of the Accountable Executive is an element of the Safety Policy and
Objectives component of the SMS framework. Head of Corporate SMS is the Manager
responsible for SMS and reports to the CMD who is the Accountable Executive.

The individual assigned responsibility for organizational implementation of an SMS is

ideally a management official that reports to the Accountable Executive. Also,
depending on the size, structure and scope of an operator‘s organization, such
individual may be assigned functions in addition to those associated with the SMS
manager position provided those functions do not result in a conflict of interest.

It is important that such manager has the necessary degree of authority when
coordinating and addressing safety matters throughout the organization. Whereas the
designated manager has responsibility for day-to-day oversight of the SMS, overall
accountability for organizational safety rests with the accountable executive. Likewise,
nominated officials or operational managers always retain the responsibility (and thus
are accountable) for ensuring safety in their respective areas of operations.

3.4.3 Air India Limited shall have a corporate safety policy that:

i) Reflects the organizational commitment regarding safety; including the promotion of a

positive safety culture.
ii) Includes a statement about the provision of the necessary resources for the
implementation of the safety policy;
iii) Is communicated throughout the organization.
iv) Is periodically reviewed to ensure continued relevance to the organization.

The requirement to have a defined safety policy is an element of the Safety Policy and
Objectives component of the SMS framework.

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The safety policy also reflects the commitment of senior management to:

i. Compliance with applicable regulations and standards of Air India Limited;

ii. Ensuring the management of safety risks to aircraft operations;
iii. The promotion of safety awareness;
iv. Continual improvement of operational performance.

3.4.3.1 The safety policy is to be reviewed at least once in two years to ensure continued
relevance to the organization.

Such policy shall be documented in the Operations Manual and all other Manuals,
which are controlled documents. To enhance effectiveness, the Policy shall be
communicated and made visible throughout the organization through dissemination of
communiqués, posters, banners and other forms of information in a form and language
which can be easily understood.

3.4.4 Air India Limited shall have a corporate policy that states the commitment of the
organization to continual improvement of the management system.

Air India Limited through its Corporate Policies on Safety, Quality, Security,
Environment as well as Corporate Social Responsibility (CSR) reflects its commitment
for continual improvement. All these policies are signed by the Accountable Manager
and are followed by the senior management to ensure measuring and evaluating on a
continuing basis, and making changes that improve the management system and the
culture. Ideas for improvement may come from internal and external sources;
therefore the organization would be constantly monitoring all sources and willing to
make changes as necessary to keep the management system refreshed and strongly
focused on improving operational safety and security performance.
Such policy commits the organization to:

i. Regular review of performance-based indicators by senior management;

ii. Regular analysis of malfunctions or undesirable operational results;
iii. Follow-up of corrective actions and their effectiveness in improving operational
performance.

3.4.4.1 The continual improvement policy is to be reviewed at least once in two years to
ensure continuing relevance to the organization.

An SMS, as well as QMS, EMS, Security Management System (SeMS) and DMS are
unique components of the overall management system of Air India Limited and are
implemented for continual improvement in accordance with the policy of Air India
Limited

A continual improvement policy is documented in Organisation Manual, Operations

Manuals and other Manuals which are controlled documents. They are made visible
throughout the organization by disseminating communiqués, posters, banners and
other forms of informational media.

3.4.5 Air India Limited shall have a corporate safety reporting policy that encourages
personnel to report hazards to aircraft operations and, in addition, defines
Organisation‘s policy regarding disciplinary action, to include:

i) Types of operational behaviours that are unacceptable;

ii) Conditions under which disciplinary action would not apply.

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Safety Reporting Policy is an element of the Safety Policy and objectives component of
the SMS framework. Safety Reporting is a key aspect of SMS hazard identification and
risk management. The Safety Reporting Policy encourages individuals to report hazards
and operational deficiencies to management. It all assures personnel that their inputs
are highly desired and are vital to safety and secure operations.

3.4.5.1 The Safety Reporting Policy is reviewed at least once in two years to ensure continuing
relevance to the organization.

3.4.6 Air India Limited shall ensure the management system defines the safety
accountabilities, authorities and responsibilities of management and non-management
personnel throughout the organization, and specifies:

i) The levels of management with the authority to make decisions regarding risk
tolerability with respect to the safety and/or security of aircraft operations;

ii) Responsibilities for ensuring operations are conducted in accordance with applicable
regulations and standards of Air India Limited;
iii) Lines of safety accountability throughout the organisation, including direct
accountability for safety and/or security on the part of senior management:

iv) Responsibilities of members of management, irrespective of other functions, as well as

of non-management personnel, with respect to the safety performance of the
organization.

The definition of authorities and responsibilities of management and non-management

personnel is an element of the Safety Policy and Objectives component of the SMS
framework.

a. Accountability is the obligation to accept ultimate responsibility and be answerable for

decisions and policies, and for the performance of applicable functions, tasks or actions.
Accountability may not be delegated.
b. Authority is the delegated power or right to command or direct activities, and to make
decisions.
c. Responsibility is the obligation to execute or perform assigned functions, duties, tasks
and/or actions. Responsibility may be accompanied by an appropriate level of delegated
authority.

In the context of an SMS, accountability means being responsible for taking corrective
actions, either to address hazards and/or errors identified through reporting or from
other sources, or in response to events, such as accidents and incidents.

An effective management system has lines of authority and responsibility that flow
from corporate senior management into all operational areas of the organization.
Delegation of authority and assignment of responsibility is described and
communicated such that it is understood throughout the organization. As a minimum,
organization charts, or organograms, are acceptable means for documenting the
structure of a management system.

Management positions critical to operational safety or security may require enhanced

job descriptions or terms of reference that reflect specialized requirements inherent in
certain key positions. Such specialized requirements would include any delegation of
authority exercised by personnel on behalf of an authority (e.g., designated or
authorized flight examiner).

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Compliance with regulatory requirements, as well as internal policies and procedures, is

an essential element of a safe and secure operational environment. The responsibility for
ensuring compliance with both regulatory and internal requirements is specified and
assigned within the management system. Job descriptions, terms of reference and
operating manuals are examples of appropriate locations for documenting management
system responsibilities.

3.4.7 Air India Limited shall have processes for the communication of safety information
throughout the organization to ensure personnel maintain an awareness of the SMS
and current operational safety issues.

Safety communication is an element of the Safety Promotion component of the SMS

framework. The general intent of safety communication is to foster a positive safety
culture in which all employees receive ongoing information on safety issues, safety
metrics, specific hazards existing in the workplace, and initiatives to address known
safety issues. Such communication conveys safety-critical information, and explains
why particular safety actions are taken and why safety procedures are introduced or
changed.

3.4.8 Air India Limited shall have processes to monitor and assess it’s SMS processes in
order to maintain or continually improve the overall effectiveness of SMS throughout
the organization.

Continual improvement of the SMS is an element of the Safety Assurance component

of the SMS framework. Continual improvement is overseen by a strategic committee of
senior management officials that are familiar with the workings and objectives of the
SMS. Such committee is called Safety Review Board (SRB), which is a very high level,
strategic committee chaired by the accountable executive and composed of senior
managers, including senior line managers responsible for functional areas in operations
(e.g. flight operations, engineering and maintenance, cabin operations) who meet once
a quarter as a part of Safety Review Meetings and once a year as a part of Safety
Review Board.

To ensure front line input as part of the SMS review process, along with flight safety
and other key operational areas, Safety Action Groups (SAGs) function to address
implementation issues in front line operations to satisfy the strategic directives of the
SRB as well as discuss the mandatory and voluntary reports along with the risk
assessment.

3.4.9 Air India Limited shall have a program that ensures personnel throughout the
organization are trained and competent to perform SMS duties. The scope of such
training shall be appropriate to each individual‘s involvement in the SMS.

SMS training is an element of the Safety Promotion component of the SMS framework.
Within an SMS, both management personnel (including the Accountable Executive) and
non-management personnel are expected to complete SMS training. The content of
such training is appropriate to the individual‘s responsibilities and involvement in the
SMS. A training curriculum includes modules that provide an overview of the elements
of SMS such as :

i. Event investigation and analysis techniques;

ii. Hazard identification;
iii. Risk assessment and mitigation;
iv. Audit principles and methodology;

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v. Communication techniques;
vi. Safety reporting;
vii. SMS implementation, analysis and continual improvement;
viii. Emergency response preparedness.

3.4.10 Air India Limited shall have SMS documentation that includes a description of:

i) The safety policy and objectives, SMS requirements, SMS processes and procedures,
the accountabilities, authorities and responsibilities for processes and procedures, and
the SMS outputs;

ii) Its approach to the management of safety, which is contained in a manual as a means
of communication throughout the organization.

SMS documentation is an element of the Safety Policy and Objectives component of the
SMS framework. SMS documentation describes both the corporate and operational areas
of safety management to show continuity of the SMS throughout the organization.
Documentation includes description of management positions and associated
accountabilities, authorities, and responsibilities within the SMS.

SMS documentation addresses:

i. Scope of the SMS;

ii. Safety policy and objectives;
iii. Safety accountabilities;
iv. Key safety personnel;
v. Documentation control procedures;
vi. Coordination of emergency response planning;
vii. Hazard identification and risk management schemes;
viii. Safety assurance;
ix. Safety performance monitoring;
x. Safety auditing (safety and quality auditing may be combined);
xi. Management of change;
xii. Safety promotion;
xiii. Outsourced services.

SMS documentation is incorporated in the Corporate Safety Management System

Manual, as well as the Manuals of all the Departments including Flight Safety and other
Operational areas.

The SMS implementation plan is kept up to date by Air India Limited.

3.4.11 Air India Limited shall have a hazard identification program that is implemented and
integrated throughout the organization, to include:

i) A combination of reactive and proactive methods for safety data collection;

ii) Processes for safety data analysis that identify existing hazards and predict future
hazards to aircraft operations
Hazard identification is an element of the Safety Risk Management component of the
SMS framework.
Hazard identification processes are necessarily formalized, coordinated and consistently
applied on an on-going basis in all areas of the organization where there is a potential
for hazards that could affect aircraft operations.

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To be effective, reactive and proactive processes are used to acquire information and
data, which are then analyzed to identify existing or predict future (i.e. potential)
hazards to aircraft operations. Examples of processes that typically yield information or
data for hazard identification include:

i. Confidential or other reporting by personnel;

ii. Investigation of accidents, incidents, irregularities and other non-normal events;
iii. Flight data analysis;
iv. Observation of flight crew performance in line operations and training;
v. Quality assurance and/or safety auditing;
vi. Safety information gathering or exchange (external sources).

Processes would be designed to identify hazards that might be associated with

organizational business changes (e.g. addition of new routes or destinations,
acquisition of new aircraft type(s), the introduction of significant outsourcing of
operational functions).

Hazards are assigned a tracking number and recorded in a log / Register or database.
Each log / Register or database entry would normally include a description of the
hazard, as well as other information necessary to track associated risk assessment and
mitigation activities. The guidelines provided in DGCA Circular are to be adopted for
this purpose.

3.4.12 Air India Limited shall have a safety risk assessment and mitigation program that
includes processes implemented and integrated throughout the organization to ensure:

i) Hazards are analyzed to determine corresponding safety risks to aircraft operations;

ii) Safety risks are assessed to determine the requirement for risk mitigation action(s);
iii) When required, risk mitigation actions are developed and implemented in operations.

Risk assessment and mitigation is an element of the Safety Risk Management

component of the SMS framework. To be completely effective, a risk assessment and
mitigation program will be implemented in a manner that:

i. Is active in all areas of the organization where there is a potential for hazards that
could affect aircraft operations;
ii. Has some form of central coordination to ensure all existing or potential hazards that
have been identified are subjected to risk assessment and, if applicable, mitigation.
iii. The safety risks associated with an identified existing or potential hazard are
assessed in the context of the potentially damaging consequences related to the
hazard. Safety risks are generally expressed in two components:
iv. Likelihood of an occurrence;
v. Severity of the consequence of an occurrence.

Matrices that quantify safety risk acceptance levels are developed to ensure
standardization and consistency in the risk assessment process. Separate matrices with
different risk acceptance criteria are sometimes utilized to address long-term versus
short-term operations. A risk register / Hazard Register is employed for the purpose of
documenting risk assessment information and monitoring risk mitigation (control)
actions.

3.4.13 Air India Limited shall have an operational safety reporting system that is implemented
throughout the organization in a manner that:

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i) Encourages and facilitates personnel to submit reports that identify safety hazards,
expose safety deficiencies and raise safety concerns;

ii) Ensures mandatory reporting in accordance with applicable regulations;

iii) Includes analysis and management action as necessary to address safety issues
identified through the reporting system.

Operational reporting is considered a proactive hazard identification activity in an SMS.

Frontline personnel, such as flight or cabin crew members and maintenance
technicians, are exposed to hazards and face challenging situations as part of their
everyday activities. An operational reporting system provides such personnel with a
means to report these hazards or any other safety concerns so they may be brought to
the attention of relevant managers.

To build confidence in the reporting process and encourage more reporting, an

acknowledgement is to be provided to each person that submits a report. An effective
system provides for a review and analysis of each report to determine whether a real
safety issue exists, and if so, ensure development and implementation of appropriate
action by responsible management to correct the situation.

3.4.14 Air India Limited shall have a confidential safety reporting system that is implemented
throughout the organization in a manner that encourages and facilitates the reporting
of events, hazards and/or concerns resulting from or associated with human
performance in operations.

The specified confidential safety reporting system is sometimes referred to as a

Confidential Human Factors (or Incident) Reporting System. The success of a
confidential safety reporting system depends on two fundamentals:

i. The ability of the management to assure absolute protection of a report submitted

by any individual;
ii. The level to which individuals within the organization exercise their freedom to
report actual or potential unsafe conditions or occurrences.
Procedures should be in place to protect confidentiality (e.g. de-identification).

3.4.14.1 There is a difference between confidential reporting and anonymous reporting.

Confidential reporting is the preferred system because it permits feedback to the
reporter in response to the report. Not only is the reporter entitled to an explanation,
but also such feedback provides excellent incentive for the submission of future
reports. The effectiveness of a confidential safety reporting system is determined by a
basic requirement for safeguarding safety and risk information. Individuals will continue
to provide information only when there is confidence that such information will be used
only for safety purposes and will never be compromised or used against them.

3.4.14.2 An effective confidential safety reporting system shall include:

i. A process that provides absolute protection of confidentiality;

ii. An articulated policy that encourages reporting of hazards and human errors in
operations;
iii. A shared responsibility between the individual flight and cabin crew members (or, if
applicable, respective professional associations) and the organization to promote a
confidential safety reporting system;

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iv. A process for secure de-identification of confidential reports;

v. A tracking process of action taken in response to reports;
vi. A process to provide feedback to the reporter;
vii. A communication process for ensuring flight and cabin crew members, as well as
other relevant personnel, are informed of potential operating hazards through
dissemination of de-identified report information.

3.4.15 Air India Limited shall have a non-punitive safety reporting system that is implemented
throughout the organization in all areas where operations are conducted.

A non-punitive reporting system might also be referred to as an open reporting system.

Such system might be considered an attribute of a reporting culture.

Front line operational personnel are often in the best position to observe and identify
operational hazards and conditions, including the actions or behavior of other
personnel, that could lead to accidents or incidents. Experience has shown that
personnel will not provide information if there is apprehension or fear that such
reporting will result in disciplinary action. To be effective, a non-punitive safety
reporting system assures employees that the reporting of unintentional errors does not
result in disciplinary or punitive action being taken against the reporter or other
individuals involved unless such errors result from illegal activity, willful misconduct or
other egregious actions, as defined by Air India Limited. Also, in such a system
employees are assured that the identity or information leading to the identity, of any
employee who reports an error under this policy is never disclosed unless agreed to by
the employee or required by law. A non-punitive safety reporting system is documented
in Organizational Manual, Operations Manuals and other controlled documents.

3.4.16 Air India Limited shall have processes for setting performance measures as a means to
monitor the operational safety performance of the organization and to validate the
effectiveness of safety risk controls.

Setting measurable safety objectives is an element of the Safety Assurance component

of the SMS framework. By setting performance measures, Air India Limited is able to
track and compare its operational performance against a target (i.e. the performance
objective, expressed as a rate or number reduction) over a period of time (e.g. one
year). Achievement of the target (or objective) would represent an improvement in the
operational performance.

The use of performance measures is an effective method to determine if desired safety

outcomes are being achieved, and to focus attention on the performance of the
organization in managing operational risks and maintaining compliance with relevant
regulatory requirements. In addressing operational performance, meaningful measures
focus on lower level (i.e. lower consequence) occurrences or conditions that are
considered to be precursors to serious events. Performance measures may be specific
to a certain area of operations or may be broad and apply to the entire system.

In addressing compliance, meaningful measures, as a minimum, would focus on

compliance with significant regulatory requirements (as determined) in all operational
areas. Ideally, performance measures are designed to be challenging, which, in turn,
enhances the effectiveness of the risk management system.

Performance measures may be set in almost any operations or maintenance area.

Some possible examples include:

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i. Flight operations (e.g., landing tail strikes, unsatisfactory line or training

evaluations);
ii. Operational control (e.g., fuel diversions due to fuel);
iii. Engineering and maintenance (in-flight engine shutdowns, aircraft component /
equipment failures);
iv. Cabin operations (inadvertent slide deployments);
v. Ground handling (aircraft damages due to vehicles or equipment);
vi. Cargo operations (dangerous goods spills);
vii. Operational security (unauthorized interference or access events).

3.4.17 Air India Limited shall have a process to identify changes within or external to the
organization that have the potential to affect the safety of aircraft operations, and:

i) For internal changes, ensure safety risk is considered before such changes are
implemented;
ii) For external changes, evaluate the adequacy of existing risk controls when such
changes will affect the operational environment.

Change management is an element of the Safety Assurance component of the SMS

framework.

Change management is considered a proactive hazard identification activity in an SMS.

Change may affect the appropriateness or effectiveness of existing safety risk mitigation
strategies. In addition, new hazards and related safety risks may be inadvertently
introduced into an operation whenever change occurs.
A change management process is designed to ensure risk management is applied to
any internal or external changes that have the potential to affect established
operational processes, procedures, products and services. Internal changes typically
include organizational expansion, contraction or consolidation, new initiatives, business
decisions, as well as the introduction of new or the modification of existing systems,
equipment, programs, products or services.

External changes could include new regulatory requirements or changes to the

operating environment (e.g. new security regulations, amendments to the dangerous
goods regulations, changes to the air traffic control system).

3.4.18 Flight Safety Analysis Program

3.4.18.1 Air India Limited shall have a flight safety analysis program that provides for the
identification of hazards and the analysis of information and data associated with
aircraft operations, to include:

i) Implementation of systematic processes for identifying and analyzing hazards and

potentially hazardous conditions;
ii) Production of relevant analytical information and data for use by operational
managers in the prevention of accidents and incidents.

A primary function of a flight safety analysis program is hazard identification, which is

an element of the Safety Risk Management component of the SMS framework. The
flight safety analysis program primarily provides operational hazard identification and
data analysis services for use by operational managers.

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The flight safety analysis program is part of an independent corporate safety structure,
which has a direct line of reporting to senior management. This type of structure allows
an effective and fully integrated system of prevention and safety across all relevant
operational disciplines of the organization.

3.4.18.2 Air India Limited shall have a designated manager with appropriate qualifications,
authority and independence (from operational management), that is responsible for the
performance of the flight safety analysis program, and for ensuring communication and
coordination with appropriate operational managers.

The Chief of Flight Safety oversees the implementation of all activities and processes
associated with the program. He shall meet the qualification and experience criteria as
laid down by DGCA.

3.4.18.3 Air India Limited shall have a process to ensure significant issues arising from the flight
safety analysis program are subject to management review.

Management review of flight safety issues supports the continual improvement of

safety performance, which is an element of the Safety Assurance component of the
SMS framework. Such review permits senior management to consider issues that have
the potential to affect the safety of operations, and ensure appropriate corrective or
preventive actions have been implemented and are being monitored for effectiveness in
preventing accidents and incidents.

Air India Limited has Senior Management Review Meetings twice a year besides the
Safety Review Board Meeting once a year to comply with the same.

3.4.18.4 Air India Limited shall have a means for disseminating information and data from the
flight safety analysis program to appropriate operations personnel.

Promulgation of safety information is an element of the Safety Promotion component of

the SMS framework. As a means of safety promotion, an effective flight safety analysis
program includes a means for the promulgation and dissemination of safety
information and data for the continuing education and interest of operational and other
associated personnel. Such dissemination of information might include an up-to-date
status of operational performance against stated performance measures.

The process ensures a method of safety information dissemination commensurate with

the size of the operation. Typical means of dissemination include a magazine,
newsletter or bulletin issued periodically. Electronic media in various forms are also
effective in the timely dissemination of information.

3.4.18.5 Air India Limited should have an electronic database to ensure effective management
of data derived from the flight safety analysis program.

The intent of this provision is for Air India Limited to have an electronic database to
manage information and data associated with aircraft operations in a manner that
results in the identification of hazards and the provision of information to operational
managers.

3.4.18.6 Air India Limited shall have a process for the investigation of aircraft accidents and
incidents, to include reporting of events in accordance with requirements of the State.

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Accident and incident investigation is considered a reactive hazard identification activity

in an SMS. A primary purpose of accident and incident investigation is hazard
identification, which is an element of the Safety Risk Management component of the
SMS framework. Investigations result in a report that describes the factors that
contributed to the event, which is then made available to responsible senior operational
managers to permit them to evaluate and implement appropriate corrective or
preventive action.

An effective investigation process includes:

i. Qualified personnel to conduct investigations (commensurate with operation

size);
ii. Procedures for the conduct of investigations;
iii. A process for reporting investigative results;
iv. A system for implementing any corrective or preventive action;
v. An interface with relevant external investigative authorities (when applicable);
vi. A process for the dissemination of information derived from investigations.

To ensure awareness among operational personnel, information derived from

investigations is disseminated to relevant areas throughout the organization.

In the event of a major accident, Air India Limited responds to participates in an

investigation in accordance with DGCA requirements and provisions contained in ICAO
Annex 13. Such capability requires Air India Limited to maintain an ongoing interface
with relevant investigative authorities to ensure preparedness in the event a major
accident occurs.

3.4.18.7 Air India Limited shall have a process for identifying and investigating irregularities and
other non-routine operational occurrences that might be precursors to an aircraft
accident or incident.

Investigation of operational irregularities is considered a reactive hazard identification

activity in an SMS. A primary purpose of investigating non-routine operational
occurrences is hazard identification, which is an element of the Safety Risk
Management component of the SMS framework.

The investigation of irregularities or non-routine occurrences is a hazard identification

activity. Minor events, irregularities and occurrences occur often during normal
operations, many times without noticeable consequences. Identifying and investigating
certain irregular operational occurrences can reveal system weaknesses or deficiencies
that, if left un-checked, could eventually lead to an accident or serious incident. These
types of events are referred to as accident precursors.

A process to monitor operations on a regular basis permits the identification and

capture of information associated with internal activities and events that could be
considered precursors. Such events are then investigated to identify undesirable trends
and determine contributory factors.

The monitoring process is not limited to occurrences, but also includes a regular review
of operational threats and errors that have manifested during normal operations.
Monitoring of normal operations can produce data that further serve to identify
operational weaknesses and, in turn, assist the organization in developing system
solutions.

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As with the investigation of accidents and serious incidents, the investigation of minor
internal occurrences results in a report that is communicated to relevant operational
managers for analysis and the possible development of corrective or preventive action.

3.4.18.8 Air India Limited shall have a flight data analysis (FDA) program that is non-punitive
and contains adequate safeguards to protect data sources. The program shall include
for aircraft of a maximum certified takeoff mass in excess of 20,000 Kgs (44093 lbs) a
systematic download and analysis of electronically recorded aircraft flight data.

Flight data analysis is considered a reactive and proactive hazard identification activity
in an SMS. A primary purpose of an FDA program is hazard identification, which is an
element of the Safety Risk Management component of the SMS framework.
The systematic download and analysis of recorded flight data has been used by
international airlines for many years to identify hazards, evaluate the operational
environment, validate operating criteria and establish training effectiveness.

As a minimum, an acceptable program for the analysis of recorded aircraft flight data
includes the following elements:

i. A manager and staff of flight operations experts, commensurate with the size of
the operation, to provide verification and analysis of the data collected from the
aircraft fleet under the Organisation‘s program;

ii. Aircraft designated within Air India‘s fleet that provide downloadable flight data
from onboard recording systems, such as the flight data recorder (FDR) or
quick access recorder (QAR);

iii. A system for downloading and transferring recorded data from the aircraft to a
data analysis system;

iv. A data analysis system that transforms raw digital data into a usable form of
information that can then be verified, processed, categorized and analyzed by
flight operations experts for flight safety purposes;

v. A process for applying the output from flight data analysis to the management
of risk and assessment of flight operations performance;
vi. A process for management of the data, to include security and retention. All or
certain of the elements could be outsourced to an external party; however, Air
India Limited would retain overall responsibility for the maintenance of the
program.

The most comprehensive approach to flight data analysis would be a program that
includes not only systematic download and analysis of electronically recorded aircraft
flight data (as described above), but also acquisition, correlation and analysis of flight
information derived from other sources.

Flight information is analyzed collectively to identify hazards, system weaknesses,

process breakdowns, regulatory violations and other trends or conditions that could
potentially lead to accidents or serious incidents. The process includes a method of risk
analysis and prioritization to enable the development and implementation of effective
corrective or preventive action.

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3.4.18.9 Air India Limited has a Flight Data Analysis Program as given above, which is
integrated with the Corporate SMS and includes :-

i. A systematic download and management of electronically recorded Flight Data from

applicable aircraft in excess of 20,000 kgs.
ii. Analysis of data performed in a consistent and standardised manner
iii. Methods for detecting and analysing events and data trends.
iv. Methods for developing and implementing corrective or remedial action to address
adverse events or trends
v. Procedures for ensuring remedial actions are taken in a non-punitive manner.
vi. Definition and application of safeguards that de-identify and ensure security of
program data and information.
The FDA program fits into the Safety Assurance (safety performance
monitoring/measuring) and Safety Risk Management (hazard identification) components
of the SMS framework. The practice of analyzing recorded data from routine flight
operations is a cornerstone in support of accident prevention programs. Rather than
reacting to serious incidents, an effective FDA program enables a proactive identification
of safety hazards associated with flight operations.

An FDA program is also used for:

i. Routine flight operational measurements;

ii. Incident investigations;
iii. Continuing airworthiness.

A key element in developing a FDA program is gaining the support of the flight crew
members. Such support is typically achieved through a policy and/or procedures formal
agreement that lays out the conditions for ensuring the program is non-punitive and
downloaded flight data is de-identified and secure. If applicable, such policy and/or
procedures would typically be set forth in a formal agreement with the association that
represents flight crew members.

It is important that the FDA program clearly defines the meaning of a non-punitive
environment, or what is commonly known as a Just Culture, and that relevant program
participants, particularly flight crew members:

i. Have a clear understanding of the types of operational behaviours that are

unacceptable, and the conditions under which disciplinary action would or would not
apply.
ii. Are provided with enough information about the process to ensure a perception of
fair treatment in accordance with program policy and procedures.
iii. Have confidence that non-punitive (or Just Culture) principles will be applied in the
treatment of events identified under the FDA program.

Within an FDA program, the application of non-punitive (or Just Culture) principles
typically includes assurance that:

i. Flight data and other relevant information are analyzed thoroughly such that, as far
as reasonably practicable, all relevant factors associated with an event are identified,
not just the action or inaction of specific individuals.
ii. Investigation of FDA events focuses on systemic issues that might influence
behaviours, rather than on individual actions.
iii. Individuals involved in the investigation of an event will be treated fairly based on the
quality of their behavioural choices.

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iv. Factual details of an event are provided to relevant operational managers so that
they may conduct a Just Culture review.

All or certain of the FDA program elements could be outsourced to an external party;
however, the operator would retain overall responsibility for the maintenance of the
program. The most comprehensive approach to flight data analysis would include not
only the systematic download and analysis of electronically recorded aircraft flight data,
but also acquisition, correlation and analysis of other information derived from
operational safety reports, regulatory authorities, investigative bodies, OEMs and other
operators.

Further guidance may be found in the following source documents:

i. ICAO Doc 9859, Safety Management Manual, and ICAO Doc 10000, Manual on
Flight Data Analysis Programmes (FDAP).
ii. CASA CAAP SMS-4(0), Guidance on the establishment of a Flight Data Analysis
Program (FDAP)–Safety Management Systems (SMS).
iii. FAA Advisor Circular AC No: 120-82, Flight Operational Quality Assurance.
iv. UK CAA CAP 739, Flight Data Monitoring.

3.4.18.10 The FDA Program Manager is the authorised manager for performance of FDA who
coordinates with Chief of Flight Safety and Head-Corporate SMS & QMS for :
i. Program integration and risk management within SMS
ii. Coordinating with relevant operational areas of the organisation to ensure FDA
findings are subjected to additional validation and assessment, and addressed with
appropriate follow-up action.
iii. Disseminating de-identified information to relevant operational managers to ensure
an awareness of FDA issues and results
iv. Liaison with relevant external entities, including OEMs, and regulatory authorities.

To be effective, the manager of the FDA program has:

i. Independence from line management;
ii. A high level of integrity and impartiality;
iii. Full support of management and flight operations (including flight crew)
personnel;

Qualifications for the FDA program manager includes:

i. Good management, analytical, presentation, diplomatic skills;
ii. A working knowledge and understanding of flight operations;
iii. The ability to effectively liaise with senior management and flight operations
personnel (including flight crews), as well as with representatives from
maintenance, safety, training, and applicable professional associations;
iv. Formal training or background experience in data processing, statistics and trend
analysis.

3.4.18.11 The FDA Program is elaborated in Flight Safety Manual and the FDA Handbook which
includes:
i. The purpose or aim of the FDA program;
ii. Program functions; responsibilities of personnel that perform program functions.
iii. Policies and procedures for program data management that address data
integrity, access, handling, protection, disclosure, storage and retention;
iv. Methods for obtaining de-identified flight crew feedback when specific follow-up
is required for contextual information;

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v. Conditions for flight crew member advisory briefings (constructive) and remedial
training (in a non-punitive manner);
vi. Conditions under which confidentiality may be withdrawn (e.g. willful misconduct,
gross negligence);
vii. Participation of flight crew member representative(s) in the assessment of the
data;
viii. Processes for program review to ensure the achievement of stated goals and the
identification of potential areas of improvement.

3.4.18.12 The FDA Program includes the following functions:

i. Flight operations interpreter(s) responsible for placing FDA data into a credible
context.
ii. Technical interpreter(s) responsible for the interpretation or analysis of FDA data
with respect to the technical aspects of aircraft operation.
iii. Flight crew liaison that is assigned the permission/responsibility for confidential
discussions with flight crew members involved in events highlighted by FDA.
iv. Engineering technical support personnel responsible for ensuring the
serviceability of mandatory FDA systems and equipment.
v. Air safety coordinator(s) responsible for cross-referencing and presenting
information/data in a credible integrated context.
vi. Replay administrator(s) responsible for the day-to-day operation of the program
elements, including data collection, analysis and security, and the production of
associated reports.

To be effective, team personnel that perform FDA functions specified in this standard
has the following background, skills and/or capabilities:
i. Flight operations interpreter(s) that are flight crew members and have an in-depth
understanding of the aircraft types, operating procedures, routes and airports.
ii. Technical interpreter(s) that have maintenance engineering and/or appropriated
maintenance technical experience, and are familiar with the power plant /structures
/systems departments, information sources/requirements and engineering
monitoring programs.

3.4.18.13 Air India Limited ensures appropriate training is provided to all concerned personnel are
trained and qualified to perform the FDA program. The training program contains the
elements necessary to ensure FDA program personnel are competent to perform
assigned duties and functions within the program.

FDA personnel complete initial training prior to performance of any program functions,
and subsequent recurrent training to ensure continued competency.

3.4.18.14 Information and records from the FDA program are protected and program findings are
coordinated with relevant operational areas for further validation and assessment and for
determination of appropriate follow up action. The FDA program includes the following
systems:
i. On-board systems for capturing a range of flight parameters (consistent with
aircraft capability) and, as applicable:
a) Recording such data for download, and/or
b) Transmitting such data to secure ground-based computer systems.
ii. If applicable, systems that permit the secure transfer of recorded flight data from
aircraft to secure ground-based computer systems;
iii. Data replay and analysis systems that:
a) Convert raw flight data into usable data for analysis;

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b) Provide data quality checks to detect abnormalities.

c) Manage data de-identification;
d) Process data for event and exceedance detection, routine data measurement,
e) event investigation and continued airworthiness investigation;
f) Produce information and reports for trend analysis and follow-up action.
iv. Database(s) for data retention and retrieval.

In addition to the above, FDA program also includes software for flight animation that
facilitates a visual simulation of actual flight events.
The intent of this provision is the existence of a training program that contains the
elements necessary to ensure FDA program personnel are competent to perform
assigned duties and functions within the program.
FDA personnel complete initial training prior to performance of any program functions,
and subsequent recurrent training to ensure continued competency.

3.4.18.15 FDA program has the provisions for the management and protection of program data and
information. Such standards should define:

i. Methods for ensuring the integrity and validity of downloaded flight data;
ii. Requirements for physical security of program media, systems, equipment and
facilities;
iii. Requirements and procedures for data de-identification and confidentiality;
iv. Methods for maintaining and presenting event and exceedance information for
trend analysis;
v. Policies and procedures for data retention and retrieval;
vi. Processes for data archiving and retrieval;
vii. Policy and procedures for the distribution of program findings and other
information to relevant operational areas of the organization;
viii. Policy for publishing findings or other information resulting from the FDA
program;
ix. Processes for assessing and improving data management policies, methods and
procedures.

Effective management and protection of FDA program data and information is critical in
ensuring the success of, and perhaps even the survival of, an FDA program.

FDA data de-identification is a critical area of protection, and therefore is normally well
defined in program standards. Air India Limited will provide a clear statement that
assures the nondisclosure of flight crew individuals associated with or linked to FDA
events, except when it can be determined there is an unacceptable safety risk if specific
action regarding the flight crew is not taken.

In general, a successful FDA program requires the establishment of an acceptable level

of trust between management and its flight crews. Therefore, the safety intent of the
FDA program will be clearly documented so it is understood by all participants, and the
conditions of use and protection of program data and information will be explicitly
defined in a formal agreement involving the operator’s management, representatives of
its flight crews and the participating regulatory authority.

3.4.18.16 FDA program has processes to ensure program findings (e.g. hazards, adverse events
and trends, airworthiness issues) are coordinated with relevant operational areas of the
organization for further validation and assessment, and then for a determination of
appropriate follow-up action. Such coordination and follow-up action should be
accomplished within the SMS as follows:

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i. Hazard identification and safety risk assessment and mitigation.

ii. Event investigation.
iii. Continuing airworthiness assessment in accordance with Maintenance
Management Manual (MMM) procedures.

The primary aim of an FDA program is the continuous improvement of overall safety
performance. Therefore, the FDA program, which functions to monitor and measure
flight safety performance, is integrated in the Safety Assurance component of the SMS.

The FDA program is also used for safety hazard identification and, as such, is integrated
in the Risk Management component of the SMS. Within an SMS, there are typically
multiple systems used for hazard identification (e.g. accident/incident investigation,
operational safety reporting, change management). Therefore, risk management
processes are integrated in the SMS to ensure an efficient use of resources and
processes, and, where possible, an elimination or reduction of duplicated processes.

The primary aim of an FDA program is the continuous improvement of the overall safety
performance. Therefore, the FDA program, which functions to monitor and measure flight
safety performance, is integrated in the Safety Assurance component of the SMS.
The FDA program is also used for safety hazard identification and, as such, is integrated in
the Risk Management component of the SMS. Within an SMS, there are typically multiple
systems used for hazard identification (e.g. accident/incident investigation, operational
safety reporting, change management). Therefore, risk management processes are
integrated in the SMS to ensure an efficient use of resources and processes, and, where
possible, an elimination or reduction of duplicated processes.

Refer to ICAO Doc 9859, Safety Management Manual, and ICAO Doc 10000, Manual on
Flight Data Analysis Programmes (FDAP) for more detailed information regarding
integration of the FDP program into the SMS.

3.4.18.17 Air India Limited shall have a program for the systematic acquisition and analysis of
data from observations of flight crew performance during normal line operations.

Line monitoring is considered a proactive hazard identification activity in an SMS. Line

operations monitoring program is a completely different activity from line evaluation (or
line checking) of the flight crew. Line operations monitoring cannot be accomplished in
conjunction with any type of operational evaluation of the flight crew.

Under this program, flight crew performance in a normal line environment is observed
from the flight deck jump seat by individuals who have been specially selected and
trained. Observers, with the cooperation of the flight crew, systematically gather
operational data that can be analyzed and used to make real improvements to certain
areas of the operation. Observers are particularly aware of, and record, threats and
errors that occur in the operating environment.

The Line Operations Safety Audit (LOSA) is a well-known and successful example of a
normal line operations monitoring program.

An acceptable program shall have the following characteristics:

i. A planned and organized series of observations of flight crew performance during

normal line flights is conducted a minimum of once during every four year period.
ii. Observations are conducted on regular and routine line flights, and the flight crew

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is advised and clearly understands that normal line monitoring is not an evaluating,
training or checking activity. The flight crew would be expected to operate as if the
observer were not there.
iii. There is mutual support and cooperation from both the management of Air India
Limited and flight crew members (through their professional association, if
applicable).
iv. Participation from the flight crew is voluntary; observations are not conducted
unless permission is received from the flight crew.
v. Data collected from observations are confidential, de-identified and used for safety
enhancement purposes only. Data from an observation are never permitted to be
used for disciplinary action unless there is evidence of willful misconduct or illegal
activity.
vi. Procedures are in place to ensure data from observations are retained in a way
that ensures effective security.
vii. Objectives of observations are clearly defined, and collected data are always used
to address specific issues that affect flight safety.
viii. Observers are specifically selected and trained (calibrated) to ensure a high level of
consistency and standardization in the data being collected. Observers are
objective, impartial and have a high level of integrity.
ix. There is a process in place to ensure data collected from observations are
subjected to analysis from appropriately diverse subject matter experts to ensure
consistency and accuracy.
x. Data derived from observations are analyzed and presented in a manner that
identifies potential weakness and permits Air India Limited to develop appropriate
action(s) that will enhance specific aspects of the operation.
xi. Results from the monitoring program, including the corrective action plan, are
communicated to flight crew members.

3.4.19 The detailed requirements for Quality Assurance are provided in Quality & Safety
Audit Manual which is a part of Corporate Safety Management Manual, accepted by
DGCA.

3.4.20 The detailed requirements for Emergency Response Plan are provided in Emergency
Management Manual which is a part of Corporate Safety Management Manual,
accepted by DGCA.

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3.5 EXTERNAL SERVICE PROVIDERS – PROCUREMENT POLICY

All SBU Heads / Corporate Directors / Executive Directors shall ensure that a contract or
agreement is executed with external service providers that conduct outsourced
operations, maintenance or security functions. Such contract or agreement shall include
measurable specifications that can be monitored to ensure that requirements that affect
the safety and / or security of operations are being fulfilled.

The external service providers shall be audited by the “Quality Management System” to
ensure all requirements are being fulfilled.

The same would also be applicable for “wet lease” and “dry lease” agreements with any
external organization.

Air India Limited Safety Management System ensures that :

i. there is a policy establishing safety accountability and authority flow between
Air India Limited and the External Service Provider
ii. the External Service Provider has a safety reporting system commensurate with
its size and complexity that facilitates the early identification of hazards and
systemic failures of concern to the service provider.
iii. the safety/quality indicators to monitor External Service Provider’s performance
are developed, where appropriate;
iv. safety promotion process ensures External Service Providers employees are
provided with the organization’s applicable safety communications; and
v. any External Service Providers roles, responsibilities and functions relevant to
emergency response plan of Air India Limited are developed and tested.

The DGCA CAR Section 1, Series 'C', Part I, Issue II, dated 27 th July 2017,
mandates all Airlines and Service Providers including Subcontracted/Outsourced
Agencies to implement SMS.

3.5.1 Quality criteria for outsourced functions will follow the following pattern :-

i. Specify quality criteria,

ii. Initiate bidding process,
iii. Verify suitability/eligibility (e.g. on site audit & review of certificates),
iv. Select suitably qualified supplier,
v. List supplier on a supplier register,

3.5.2 The following Standards are required to be followed when selecting external service
providers/product suppliers.

i. We need to ensure that when we conclude an agreement with the service provider,
the agreement shall include measurable specifications that can be monitored by the
concerned functional representative to ensure requirements that affect the safety
and/or security of operations are being fulfilled.
ii. We need to have a process to monitor the external service providers to ensure
requirements that affect the safety and security of operations/maintenance are
being fulfilled.
We need to have a process to ensure products acquired from external suppliers, which
directly affect the safety or security of operations, meet required technical specifications
prior to being utilized in the conduct of operations/maintenance.

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3.6 In order to achieve the above standards of quality, the following procurement
procedures will be followed :-

Outsourced Services

1. The unambiguous and sufficiently detailed technical specifications required for the
outsourced service product shall include the requirement of accreditation or approval
(as applicable) by an appropriate recognized regulatory / quality / safety agency. If the
service provider / product supplier is not accredited by any recognized agency, the
service provider should agree to be pre-audited by Air India Limited during the
Technical evaluation. The detailed technical specifications shall include measurable
specifications to ensure the required quality / safety / security standards are fulfilled.

2. The Technical Evaluation Committee shall ensure that products being evaluated meet
the required technical specifications for the conduct of operations/maintenance. The
Technical Evaluation Committee shall verify the accreditation of the Service
provider/product supplier by an appropriate recognized Regulatory/Quality/Safety
agency e.g. DGCA, ISO, IOSA, EASA, FAA etc.

3. If the Service provider or product supplier is not accredited to any of the required
Regulatory/Quality/Safety, the TEC should approach QMS to conduct Audit of the
service provider or product supplier to ensure that they meet the required
regulatory/quality/safety and technical requirements. The QMS shall nominate a team
of qualified quality auditors comprising of at least one member from the concerned
functional area. This QMS team shall carry out the quality audit of the service
provider/product supplier and submit the report to the TEC. The TEC shall take into
account the QMS report when recommending a service provider/product supplier.

4. The contract with Service Providers shall specify measurable specifications of service
which can be easily measured by the officials who will be required to monitor the
services provided by the service provider. In order to ensure that the service
provider/product supplier conforms to quality/regulatory standards on continuous basis,
the contract shall also specify that the service provider/product supplier shall be audited
by the QMS at least once in two years.

5. All the contracts need to be renewed well before expiry. The re-negotiation for
contracts shall commence three months before expiry of the contracts and shall be
concluded at least one month before expiry of the contracts. The concerned
Department / Regional Head / Station Head shall be responsible to ensure the same.

6. All functional areas/ SBUs/ Departments / Regions shall ensure that the detailed
specifications and standard contracts for various types of outsourced services / products
are available. These technical specifications / contracts shall be revised at regular
intervals, as required.

7. All Ground Handling contracts shall include provision for availability of GPUs / ACUs.
This will help in saving fuel.

i. The airport manager of the station shall have copies of all the contracts of the Airport
so that he can effectively monitor the service provider in terms of quality, safety and
security.

ii. All fuel contracts shall be closely monitored for fuel quantity supplied and quality.

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iii. For all contracts above Rs. 10 crores, an Integrity clause / pact shall be required to
be signed by the Service Provider.

Aircraft/ Component Maintenance

In addition to the above, for aircraft and component maintenance :-

A) The service provider must be approved by DGCA as per CAR 145 AIR INDIA
organization (Refer AIR INDIA LIMITED CAR 145 MOE for details)

B) Aircraft Component and Material

For procurement of aircraft products (components / material/ consumables) following

are additional requirements:

i. Products can be directly purchased from OEMs

ii. The Supplier must be approved by DGCA as per CAR 145 AIR INDIA organization

(Refer AIR INDIA CAR 145 MOE for detail)

C) For “One off” policy on aircraft maintenance service provider and procurement of
products from unapproved sources refer AIR INDIA CAR 145 MOE

Include supplier in Quality Assurance programme.

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3.7 OUTSOURCING CONTROL - POLICY

3.7.1 AIR INDIA Limited shall always retain the responsibility for all outsourced functions in
all areas, including Operations, Maintenance or Security functions that have been
voluntarily transferred to an external service provider.

The QMS shall have a process to ensure a contract or agreement is executed with
external service providers that conduct outsourced functions, including operations,
maintenance or security functions for AIR INDIA Limited. Such contract or agreement
shall include or reference measurable specifications that can be monitored to ensure
requirements that affect the safety and/or security of operations are being fulfilled.

3.7.2 The QMS shall have a process to monitor external service providers that conduct
outsourced functions, including Operations, Maintenance or Security functions to ensure
requirements that affect the safety and/or security of operations are being fulfilled.

3.7.3 The QMS includes auditing as a process for monitoring external service providers.

3.7.4 If AIR INDIA Limited satisfies operational needs through a “wet lease” agreement with
any external organisation, there shall be a process to monitor the performance of such
external organisations to ensure operational safety and security needs of AIR INDIA
Limited are being fulfilled.

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3.8 Interface Management:

It shall be ensured that:

i. The safety accountability and authority flow with the sub-contractor is established.
ii. The sub-contractor has a safety reporting system commensurate with its size and
complexity that facilitates the early identification of hazards and systemic failures of
concern to the Air India Limited;
iii. The safety/quality indicators to monitor sub-contractor performance are developed,
where appropriate;
iv. The sub-contractor employees are provided and educated regarding Air India’s
Limited safety communications
v. The sub-contractor roles, responsibilities and functions relevant to the emergency
response plan are developed and tested.

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3.9 Management of Safety Risks:

3.9.1 Air India Limited shall have processes to ensure the management of safety risks in
outsourced operational functions conducted by external service providers for Air
India Limited :

i. If Air India Limited outsources such functions with external service providers
that have a valid SMS, QMS shall have coordination and monitoring processes
that ensure the management of safety in operations conducted for Air India
Limited.
ii. The risks identified from the Voluntary Hazard Reports received from
internal/external agencies are analyzed and mitigated as per Corporate SMS
Policy.
iii. It shall be ensured that the sub-contractor has a safety reporting system
commensurate with its size and complexity that facilitates the early
identification of hazards and Systemic failures of concern to Air India Limited;
iv. Air India Limited shall ensure that the sub-contractor roles, responsibilities and
functions relevant to the emergency response plan are developed and tested.

3.9.2 The intent is the assurance that safety risks are still managed when Air India
Limited outsources the conduct of operational functions to an external service
provider.

SMS is to be subjected to some type of formal validation in order to ensure full

implementation.

The following are examples of methods that provide SMS validation:

i. Approval or acceptance under a state safety program (SSP).
ii.An SMS validation audit conducted by any IOSA operator.
iii.
IOSA registration.
iv.ISAGO registration, if such registration reflects conformity with all designated
SMS provisions.
v. An SMS validation audit conducted under any other industry-recognized audit
program against provisions that address the full set of SMS elements.

SMS elements identified and defined by Air India Limited for implementation by a
non-SMS provider as specified in item i) a) would focus on hazard identification
(e.g. quality assurance program, operational safety reporting system, confidential
safety reporting system, accident/incident investigation program) and include the
need for training of involved personnel.

3.9.3 Corporate SMS will establish a communication link with service providers to ensure
any identified safety hazards, deficiencies and/or concerns relevant to operations
performed for Air India Limited are conveyed to Air India Limited.

SMS training for a provider's personnel as specified in item i) b) may be conducted

by the provider or other organization in accordance with arrangements with Air
India Limited.

3.9.4 Implementation of the specifications of this provision will be achieved through

contracts and other means as agreed to by Air India Limited and individual
external service providers. Examples of such means might include a
memorandum of understanding (MOU) or a side letter of agreement (SLOA).

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AIR INDIA LIMITED
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL

SAFETY POLICY

CHAPTER – 4
 CORPORATE SAFETY AI–ORG-SMS-001
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Issue-4 Rev-0 01 JUN 2018
SAFETY POLICY

4.1 SAFETY POLICY COMMITMENT

Safety policy is published in Chapter ‘0’ of all Corporate Manuals and all Departmental
Manuals.

Air India Limited has a corporate safety policy that:

i. Reflects the organizational commitment regarding safety;

ii. Includes a statement about the provision of the necessary resources for the
implementation of the safety policy;

iii. Is communicated throughout the organization.

The safety policy reflects the commitment of senior management to:

i. Compliance with applicable regulations and standards;

ii. Ensuring the management of safety risks to aircraft operations;

iii. The promotion of safety awareness;

iv. Continual improvement of operational performance.

The Corporate Safety Policy is documented in the Organisation Manual, Flight Safety
Manual, Operations Manual and other Manuals across the Organisation. It is
communicated and made visible throughout the organization through dissemination of
communiqués, posters, banners and other forms of information in a form and language
which can be easily understood. To ensure continuing relevance, the corporate policy
reviewed for possible update a minimum of every two years.

As per DGCA CAR “Management Commitment Requirements “for the safety policy is
issued in accordance with international and national requirements. The safety policy
statement :

i. reflects commitment regarding safety, including the promotion of a positive safety

culture;
ii. include a clear statement about the provision of the necessary resources for
implementation of the safety policy;
iii. include safety reporting procedures;
iv. clearly indicate which types of behaviours are unacceptable related to the Air India
Limited aviation activities and include the circumstances under which disciplinary
action would not apply ;
v. signed by the accountable executive and CMD of Air India Limited ;
vi. be communicated, with visible endorsement, throughout the organization; and
vii. be periodically reviewed to ensure it remains relevant and appropriate to the
organization.

The safety policy statement includes commitment to :

i. achieve the highest safety standards ;

ii. comply with all applicable regulatory requirements;
iii. comply with international standards;

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iv. adopt proven best practices appropriate to the activity ;

v. provide all the necessary resources;
vi. ensure safety is the primary responsibility of all managers;
vii. ensures that the safety policy is understood, implemented and maintained at all levels.

In order to mitigate the organization’s risks, the management includes the following:

i. document the organisation’s priorities;

ii. prescribe and document procedures for performing activities/processes
iii. provide training to the staff to develop necessary knowledge ,skills and attitude;
iv. provide safety directives and controls to ensure their compliance;
v. procure suitable equipment and systems to support activities and ensure its continuing
serviceability ; and
vi. ensures that necessary resources are deployed to maximize the organization’s safety
performance.

Based on its safety policy, Corporate SMS defines safety objectives , which are top-level
and short statement describing the organizations commitment to achieving safety.
Safety Objectives includes;

i. form the basis for safety performance monitoring and measurement ;

ii. reflect the organisation’s commitment to maintain or continuously improve the overall
effectiveness of the SMS ;
iii. be communicated throughout the organization with the intent that all personnel are
made aware of their individual safety obligations; and
iv. be periodically reviewed to ensure that they remain relevant and appropriate to the
service provider.

4.1.1 The Accountable Executive is the Chairman and Managing Director for Air India
Limited. The Corporate Safety Policy signed by the Accountable Executive is
reproduced below :

“Safety is one of the core business functions of Air India Limited covering all Air
Operator Certificates, subsidiaries and Strategic Business Unit(SBU) functions. We are
committed to developing, implementing, maintaining and constantly improving strategies
and processes to ensure that all our aviation activities take place under a balanced
allocation of organizational resources, aimed at achieving the highest level of safety
performance through a Corporate Safety Management System(SMS) covering all the
AOCs, subsidiaries and Strategic Business Units (SBUs) and meeting National and
International standards, while delivering our services.

All levels of management and all employees are accountable for the delivery of this
highest level of safety performance, starting with the Chairman and Managing Director
(CMD)) and Managing Committee of Air India Limited. All the Directors / SBU Heads /
Chiefs / Exec. Directors/Departmental Heads, will appropriately implement and
integrate the Safety Management System(SMS) throughout the Organisation to address
safety of aircraft operations.

The Corporate Safety policy will be carried forward by all Functional Heads to all
employees and shall be visible throughout the Organisation by means of
communiqué’s, posters, website and other terms of information.

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4.1.2 Air India Limited is committed to:

i. Support the management of safety through the provision of all appropriate resources,
that will result in an organizational culture that fosters safe practices, encourages
effective safety reporting and communication, and actively manages safety with the
same attention to results as the attention to the results of the other management
systems of the organization.

ii. Enforce the management of safety as a primary responsibility of all managers and
employees.

iii. Clearly define for all staff, managers and employees alike, their accountabilities and
responsibilities for the delivery of the organization’s safety performance and the
performance of our safety management system.

iv. Establish and operate hazard identification and risk management processes,
including a hazard reporting system, in order to eliminate or mitigate the safety risks of
the consequences of hazards resulting from our operations or activities to a point which
is as low as reasonably practicable (ALARP).

v. Ensure that no action will be taken against any employee who discloses a safety
concern through the hazard reporting system, unless such disclosure indicates, beyond
any reasonable doubt, an illegal act, gross negligence, or a deliberate or willful
disregard of regulations or procedures.

vi. Comply with and, wherever possible, exceed, legislative and regulatory requirements
and standards.

vii. Ensure that sufficient skilled and trained human resources are available to implement
safety strategies and processes.

viii. Ensure that all staff are provided with adequate and appropriate aviation safety
information and training, are competent in safety matters, and are allocated only tasks
commensurate with their skills. And ensure that personnel at all levels are involved in
establishment and maintenance of SMS

ix. Establish and measure our safety performance against realistic safety performance
indicators and safety performance targets.

x. Continually improve our safety performance through management processes that

ensure that relevant safety action is taken and is effective.

xi. Ensure externally supplied systems and services to support our operations are
delivered meeting our safety performance standards.

xii. Ensure the promotion of safety awareness among all personnel.

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SAFETY POLICY

4.2 GENERAL REQUIREMENTS – SAFETY POLICY

The safety policy is signed by the Accountable Executive of the organization.

The safety policy includes the responsibilities of management and employees with
respect to the safety performance of the SMS.

The safety policy is communicated to all the employees.

The safety policy includes:

i. a commitment to review the safety management system to determine its

effectiveness for continual improvement in the level of safety; This review will be
carried out atleast once in two years;
ii. procedures for reporting of a hazard, incidents and accidents;
iii. procedures for collection of data relating to a hazard, incidents and accidents, its
analysis and ;
iv. the conditions under which disciplinary action would not be applicable following
hazard reporting by employees.

4.2.1 The safety policy is in accordance with all applicable legal requirements and
international standards, best industry practices and reflects organizational
commitments regarding safety. It incorporates the latest IOSA standards also.

The safety objectives are linked to the safety performance indicators, safety
performance targets and action plans of the Corporate SMS of Air India Limited.

The systematic management of safety is a core business function, led by the board and
senior management levels to plan and implement a Safety Management System (SMS).
The SMS, described in an SMS Manual (SMSM) is dedicated to the business of Air India
Limited and is planned and drafted to meet the scope and nature of its overall system
and the sub-systems within the overall system.

As part of the SMS, Air India Limited is committed to :

a. developing, implementing, maintaining and constantly improving strategies and
processes to ensure that their aviation activities take place under a balanced
allocation of organisational resources: all aimed at achieving the highest level of
safety performance and meeting organisational, national and international
standards, while delivering services.
b. Ensure that all levels of management and all employees have declared and
appropriate levels and scope of accountabilities for the delivery of safety
performance, starting with the executive named as having overall and ultimate
accountability for safety and safety performance; “the Accountable Executive”.
c. Establish and implement a safety policy and safety objectives that reflect the
following:
i. Management commitment and responsibility
ii. Safety accountabilities
iii. Appointment of key safety personnel
iv. Coordination of emergency response planning
v. SMS documentation

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SAFETY POLICY

4.3 SAFETY POLICY DEVELOPMENT

The Safety Policy requirement and review will reflect the following:-

1. Meet the safety requirement needs of the organisation, which will, as a minimum,
comply with the regulations. The only exception to this are the exemptions, if any, for
which the compensatory safety risk controls need to be introduced, including review
timescales. The organisation:

a. acknowledges that the national requirements are minimum standards;

b. understands the need to exceed these where necessary in the pursuit of controlling
safety risks, and achieving the declared safety performance; and

c. recognises the desirability of seeking out and adopting good accepted international
practice.

2. Establish and implement a Safety Management System (SMS), the scope of which
covers the entire system including the sub-systems, in line with an Implementation
Plan, reflecting an agreed strategy, regulatory requirements and declared safety
performance. Safety requirements of the SMS will include (inter-alia) processes and
mechanisms:

a. For hazard identification and risk management, including a hazard reporting system,
in order to eliminate or mitigate the safety risks from the consequences of hazards
resulting from operations or activities; all to a point which is As Low As Reasonably
Practicable (ALARP).

b. To set demanding but realistic safety performance indicators, targets and action
plans, to be agreed with the DGCA, and monitored and measured by internal
processes.

c. To:
i. Continually review non-compliances which are the subject of exemptions, against
the relevant safety assessment or safety case, applying corrective action as
required by the agreed action plan and company’s safety requirements, and
advising the DGCA of any deviation from the agreed action plan.

ii. Advise the DGCA of any new non-compliance found and how the company plans
to meet the CAR on exemptions.

d. For the reporting, collection, recording and analysis of occurrence data.

e. To manage change, in relation to safety management and performance.

f. For two way communications between all staff and the management of the
organisation, including safety-critical information and safety promotion material, and
not forgetting interfaces with contractors and users.

g. To identify training needs, meet them in a timely manner and assess training
effectiveness.

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h. For the coordination of the operator emergencies with the relevant elements of the
organisation’s management systems and the appropriate internal and external
stakeholders.

i. For effective and disciplined document provision and control, the format and layout
will take account of readability and be as clear and concise as possible.

3. Support the management of safety through the provision of all appropriate resources,
including the appropriate quality policy and use of the quality assurance process, and
authority for decision making and budget expenditure that will result in an
organisational culture that:

a. fosters safe practices;

b. encourages effective safety reporting and communication; and
c. actively manages safety with the same attention to results as the attention to the
results of the other management systems of the organisation.

4. Clearly define and communicate for all staff, managers and employees alike, their
accountabilities and responsibilities for the delivery of the organisation’s safety
performance and the performance of the SMS.

5. Enforce the management of safety as a primary responsibility of all managers and

employees, not forgetting interfaces with contractors and users.

6. Ensure that:

a. No action will be taken against any employee who discloses a safety concern
through the hazard reporting system, unless such disclosure indicates, beyond any
reasonable doubt, an illegal act, gross negligence, or a deliberate or willful disregard
of regulations or procedures.

b. Sufficient skilled and trained human resources are available to implement safety
strategies and processes, including for any services outsourced.

c. All staff members are provided with adequate and appropriate aviation safety
information and training, are competent in safety matters, and are allocated only
tasks commensurate with their skills.

d. The organisation works cooperatively with users and other stakeholders, using
safety committees and focused joint safety teams, where necessary.

e. Externally supplied systems and services, to support their operations, meet the
organisation’s safety performance standards.

7. Continually improve safety performance through management processes that ensure

that relevant safety action is taken and is effective, including that related to non-
compliances.

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SAFETY OBJECTIVES

CHAPTER – 5
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SAFETY OBJECTIVES Issue-4 Rev-0 01JUN 2018

5.1 SAFETY OBJECTIVES

Air India Limited will have the Safety Management System committed to :

1. achieve a mature system for managing safety and the organisation’s contribution to
meeting the DGCA Safety Plan’s objectives by continually reviewing the SMS and
implementing any revisions deemed necessary from those reviews, at least once in 2
years.

2. Be satisfied that the organisation is operationally competent during day-to-day

operations and change, in terms of:

i. training in functional and professional areas (initial, recurrent and effectiveness);

ii. equipment, infrastructure, and service facility provision;
iii. maintenance of equipment, infrastructure, and service facilities;

iv. the provision and promulgation of data to the required accuracy;

v. safety performance setting and monitoring;

vi. reacting to occurrences and being proactive and predictive in identifying emerging
hazards;

vii. design, development and the entering into service of changes in airport
organisation, infrastructure, and facilities; and

viii. staffing establishment, including the:

a. appointment of the right people in the right jobs by a process that matches
personnel profiles to task competence needs, including key appointments in
safety-critical areas; and

b. establishment of specialist safety groups at the senior and other levels.

3. Be satisfied as an organisation, and be able to satisfy the DGCA, in relation to

contractors’ safety performance, by using a procedure to write safety requirements into
the contracting process, including:

i. bidding and contractual documentation;

ii. demonstration of task capability, in all areas of the service provision;

iii. supervision and surveillance requirements; and

iv. pre entry-into-service testing, in order to demonstrate fitness for purpose and the
meeting of the organisation’s safety performance requirements.

4. To seek improvements in safety performance where that is possible. Otherwise, maintain

safety performance, in line with that agreed with the DGCA, as part of safety assurance
as a component of the operational SMS (as distinct from SMS design).

5. To integrate the SMS with other management systems as the SMS matures; for it to
become part of overall business planning and operational system. In order to pursue,
in line with the implementation plan :

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i. Make effective and efficient use of resources by:

a. identifying the most significant risks to safety, and directing appropriate resource
to resolve those safety concerns; and
b. integrating management systems, such as using the QMS as a tool to support the
SMS in internal audits of processes.

ii. Attain an organizational way of working that will:

a. enable the development of a just culture; and,

b. Further encourage full staff participation and commitment in safety management.

6. To demonstrate to the safety regulator that the organisation does what it says it will
do in its safety policy and objectives, and be able to produce evidence to that effect,
including that related to non-compliances.
Any overall safety statement, as well as the safety policy and safety
objectives, is to be signed and dated by the “Accountable Executive”,
representing the Board, be communicated to all staff in an adequate and
timely manner, and be the subject of regular review.

7. There is a formal process to develop a coherent set of safety objectives, which are
reviewed in the Safety Analysis meetings and Safety Review Board meetings at least once
a year.

8. The Safety Objectives are publicized and distributed through the minutes of the meetings
to all concerned.

9. Resources are allocated for achieving the objectives.

10. The Safety Objectives are limited to Safety Indicators (SPI and SPT) to facilitate
monitoring and measurement where appropriate.

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5.2. The safety objectives of Air India Limited are expressed as a top-level statement
describing the organization’s commitment to achieving safety, which are as follows:

i. Minimise adverse safety events during service delivery operations.

ii. Implement an effective safety reporting programme.
iii. Deliver high quality safety management training
iv. Implement an effective Flight data analysis programme
v. Avoid injury to personnel and damage to equipment as consequences of service delivery
Operations.
vi. Ensure availability of resources to safely deliver maintenance operations, Flight Operations,
Cabin Operations, Ground Handling, Cargo and Security.
vii. Reduce Foreign Object Damage (FOD).
viii. Minimise airport runway and ATC related conflicts including TCAS/RA
ix. Reduce the number of non-technical and non-operational Air Turn backs
x. Enhance safety culture amongst employees
xi. Enhance safety of Flight operation through monitoring of FRMS, FDTL etc
xii. Ensure SAFA ratio less than 2.0
xiii. Ensure reduction in QMS, Flight Safety, DGCA and external agencies audit findings.
xiv. Align all SBU’s & AOC’s under corporate structure to enhance Safety.

xv. Enhance existing disciplinary procedure/ policy with due consideration of unintentional errors
or mistakes from deliberate or gross violations.
xvi. Integrate hazards identified from occurrence investigation reports with the voluntary hazard
reporting system and Integrate hazard identification and risk management procedures with
the sub-contractor’s or customer’s SMS where applicable.
xvii. Enhance safety data collection and processing system to include lower consequence events.
xviii. Develop lower-consequence SPIs and associated targets/alert settings.
xix. Proactively include all non operational areas also as a part of Corporate SMS to enhance
Safety Management .

xx. Reduction in BA positive cases for both cabin and cockpit crew.

NOTE: The safety objectives are publicized and distributed and Resources have been allocated for
achieving the objectives. The safety objectives are reviewed regularly and SPIs and SPTs are aligned
accordingly.

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 AIR INDIA LIMITED
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL

SAFETY ACCOUNTABILITIES
AND
KEY PERSONNEL

CHAPTER – 6
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ROLE, SAFETY ACCOUNTABILITY AND

RESPONSIBILITY OF PERSONNEL INVOLVED
IN SMS Issue-4 Rev-0 01 JUN 2018

6.1 MANAGEMENT AND CONTROL – SAFETY

Air India Limited meets the DGCA CAR requirements, as follows:

i. Air India Limited has an Accountable Executive who, irrespective of other functions, is
accountable on behalf of the organization for the implementation in all areas of the
organization and maintenance of an effective SMS;
ii. The Safety accountability is clearly defined throughout the organization, including a
direct accountability for safety on the part of senior management;
iii. The responsibilities of all members of management is identified, irrespective of other
functions, as well as of employees, with respect to the safety performance of the
organization;
iv. The safety accountability, responsibilities and authorities is documented and
communicated, throughout the organization.
v. The levels of management with authority to make decisions regarding safety risk
tolerability is defined.

6.1.1 Air India Limited has a management system that has continuity throughout the
organization and ensures control of operations and management of safety and security
outcomes.

A management system is documented in controlled company media at both the

corporate and operational levels. Manuals or controlled electronic media are acceptable
means of documenting the management system.

The Airline Documentation provides a comprehensive description of the scope,

structure and functionality of the management system and depicts lines of
accountability throughout the organization, as well as authorities, duties,
responsibilities and the interrelation of functions and activities within the system for
ensuring safe and secure operations.

Acceptable means of documentation include, but are not limited to, organograms
(organization charts), job descriptions and other descriptive written material that define
and clearly delineate the management system.

Documentation also reflects a functional continuity within the management system that
ensures the entire organization works as a system and not as a group of independent
or fragmented units (i.e., silo effect).

An effective management system is fully implemented and functional with a clear

consistency and unity of purpose between corporate management and management in
the operational areas.

6.1.2 The management system ensures compliance with all applicable standards and
regulatory requirements. In addition to internal standards and regulations of DGCA,
compliance is also ensured with authorities that have jurisdiction over operations that
are conducted over the high seas or within a foreign country.

6.1.3 The management system defines the safety accountabilities, authorities and
responsibilities of management and non-management personnel throughout the
organization, and specifies:

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i. The levels of management with the authority to make decisions regarding risk
tolerability with respect to the safety and/or security of aircraft operations;
ii. Responsibilities for ensuring operations are conducted in accordance with applicable
regulations and standards of Air India Limited;
iii. Lines of accountability throughout the flight operations, including direct
accountability for safety and/or security on the part of flight operations senior
management;
iv. Accountabilities of members of management, irrespective of other functions, as well
as of non-management personnel, with respect to the safety performance of the
organization.
Operational personnel required to perform functions relevant to the safety and security
of aircraft operations are identified, their accountability, authorities and responsibilities
are defined by Air India Limited and communicated throughout the organisation,
including flight operations organization.
6.1.4 Air India Limited has post holders and nominated officials within the management
system that are acceptable to the DGCA and have the responsibility, and thus are
accountable, for ensuring, in their respective defined operational areas:

i) The management of safety risks and security threats to aircraft operations;

ii) The conduct of operations in accordance with conditions and restrictions of the Air
Operator Certificate (AOC), and in compliance with applicable regulations and
standards.
The post holder for Chief of Flight Safety(COFS) is proposed by the Management and
thereafter selected and approved by DGCA. The post holder for Continued
Airworthiness Maintenance Organisation(CAMO) and Quality Manager for Engg. is
approved by DGCA. Other positions as per CAP 3100 are approved/accepted as per
DGCA Requirement.
6.1.5 Air India Limited has a process for the delegation of duties within the management
system that ensures managerial continuity is maintained when operational managers,
including nominated post holders, if applicable, are absent from the workplace.
A documented process that ensures a specific person (or perhaps more than one
person) is identified to assume the duties of any operational manager that is or is
expected to be away from normal duties meets the intent of this requirement. Air India
Limited has nominated deputies in place and has a process for ensuring the
appointment of a temporary replacement in case the nominated deputy is not
available.
A notification of such delegation of duties is communicated throughout the
management system using email and other suitable communication medium, as
applicable.
6.1.6 Air India Limited ensures delegation of authority and assignment of responsibility within
the management system for liaison with regulatory authorities, original equipment
manufacturers and other operationally relevant external entities.
To ensure the communication and coordination with external entities is consistent and
appropriate, liaison with operationally relevant external entities is normally controlled
through the delegation of authority and assignment of responsibility to specifically
named management personnel. Such authorities and responsibilities are included in the
job descriptions of the applicable managers.
6.1.7 Air India Limited has a policy that informs operational personnel throughout the
organization of their responsibility to comply with the applicable laws, regulations and

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procedures in all locations where operations are conducted.

6.1.8 Air India Limited has a communication system that enables an exchange of information
relevant to the conduct of operations throughout the management system and in all
areas where operations are conducted.

An effective communication system ensures the exchange of operational information

throughout all areas of the organization, and includes senior managers, operational
managers and front line personnel. To be totally effective, the communication system
includes external organizations that conduct outsourced operational functions.

Methods of communication vary according to the size and scope of the Departments.
However, to be effective, methods are as uncomplicated and easy to use as is possible,
and facilitate the reporting of operational deficiencies, hazards or concerns by
operational personnel.

Air India Limited has processes for the communication of safety information throughout
the organization to ensure personnel maintain an awareness of the SMS and current
operational safety issues.

Safety communication is an element of the Safety Promotion component of the SMS

Framework. The General intent of safety communication is to foster a positive safety
culture in which all employees receive ongoing information on safety issues, safety
metrics, specific hazards existing in the workplace and initiatives to address known
safety issues. Such communication conveys safety-critical information, explains why
particular actions are taken to improve safety, and why safety procedures are
introduced or changed.

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6.2 ACCOUNTABLE EXECUTIVE

6.2.1 Air India Limited has the Chairman and Managing Director as the Accountable
Executive who has overall responsibility and accountability on behalf of Air India
Limited, including the Three AOCs of Air India, Air India Express, Alliance Air as well as
other subsidiaries of Air India Limited for implementation and maintenance of the SMS
throughout the organization, which includes Personnel, Finance and all Operational and
Non-Operational Areas.

6.2.2 Accountabilities:
i) The CMD is accountable for performance of the management system, and,
irrespective of other functions, has ultimate responsibility and accountability on
behalf of Air India Limited for the implementation and maintenance of the safety
management system (SMS) throughout the organization;
ii) Has overall responsibility and is accountable for ensuring operations are conducted
in accordance with conditions and restrictions of the Air Operator Certificate (AOC),
and in compliance with applicable regulations and standards of Air India Limited.
iii) Has the Accountability to accept the risk of 16 and above (refer Section 8.5 & 8.6 of
this manual)
iv) Has the accountability to establish and promote Safety Policy, Objectives and
positive safety culture in the organisation
v) Has the accountability to take decisions in the Safety Review Board and Senior
Management Review Meetings.
vi) To ensure safety performance of the Organisation is met against the laid down
company’s safety policy and objectives.

Authority:
i) Has the authority to ensure the planning and allocation of resources necessary to
manage safety and security risks to aircraft operations;
ii) Has the full corporate authority to ensure that aircraft operations and maintenance
activities are performed as per standards of DGCA and other international
regulatory authorities.
iii) Has the authority to provide and allocate Human, Technical, Financial and other
resources necessary for effective and efficient performance of SMS.
iv) Has the final authority to decide for continuing operations with residual risk
identified as Unacceptable (Extreme Risk).

Responsibilities:
i) The Accountable Executive is responsible for complying with the requirements as
laid down in the DGCA CAR. Is responsible and accountable on behalf of the Air
India Limited for meeting the requirements of DGCA CAR Section 1, Series ‘C’,
Part-I dated 27th July, 2017.
ii) The Accountable Executive is a single, identifiable person who, irrespective of
other functions, has ultimate responsibility and accountability, on behalf of the
[organization], for the implementation and maintenance of the SMS.
iii) The Accountable Executive is responsible for the full control over the following:
a. The required human resources;
b. The required financial resources;

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iv) The Accountable Executive is the final authority over operations authorized to and
is directly responsible for the conduct of the organization’s affairs and is the final
responsibility for all safety issues.
v) In an SMS, the Accountable Executive has:
a. Ultimate responsibility and accountability for the safety of the entire operation
together with the implementation and maintenance of the SMS;
b. Responsibility for ensuring the SMS is properly implemented in all areas of the
organization and performing in accordance with specified requirements.
vi) The Accountable Executive is responsible for resolving operational quality, safety
and security issues, and in general, ensure necessary system components are in
place and functioning properly.

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6.3 CORPORATE SMS ORGANISATION AND RELATIONSHIP

6.3.1 The necessary organizational arrangements for the implementation of, adherence to and
maintenance of the organization’s SMS is as follows :-

The safety accountabilities, responsibilities and authorities of all members of

management as well as of all employees, irrespective of other responsibilities, are
documented in all the Manuals – the Organisation Manual, Flight Safety Manual,
Operations Manual and all the functional area Manuals.

The Safety-related accountabilities, responsibilities and authorities are defined,

documented and communicated throughout the organization and in all the manuals of
all departments.

6.3.2 To ensure that Air India Limited continues to meet applicable requirements, the
Accountable Executive has designated a Safety Manager (Head of Corporate SMS) with
the responsibility for monitoring compliance. The role of such manager would be to
ensure that the activities of Air India Limited are monitored for compliance with the
applicable regulatory requirements, as well as any additional requirements as
established by Air India Limited, and that these activities are being carried out properly
under the supervision of the relevant head of functional area.

The Head of Corporate SMS is responsible for the implementation, maintenance and
day-to-day administration of the Corporate SMS throughout the organization on behalf
of the Accountable Executive and senior management.

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Head of Corporate SMS has the necessary degree of authority when coordinating and
addressing safety matters throughout the organization. The Chiefs of Flight Safety also
have the necessary degree of authority while addressing safety matters within their
respective AOC. Whereas the designated manager i.e. Head of Corporate SMS, Chiefs
of Flight Safety have responsibility for day-to-day oversight of the SMS, overall
accountability for organizational safety rests with the accountable executive. Likewise,
nominated officials or operational managers always retain the responsibility (and thus
are accountable) for ensuring safety in their respective areas of operations.

6.3.3 The Corporate SMS lays down the objectives, the Safety Policy and provides the
directions, framework, policies, processes and procedures for SMS implementation to
all 3 AOCs and subsidiaries. The Corporate SMS also manages the SMS budget, and
organizes/supports the training programmes for SMS.

The Chiefs of Flight Safety in coordination with the Corporate SMS carry out Risk
Management, Safety Assurance and Safety Promotion for their respective AOCs.

All operational and functional heads (nominated post-holders) have incorporated SMS
within their own departments. They retain the responsibility and accountability for
ensuring safety in their respective areas of operations.

The QMS is responsible for performance based oversight and Corp SMS & QMS are
responsible for safety and quality assurance, continuous improvement for the
Organization which includes these AOCs and subsidiaries.

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6.3.4 Corporate SMS

CMD - AIR INDIA LTD

ACCOUNTABLE EXECUTIVE

AIR INDIA CEO CEO Head of Corporate CEO CEO

AICL Alliance Air SMS AIESL AIATSL
(Accountable (Accountable (Accountable (Accountable
Manager) Manager) Manager) Manager)
Chief
of Flt.
Safety
& SMS-
Safety
Mgr Chief Chief Safety Safety
of Flt. of Flt. Mgr Mgr
Safety Safety
All Dep & SMS- & SMS-
Heads Safety Safety
(See Mgr Mgr
3.3.5)

6.3.4.1 The CMD of Air India Limited is the Accountable Executive for Air India Limited
(covering all Three AOCs of Air India, Air India Express and Alliance Air as well as
AIESL, AIATSL and other subsidiaries.)

6.3.4.2 The Head of Corporate SMS is the Corporate Safety Manager and is responsible for the
implementation, maintenance and day-to-day administration of the Corporate SMS
throughout the organization on behalf of the Accountable Executive and senior
management.

6.3.4.3 Air India AOC is a large airline and the CMD is the direct Accountable Manager for Air
India. The Chief of Flight Safety is also the Safety Manager for Air India AOC for SMS
implementation. All Departmental Heads including key areas of Flight Operations,
Training, Cabin Operations, Engineering, Ground Operations, Cargo and Security have
safety accountabilities described in their respective Departmental Manuals. The chief
of Flight Safety coordinates with all the Departmental Heads with regard to SMS
implementation.

6.3.4.4 Air India Express AOC (Air India Express Limited) is a subsidiary low cost carrier airline
of Limited which is headed by a CEO, who is the Accountable Manager, but who
reports to the CMD of Air India Limited (who is also Chairman, AICL) and the
Accountable Executive of the Corporate Group of Air India Limited.

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6.3.4.5 Alliance Air AOC is a subsidiary Regional Carrier of Air India Limited, which is headed
by a CEO, who is the Accountable Manager, but who reports to the CMD of Air India
Limited (who is also Chairman, Alliance Air) and the Accountable Executive of the
Corporate Group of Air India Limited.

6.3.4.6 Air India Engineering Services Limited (AIESL) is an MRO which is a subsidiary of Air
India Limited, which is headed by a CEO, who is the Accountable Manager, but who
reports to the CMD of Air India Limited (who is also Chairman, AIESL) and the
Accountable Executive of the Corporate Group of Air India Limited.

6.3.4.7 Air India Air Transport Services Limited (AIATSL) is a Ground Handling Business Unit
which is a subsidiary of Air India Limited, which is headed by a CEO, who is the
Accountable Manager, but who reports to the CMD of Air India Limited (who is also
Chairman, AIATSL) and the Accountable Executive of the Corporate Group of Air India
Limited.

6.3.4.8 While all the AOCs and subsidiaries are responsible for implementation of SMS within
their areas of jurisdiction through the Chiefs of Flight Safety / Safety Managers,
considering that Air India Limited is a large Corporate group with a common CMD who
is the common Accountable Executive, the Head of Corporate SMS coordinates with all
the AOCs and subsidiaries as the Corporate SMS Manager and acts on behalf of the
CMD, the Accountable Executive.

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6.3.5 AIR INDIA ORGANISATION CHART

Details of duties and safety accountability are defined in each Departmental Manual.
Executive Director-Flight Safety is In-charge of SMS Implementation in Air India and is
the SMS – Safety Manager, for Air India AOC.

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6.4 DESCRIPTION OF SAFETY PERSONNEL

Air India Limited has a designated manager of the Corporate SMS that is responsible
for the day-today administration and oversight of SMS operation throughout the
organization on behalf of the Accountable Executive and senior management.

The Chiefs of Flight Safety, for the respective AOCs are the designated Managers of
SMS. The Safety Officers for the SBUs are the designated Managers of SMS. The Chiefs
of Flight Safety & Safety Officers work in coordination with the Corporate SMS Office.

The requirement for a manager that focuses on the administration and oversight of the
SMS on behalf of the Accountable Executive is an element of the Safety Accountabilities
component of the SMS framework, in Air India Limited.

The Head of Corporate SMS is an individual assigned responsibility for organizational

implementation of an SMS and reports to the Accountable Executive.

The Head of Corporate SMS is the designated organizational focal point for the day-to-
day development, administration and maintenance of the SMS.

The Head of Corporate SMS has the necessary degree of authority when coordinating
and addressing safety matters throughout the organization. Whereas the Head of
Corporate SMS has responsibility for day-to-day oversight of the SMS, overall
accountability for organizational safety rests with the Accountable Executive. Likewise,
nominated post-holders and, officials or operational managers always retain the
responsibility (and thus are accountable) for ensuring safety in their respective areas of
operations.

6.4.1 The Head of Corporate SMS (Safety Manager) shall :

i. ensure that processes needed for the SMS are developed, implemented
adhered to and maintained;
ii. report to the Accountable Executive on the performance of the SMS and on any
need for improvement; and
iii. ensure safety promotion throughout the organization.

6.4.2. Head of Corporate SMS is the Manager responsible for SMS and reports to the CMD
who is the Accountable Executive.

He/She is responsible for the implementation and maintenance of SMS on behalf of the
Accountable Executive.
The safety manager’s functions include, but are not necessarily limited to:
i. performing/facilitating hazard identification and safety risk analysis;
ii. monitoring corrective actions and evaluating their results;
iii. providing periodic reports on the organization’s safety performance;
iv. maintaining records and safety documentation;
v. planning and facilitating staff safety training;

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vi. providing independent advice on safety matters;

vii. monitoring safety concerns in the aviation industry and their perceived impact
on the service provider’s operations; and
viii. coordinating and communicating (on behalf of the accountable executive) with
DGCA and other service providers on issues relating to safety.

6.4.3 For selection of a safety manager, Air India Limited follows the guidance provided in
SSP circular and ICAO Doc 9859.

6.4.4 After induction, the safety manager shall be imparted knowledge of the organization’s
operations, procedures and activities as well as the applicable SSP requirements.

6.4.5 Qualifications, experience and attributes/skill set to meet the key roles of the function.

i. broad operational knowledge and extensive experience in the functions of the

organisation and the interfaces with users and major technical contractors;
ii. sound knowledge of safety management principles and practices;
iii. good written and verbal communication skills;
iv. well-developed interpersonal skills;
v. computer literacy;
vi. ability to relate to and influence persons at all levels, both inside and outside the
organisation; organisational ability;
vii. ability to work unsupervised;
viii. good analytical skills;
ix. leadership skills and an authoritative approach; and
x. worthy of respect from peers and management.

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6.5 DUTIES AND RESPONSIBILITIES FOR THE HEAD OF CORPORATE SMS

(SAFETY MANAGER)

The duties and responsibilities for the Head of Corporate SMS(Safety Manager) are as
follows :-

1. Overall purpose

The safety manager is responsible for providing guidance and direction for the
planning, implementation and operation of the organisation’s safety management
system (SMS).

2. Nature and scope of the function

The safety manager will interact with operational personnel, senior managers and
departmental heads throughout the organisation. The safety manager should also
foster positive relationships with regulatory authorities, agencies and service providers
outside the organisation. Other contacts and working relationships will be established
at a working level as appropriate, including those at functional interfaces, such as
quality management and training.

3. Responsibilities

3.1 The position requires the ability to cope with changing circumstances and situations
with little supervision. The safety manager acts independently of other managers
within the organisation.

3.2 The safety manager is responsible for providing information and advice to senior
management and to the Accountable Executive on matters relating to safe operations.
Tact, diplomacy and a high degree of integrity are prerequisites.

3.3 The job requires flexibility because assignments may be undertaken with little or no
notice and outside normal work hours.

4. Key Roles

Safety advocate - Demonstrates an excellent safety behaviour and attitude, follows

regulatory practices and rules, recognises and reports hazards and promotes effective
safety reporting.

Leader - Models and promotes an organisational culture that fosters exemplary safety
practices through effective leadership.

Communicator - Acts as a two way information conduit, providing and articulating

information regarding safety issues to the organisation’s staff, contractors and
stakeholders.

Developer - Assists in the continuous improvement of the hazard identification and

safety risk assessment processes and the organisation’s SMS.

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Relationship builder - Builds and maintains an excellent working relationship with the
organisation’s safety functions and those that interface with it, including quality
management.

Ambassador – Represents the organisation, as required.

Analyst - Analyses technical data for trends related to hazards, events and occurrences.

Process manager - Effectively utilises applicable processes and procedures to fulfil roles
and responsibilities, as well as measuring effectiveness and investigating opportunities
to improve the quality of processes.

5. Authority

5.1 Regarding safety matters, the safety manager has direct access to the Accountable
Executive and appropriate senior and middle management.

5.2 The safety manager is authorised to conduct safety audits, surveys and inspections of
any aspect of the operation.

5.3 The safety manager has the authority to conduct investigations of internal safety
events in accordance with the procedures specified in the safety management systems
manual (SMSM) of the organisation.

5.4 Accountabilities:
i) The Safety Manager is accountable for performance of the management system,
and, irrespective of other functions, has responsibility and accountability on behalf
of Air India Limited for the implementation and maintenance of the safety
management system (SMS) throughout the organization;
ii) Has overall responsibility and is accountable for ensuring operations are conducted
in accordance with conditions and restrictions of the Air Operator Certificate (AOC),
and in compliance with applicable regulations and standards of Air India Limited.
iii) Has the Accountability to accept the risk of 16
iv) Has the accountability to promote Safety Policy, Objectives and positive safety
culture in the organisation
v) Has the responsibility to escalate safety concerns to Top Management and
Accountable Executive to enable them to take decisions in the Safety Review Board
and Senior Management Review Meetings.
vi) To ensure safety performance of the Organisation is met against the laid down
company’s safety policy and objectives.

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6.6 DUTIES OF CHIEFS OF FLIGHT SAFETY

The Chiefs of Flight Safety have laid out in their respective flight safety manuals / SMS
Manual for each AOC the key safety personnel and their duties and responsibilities to
implement the Safety Management System (SMS).

6.6.1 Duties of SAFETY MANAGER of Air India:

The safety manager is responsible for:

1. Providing guidance and direction for the planning, implementation and operation of the
organization’s safety management system (SMS) on behalf of the Accountable Executive
in coordination with Head of Corporate SMS. The Safety Manager is also responsible for
providing information and advice to senior management and to the Accountable
Executive on matters relating to safe operations
2. Interact with operational personnel, senior managers and departmental heads
throughout the organization for performing/facilitating hazard identification and safety
risk analysis.
3. Foster positive relationships with regulatory authorities, agencies and service providers
outside the organisation. Other contacts and working relationships will be established at
a working level as appropriate, including those at functional interfaces, such as quality
management and training.
4. Ensure safety promotion throughout the organisation
5. The safety manager acts independently of other managers within the organization and
report to Accountable Manager and Accountable Executive.
6. monitoring corrective actions and evaluating their results;
7. providing periodic reports on the organization’s safety performance;
8. maintaining records and safety documentation;
9. planning and organizing staff safety training;
10. providing independent advice on safety matters;
11. monitoring safety concerns in the aviation industry and their perceived impact in the
organization’s operations aimed at service delivery;
12. coordinating and communicating (on behalf of the Accountable Executive) on issues
relating to safety with the State’s oversight authority, and other State agencies as
necessary; and
13. Coordinating and communicating (on behalf of the Accountable Executive) on issues
relating to safety with international agencies.
14. Regarding safety matters, the safety manager has direct access to the Accountable
Executive and appropriate senior and middle management.
15. The safety manager is authorized to conduct safety audits, surveys and inspections of
any aspect of the operation.
16. The safety manager has the authority to conduct investigations of internal safety
events in accordance with the procedures specified in the safety management
systems manual (SMSM) of the organization.

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6.7 POST HOLDERS, DEPARTMENTAL HEADS and CHIEFS OF OPERATIONS,

ENGINEERING, ETC.
The duties of Post-holders of Flight Operations, Flight Despatch & Operational Control,
Engineering, Cabin Operations, Ground Operations, Cargo Operations, and Security are
given in their respective Manuals for each AOC.
All post holders and Heads of Department have safety accountability for the
functional and operational area that they head as part of the Safety
Management System.
6.7.1 Safety Accountability Departmental Heads / Post Holders:

6.7.1.1 Exec Director-Operations / Gen Manager-Flight Despatch / Gen Manager-

Cabin Crew/ Regional Cargo Managers / Exec Director-Security /other
Departmental Heads and/or equivalent posts:

The above mentioned post holders are accountable and responsible for safety of his
functional and operational area as part of the Safety Management System. They are
accountable for:
i. Identification of safety hazards within his department through hazard identification
program that include:
a. A combination of reactive and proactive methods for safety data collection
b. Processes for safety data analysis that identify existing hazards and predict
future hazards to aircraft operations.
ii. Hazard analysis to determine the existing and safety potential risk to aircraft
operations.
iii. Assessment of safety risks to determine the risk mitigation action and when
required risk mitigation actions are developed and implemented in operations.
iv. Ensuring that remedial action necessary to maintain an acceptable level of safety is
implemented
v. Providing for continuous monitoring and regular assessment of the safety level
achieved; and
vi. Aiming to make continuous improvement to the overall level of safety
vii. Coordinating with the SMS Office / Flight Safety Department / QMS as applicable.
viii. Attending meetings Safety Review Meetings, Safety Review Board Meetings.
ix. Nominating SMS Nodal officers to represent their departments in the various
meetings viz. Safety Action Group Meeting and coordination of SMS activities as a
link between Corporate SMS and the department.
x. Ensuring implementation of SRB/ SRM/SAG directives, company’s safety policy and
objectives.

6.7.1.2 Post Holder – Engineering

ED-Engineering / Chief of Engineering is accountable and responsible for safety of his
functional and operational area as part of the Safety Management System. He is
responsible for :
i. Ensure management of safety risks and safety risk tolerability in maintenance
operations including security threat and that the maintenance operations are conducted
in accordance with conditions and restrictions of AOC and in compliance with applicable
regulations and standards mentioned in CAME.
ii. As the Engineering services are outsourced to AIESL, ED-Engineering is also
responsible to oversee the following SMS related functions of Chief of Quality & Safety
of AIESL which are as follows :-

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a. Ensure development of the processes need for the SMS and are implemented,
adhered to and maintained;
b. Report to the Accountable Manager on the performance of the SMS and on any
need for improvement
c. Ensure safety promotion throughout the organisation
d. To provide current information and training to all staff on the safety management
system and safety issues. To arrange training from external sources as necessary
e. To promote effective hazard identification and reporting
f. To communicate regarding safety issues to all staff
g. Responsible for continuous improvement in the hazard identification and risk
assessment processes.
h. To establish excellent working relationship with the organisation’s safety functions
and those that interface with it, including quality management
i. Ensure that technical data for trends related to hazards, events and occurences are
analysed
j. To conduct / organise safety audits, surveys and inspections any aspect of
maintenance and operation
k. To conduct investigations of internal safety in accordance with procedures laid
down in this manual
l. To oversee the entire functioning of the safety management system in the Facilities.
Participate in the Safety Review Board and Safety Action Group meetings and
advise the members in issues related to the SMS.

6.7.1.3 Post Holder – Ground Handling :-

Executive Director-Ground Handling is accountable and responsible for safety of his

functional and operational area as part of the Safety Management System. He is
responsible for:

i. identification of safety hazard within his department, ensuring that the same are
identified by GHA at the concerned operating area;
ii. Ensuring that remedial action necessary to maintain an acceptable level of safety is
implemented by SP at the concerned operating area
iii. Providing for continuous monitoring and regular assessment of the safety level
achieved;
iv. Aiming to make continuous improvement to the overall level of safety.
v. Hazard analysis to determine the existing and safety potential risk to aircraft
operations.
vi. Coordinating with the Flight Safety Department / QMS as applicable.

6.7.2: Authorities:

All Departmental Heads and Post Holders have the authority to accept risk (Low, Moderate
and High Risk, i.e., risk from 5-15). Refer section 8.5 and 8.6 of this manual for details.
In addition to the same, the details of their Duties, Responsibilities and Accountabilities are
listed in their respective Department manuals.

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6.7.3 HEADs OF DEPARTMENTS / POST HOLDERS- Safety Responsibilities

Following are the Duties & Responsibilities of HOD’s towards their departments:-
i. Ensure implementation of SMS in their department
ii. Ensure all staff are aware of the Safety Policy & Objective
iii. Ensure all staff are trained for SMS and are current on the subject
iv. Ensure all staff are aware of differentiating between Hazard and a consequence.
v. Ensure all staff are aware of different reporting forms and methods of reporting hazards.
vi. Ensure all hazards reported, through the voluntary reporting system, is brought to the
notice of the Accountable Executive and SMS Manager before taking action on it.
vii. Develop, implement & evaluate the strategies to manage the safety risks of the
consequence of hazards which are a by-product of an external or internal change.
viii. Ensure proper documentation of SMS is carried out.
ix. Ensure the hazards reported are bought up in Safety Review Board meeting and SAG
meetings.
x. Ensure all external agencies are aware of the requirements of reporting hazards to the
Corporate SMS.

In addition to the same, the details of their Duties, Responsibilities and Accountabilities are
listed in their respective Department manuals.

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6.8 SMS NODAL OFFICERS / OTHER EMPLOYEES:

6.8.1 SMS Nodal Officers:

Each department nominates SMS Nodal Officers for coordinating SMS activities. The Nodal
Officers participate in the various meetings held from time to time, and represents the
department.
Following are the Roles & Responsibilities of the Senior Managers of AIR INDIA LTD towards
SMS:-

i. Develop, implement & evaluate the strategies to manage the safety risks of the consequence
of hazards which are a by-product of an external or internal change.
ii. Ensure all hazards reported, through the voluntary reporting system, is brought to the notice
of their respective departmental head, Flight Safety and Corporate SMS Office.
iii. Ensure minutes of all SAGs are documented, when held within the department and circulated
to all the attendees.
iv. Ensure all documents pertaining to SMS are updated and maintained and to submit reports to
Corporate SMS from time to time.
v. Periodically check for safety updates and the regulators website for circulars or amendments
on Civil Aviation Regulations pertaining to safety.
vi. Carry out Safety Risk Assessment for the Department.
vii. To participate in the SAG, SRM, SRB meetings as applicable.

6.8.1.1 Authorities:

All SMS Nodal Officers have the authority to accept risk (negligible risk 1-4). Refer section
8.5 and 8.6 of this manual for details.

6.8.2 ALL EMPLOYEES OF AIR INDIA LIMITED

Following are the Roles & Responsibilities of all employees towards SMS:-
All employees should:-
i. Have a clear understanding of the Safety Management System.
ii. Be aware of what Hazards, Risks and consequences are.
iii. Report hazards without hesitation.
iv. Ensure a safety culture at their workplace/workstation.
v. Not stop any personnel from reporting a hazard or a risk.
vi. Bring to the notice of the management of any malpractices which may affect safety of our
operations.

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6.9 SAFETY REVIEW BOARD -CORPORATE

The role, safety accountability and responsibility of the personnel involved in SMS function at
both, the Corporate Level, through various meetings and escalations as given in para 6.9, and
at the AOC level which, for Air India, is given in para 6.10.

Safety Review Board is constituted at the Corporate level as a part of the Safety
Management System (SMS) covering all AOCs and Strategic Business Units (SBUs) including
MRO and Ground Handling.

CMD, Accountable Executive

Air India Limited

CORPORATE AOCs SBUs

Head of AIR INDIA MRO GROUND

QMS & ED-SEC HANDLING
Corporate  CEO  CEO
SMS  Chief of Safety  QM  CEO
 Director Ops & ED-OPS  Safety  QCM-GRH
 ED-TRG Manager  Safety Officer
 ED (Engg.) & CAM-ENGG
 ED-CS
 ED-Cargo
 ED-GRH

AIR INDIA
EXPRESS LTD
 CEO & COO
 Chief of Safety
 Chief of OPS
 Chief of TRG
 CAM-ENGG

ALLIANCE AIR
 CEO & COO
 Chief of Safety
 Chief of OPS
 Chief of TRG
 CAM-ENGG

6.9.1 All the Chiefs of Flight Safety for the respective AOCs internally set up an SMS Team
which functions like a Safety Action Group. The SAG (Safety Action Group) meets
once a month. This Team submits a quarterly progress report to the Corporate SMS.
Similarly, the CEOs/ Safety Managers for MRO and Ground Handling also internally have
a Safety Action Group implementing SMS in their respective areas.

6.9.2 Besides the internal SAG meetings of all AOCs and Subsidiaries, the Corporate SMS
office has quarterly meetings with AOCs and Subsidiaries as a part of Corporate SMS
Plan. The Corporate SMS office also facilitates the SAG every month with
representatives from all AOCs and Subsidiaries considering the interlinked activities and

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interdependencies that exist for safe operations.

6.9.3 The Chiefs of Flight Safety and Safety Heads of SBUs have regular Safety Review
Meetings, at least once a quarter. Head of QMS & Corporate SMS as well as ED-
Security also ensure that their representatives attend the Safety Review Meetings for all
AOCs and SBUs. The respective Chiefs of Flight Safety (for AOCs) and Safety Officer (for
SBUs) coordinate the Safety Review Meetings to be held every quarter at AOC/SBU
Level.
6.9.4 Important issues pertaining to Safety & SMS are taken up in the Senior Management
Review Meetings which are held once in six months as and when required.
6.9.5 At the Corporate level, the Safety Review Board Meeting is held at least once a
year. Head of Corporate SMS coordinates the Corporate Safety Review Board meeting
and respective Chiefs of Flight Safety coordinates for Safety Review Board Meetings for
their respective AOCs once a year. These meetings at the Corporate level and AOC level
may be combined. However, in such cases, adequate time has to be provided for
Corporate level issues as well as safety issues for each AOC.

Safety Review Board (SRB) ensures that continual improvement process is overseen
through this strategic committee of senior management officials that are familiar with
the workings and objectives of the SMS. Since this is a very high level, strategic
committee chaired by the Accountable Executive and composed of senior managers,
including senior line managers responsible for functional areas in operations (e.g. flight
operations, engineering and maintenance, cabin operations) and is eminently strategic,
it deals with high-level issues in relation to policies, resource allocation and
organisational performance monitoring, and meets at least once a year. The SRB

a) monitors the effectiveness of the SMS implementation plan;

b) monitors that any necessary corrective action is taken in a timely manner;
c) monitors safety performance against the Organisation’s safety policy and objectives;
d) monitors the effectiveness of the Organisation’s safety management processes
which support and declared corporate priority of safety management as another
core business process;
e) monitors the effectiveness of the safety supervision of subcontracted operations;
f) ensures that appropriate resources are allocated to achieve safety performance
beyond that required by regulatory compliance, and;
g) Gives strategic direction to the SAG.

6.9.6 Safety Action Group (SAG) – To ensure front line input as part of the SMS review
process, Air India Limited has formed multiple units of specially selected operational
personnel (e.g. managers, supervisors, front line personnel) that function to oversee
safety in areas where operations are conducted. Such units referred to as Safety Action
Groups (SAGs), are tactical committees that function to address implementation issues
in front line operations to satisfy the strategic directives of the SRB.

While all Regions/Departments shall have their own SMS Nodal Officers to co-ordinate
Safety/SMS Reports with-in their own Regions/department, they shall also participate in
the Inter Departmental monthly Safety Action Group (SAG) meetings organized by
Flight Safety Department of the Region/Base of all AOC”s where inputs from SMS Nodal
Officers, Hazards/Voluntary Reports etc. shall be discussed.

These groups have SMS Nodal Officers/Representatives from all AOCs and subsidiaries
across Departments, Regions, who meet at least once a month centrally in Mumbai to
review safety concerns. The inputs from SMS/Flight Safety Analysis Working Group and

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the audits and surveillance group shall be discussed by the SAG.

The AOC’s with more than one Base/Region will conduct Regional SAG meetings
Base/Region wise, such meetings shall be coordinated by Base/Regional Flight Safety
Department.
The non base stations/Line stations Airport Manager will act as SMS Nodal Officer and
will coordinate with Regional SMS Nodal Officer of Flight Safety Department. The
Regional SMS Nodal Officers from Flight Safety Department will coordinate Regional
SAG meetings and shall submit report to Corporate SAG Nodal Officer; he/she will
also attend monthly Corporate SAG meetings.

6.9.7 Safety Review Meeting - The Safety Review Meeting comprising of following
members shall review all aspects of flight safety including significant issues arising
from SMS and SAG meetings, besides Flight Safety Analysis program. The review
committee will be held every quarter. The members of the committee will be:

1. Executive Director-Flight Safety - Convenor

2. Head of Corporate SMS - Member
3. Executive Director Operations - Member
4. Executive Director Training - Member
5. Executive Director, Engineering - Member
6. CAM-Engineering - Member
7. Executive Director (IFS) - Member
8. Executive Director (GH) - Member
9. Executive Director (Cargo) - Member
10. Executive Director (Security) - Member
11. General Manager (Medical) - Member
12. Head of Corporate QMS - Member
13. Dy. Chief of Flight Safety Secretary
14. Invitees at the direction of the Convener

The minutes of the meeting shall be forwarded by the ED-Flight Safety / Secretary to
all the members and invitees. The minutes shall be documented and controlled as per
the Corporate Document Management system.

6.9.8 Escalation of safety concerns takes place from the SAG to the SRM and finally to
the SRB if issues do not get resolved. The Accountable Executive ensures that all
decisions that could not be resolved are addressed at his level and suitable decisions
are taken to ensure the highest level of safety.

6.9.9 Senior Management Review Meeting-

The Senior Management Review Meeting formed under the Chairmanship of the CMD
and coordinated by Corporate QMS, shall meet at least every six months and review
the management system to ensure its continuing suitability, adequacy and effectiveness
in the management and the control of operations. The review shall include assessing
opportunities for improvement and need for changes to the system, including, but not
limited to, organization structure, reporting lines, authorities, responsibilities, policies,
processes and procedures, as well as allocation of resources and identification of training
needs.

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This meeting shall be responsible for setting performance measures as a means to

monitor the operational safety performance of the organization and to validate the
effectiveness of safety risk controls.

The minutes of the meeting shall be forwarded by the Secretary to all the members and
invitees, if any, of the board within two working days and the minutes shall be documented and
controlled as per the Corporate Document Management system.

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6.10 AIR INDIA SAFETY REVIEW BOARD

Air India Safety Review Board shall meet once in a year and comprises the following
personnel. Air India Safety Review Board can be held on the same day as Safety Review
Board at Corporate Level, provided additional time is provided for the same.

1. Chairman and Managing Director Chairman

2. Chief of Flight Safety and Executive Director-Flight Safety – Convener
3. Head of Corporate SMS - Member
4. Executive Director Operations - Member
5. Executive Director Training - Member
6. Executive Director, Engineering - Member
7. CAM-Engineering - Member
8. Executive Director (IFS) - Member
9. Executive Director (GH) - Member
10. Executive Director (Cargo) - Member
11. Executive Director (Security) - Member
12. General Manager (Medical) - Member
13. Head of Corporate QMS - Member
14. Dy. Chief of Flight Safety Secretary
15. Invitees at the direction of the Convener

Functional Directors (including Personnel, Finance, Commercial and other

Executive Directors and Departmental Heads will also be invited.)

This meeting shall be responsible for setting performance measures as a means to

monitor the operational safety performance of the organization and to validate the
effectiveness of safety risk controls.

The minutes of the meeting shall be forwarded by the ED-Flight Safety to all the
members and invitees, if any, of the board and the minutes shall be documented
and controlled as per the Corporate Document Management system.

6.10.1 Management Review & Responsibilities

It shall also review and ensure the continual improvement of the SMS throughout
the organization, to include, when substandard performance of SMS of different
departments of Air India has been identified:

i. Identification of cause(s) of substandard performance

ii. Determination of the implications of substandard performance in operations
iii. Elimination or mitigation of cause(s) of substandard performance

The following aspects shall be reviewed:

i. SMS and Flight Safety Analysis Programme Data

ii. Flight Operations Quality Assurance (FOQA) Trends of the fleet.
iii. Incident Trend and Analysis of the fleet
iv. Results of audits, findings of operational inspections and investigations.
v. Status of corrective and preventative actions.
vi. Operational feedback.
vii. Quality improvement in respective areas.

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viii. Changes in regulatory policy or civil aviation legislation and our response.
ix. Follow-up actions from previous management reviews.
x. Feedback and recommendations for management system improvement.
xi. Regulatory violations.
xii. Security requirements and issues.
xiii. Follow up actions from previous Flight Safety Review Boards.
xiv. Feedback and recommendations for SMS improvement
xv. Findings from operational inspections and investigations;
xvi. Operational feedback;
xvii. Process performance and organizational conformance;
xviii. Results from implementation or rehearsal of the emergency response plan
(ERP);
xix. Follow-up actions from previous management reviews;
xx. Resource needs.

The decisions and the actions required to be taken related to improvement of the
processes throughout the Management system, Safety and Security requirements along
with the resources needed including action plan for the changes shall be documented,
and the same shall be sent to appropriate personnel for corrective/preventive action.
Progress shall be tracked by Deputy Chief of Flight Safety to ensure that necessary
corrective actions have been taken and effectiveness thereof.

6.10.1.1 AIR INDIA – SAFETY & SMS MEETINGS

Safety Action Group

MONTHLY MEETING
(SAG)

Safety Review Meeting

QUARTERLY MEETING
(SRM)

Safety Review Board

MINIMUM ONCE A YEAR
(SRB)

Besides the above, Air India AOC participates in Corporate SMRM (Senior Management
Review Meeting) held twice a year chaired by CMD and coordinated by Corporate QMS)
and Corporate Safety Review Board held once a year chaired by CMD and coordinated by
Corporate SMS.

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6.10.2 SAFETY ACTION GROUP (SAG):

The Flight Safety Department of Air India will schedule monthly meeting of the Safety Action
Group wherein factors affecting the safe operation of the airline including Air India Ltd shall be
discussed. The inputs from SMS/Flight Safety Analysis Working Group and the audits and
surveillance group shall be discussed by the SAG wherein the remedial actions shall be
proposed for implementation. This meeting will also cover the Corporate Air India Limited SMS-
SAG requirement being the largest AOC with participation from other SBUs and AOCs also.

To ensure front line input as part of the SMS review process, Air India Limited has formed
multiple units of specially selected operational personnel (e.g. managers, supervisors, front
line personnel) that function to oversee safety in areas where operations are conducted. Such
units referred to as Safety Action Groups (SAGs), are tactical committees that function to
address implementation issues in front line operations to satisfy the strategic directives of the
SRB.

While all Regions/Departments shall have their own SMS Nodal Officers to co-ordinate
Safety/SMS Reports with-in their own Regions/department, they shall also participate in the
Inter Departmental monthly Safety Action Group (SAG) meetings organized by Flight Safety
Department of the Region/Base of all AOCs where inputs from SMS Nodal Officers,
Hazards/Voluntary Reports etc. shall be discussed.

These groups have SMS Nodal Officers/Representatives from all AOCs and subsidiaries across
Departments, Regions, who meet atleast once a month centrally in Mumbai to review safety
concerns. The inputs from SMS/Flight Safety Analysis Working Group and the audits and
surveillance group shall be discussed by the SAG.

The non base stations/Line stations Airport Manager will act as SMS Nodal Officer and will
coordinate with Regional SMS Nodal Officer of Flight Safety Department. The Regional SMS
Nodal Officers from Flight Safety Department will coordinate Regional SAG meetings and shall
submit report to Corporate SAG Nodal Officer; he/she will also attend monthly Corporate SAG
meetings.

Chief of Flight Safety/Dy. Chief of Flight Safety/Dy.GM-Flight Safety will act as Chairman of the
SAG meeting and conduct the meeting. The SMS nodal officers of each department like
Engineering, Operation, Training, Security, Cargo, Flight Dispatch, Ground Handling etc will
provide the input to be present in SAG meeting to Flight Safety Department. Depend upon the
agenda Flight Safety of Air India Ltd will invite at the direction of Chief of Flight Safety/ Dy.
Chief of Flight Safety, the additional members to attend the meeting.

The minutes of the meeting shall be forwarded to all the members and invitees and the same
will be forwarded to the Chief of Flight Safety and the Deputy Chief of Flight Safety. The
minutes shall be documented and controlled as per the Corporate Document Management
system.

6.10.3 SAFETY REVIEW MEETING

The Safety Review Meeting comprising of following members shall review all aspects of
flight safety including significant issues arising from SMS and SAG meetings, besides Flight

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Safety Analysis program. The review committee will be held every quarter. The members
of the committee will be:

1. Executive Director-Flight Safety -Convenor

2. Head of Corporate SMS - Member
3. Executive Director Operations - Member
4. Executive Director Training - Member
5. Executive Director, Engineering - Member
6. CAM-Engineering - Member
7. Executive Director (IFS) - Member
8. Executive Director (GH) - Member
9. Executive Director (Cargo) - Member
10. Executive Director (Security) - Member
11. General Manager (Medical) - Member
12. Head of Corporate QMS - Member
13. Dy. Chief of Flight Safety- Secretary
14. Invitees at the direction of the Convener

The minutes of the meeting shall be forwarded by the ED-Flight Safety / Secretary to all the
members and invitees. The minutes shall be documented and controlled as per the
Corporate Document Management system.

Escalation of safety concerns takes place from the SAG to the SRM and finally to the SRB if
issues do not get resolved. The Accountable Executive ensures that all decisions that could
not be resolved are addressed at his level and suitable decisions are taken to ensure the
highest level of safety.

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INTENTIONALLY LEFT BLANK

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 AIR INDIA LIMITED
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL

SAFETY REPORTING
AND
REMEDIAL ACTIONS

CHAPTER – 7
 CORPORATE SAFETY AI–ORG-SMS-001
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SAFETY REPORTING AND REMEDIAL
ACTIONS Issue-4 Rev-2 11 Dec 2020

7.1 SAFETY REPORTING POLICY

7.1.1 Air India Limited has an Open Reporting System, which is published through various
manuals as well as on the website encouraging personnel to report. The same is also
encouraged through SMS campaigns, SMS trainings and through circulars from time to
time.

7.1.2 An operational safety reporting system is implemented throughout the organization in a

manner that:

i) Encourages and facilitates feedback from personnel to report safety hazards,

expose safety deficiencies and raise safety or security concerns;

ii) Ensures mandatory reporting in accordance with applicable regulations;

iii) Includes analysis and management action as necessary to address safety issues
identified through the reporting system.

Operational reporting is a proactive hazard identification activity in an SMS.

Frontline personnel, such as flight or cabin crew members and maintenance
technicians, are exposed to hazards and face challenging situations as part of their
everyday activities. An operational reporting system provides such personnel with
a means to report these hazards or any other safety concerns so they may be
brought to the attention of relevant managers.

To build confidence in the process and encourage more reporting, an

acknowledgement for each report is given.

A review and analysis of each report is carried out to determine whether a real
safety issue exists, and if so, ensure development and implementation of
appropriate action by responsible management to correct the situation.

Air India Limited encourages all individuals for reporting Mandatory, Voluntary as
well as Confidential Reports in all operational area including Operations,
Maintenance, Cabin Operations, Ground Handling, Cargo Operations, and Security
etc. The reports can be of Proactive or the events that have already occurred will
help us in to prevent accidents and incidents. If any individual notices a situation or
an event which can potentially lead to an accident / incident, he/ she is encouraged
to report the same.

7.1.3 Air India Limited has a non-punitive safety reporting system that is
implemented throughout the organization in all areas where operations are
conducted.
Also, in such a system employees are assured that the identity or information
leading to the identity, of any employee who reports an error under this policy is
never disclosed unless agreed to by the employee or required by law. A non-punitive
safety reporting system is documented in Organizational Manual, Operations
Manuals and other controlled documents.

An essential element of any SMS is the Safety Reporting Policy. Air India Limited is
committed to implement a Non-Punitive Reporting System in all areas where

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operations are conducted. All employees are encouraged to report unpremeditated

or inadvertent errors, safety hazards and safety risks or other potentially hazardous
conditions timely for which no disciplinary or punitive action shall be taken unless
such errors result from illegal activity or willful misconduct.

The information received through voluntary and confidential reports shall only be
used as a preventive tool and under no circumstances will be used as material
evidence for taking disciplinary action against the person reporting. This shall
however be without prejudice to usual regulatory investigation and consequent
action by DGCA under the rules and for any act of willful negligence or deliberate
non-adherence to procedures or such similar acts.

It is important for the success of this program that all flight and Cabin crew
members share the common organizational responsibility of identified hazards in
order that action is taken to mitigate them.

Voluntary /Confidential Reporting is Non-Punitive and absolute Confidentiality is

maintained.

7.1.4 Air India Limited has a confidential safety reporting system that is implemented
throughout the organization in a manner that encourages and facilitates the
reporting of events, hazards and/or concerns resulting from or associated with
human performance in operations.

The success of a confidential safety reporting system is ensured by assuring

absolute protection of a report submitted by any individual; and providing their
freedom to report actual or potential unsafe conditions or occurrences.

There is a difference between confidential reporting and anonymous reporting.

Confidential reporting is the preferred system because it permits feedback to the
reporter in response to the report. Not only is the reporter entitled to an
explanation, but also such feedback provides excellent incentive for the submission
of future reports.
The effectiveness of a confidential safety reporting system is determined by
safeguarding safety and risk information. Such information is used only for safety
purposes and is not used against them.
The effective confidential safety reporting system might include:

i. A process that provides absolute protection of confidentiality;

ii. An articulated policy that encourages reporting of hazards and human
errors in operations;
iii. A shared responsibility between the individual flight and cabin crew members
(or, if applicable, respective professional associations) and the organization
to promote a confidential safety reporting system;
iv. A process for secure de-identification of confidential reports;
v. A tracking process of action taken in response to reports;
vi. A process to provide feedback to the reporter;
vii. A communication process for ensuring flight and cabin crew members, as well
as other relevant personnel, are informed of potential operating hazards
through dissemination of de-identified report information.

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Confidential Report aims to protect the identity of the reporter. This is one way of
ensuring that voluntary reporting system is Non-punitive. Confidential incident reporting
system facilitates the disclosure of hazard leading to human error, without fear of
retribution or embarrassment, and enable broader acquisition of information on hazards.
The Confidential reports are de-identified on receipt to ensure confidentiality.

7.1.5 MANDATORY REPORTING SYSTEM

The following are the mandatory reports and refer FSM Chapter 3 for more details.
i. Flight Safety Report raised by PIC of the flight.
ii. Air Traffic Incident / Air Miss Reports
iii. EGPWS Occurrence Reports
iv. Pilot/ Observer RA Reports
v. Wild Life(Bird/Animal) Strike Reports
vi. Any other incident reported by PIC / Engineering/ Others.

7.1.6. VOLUNTARY SAFETY REPORTING SYSTEM

In order to encourage voluntary reporting of occurrences by personnel Voluntary

Reporting System has been established which could be an event or Hazard. Under this
system, anyone who witnesses or is involved or has knowledge of an event, hazard or
situation which he or she believes to have posed a risk to safety or a potential threat to
safety may report the same. It encompasses basic principles of provision of
confidentiality & possibility of feedback. The system provides assurance that no punitive
action will be taken on such voluntary reporting made unless infringement relates to
unlawful/ criminal/ deliberate gross negligent unsafe actions.

An individual may come across an event, safety hazard or observation which does not
come under the purview of a Mandatory report. However, he feels that reporting the
same could enhance safety or allow others to gain from his experience. In such cases a
Voluntary Report can be raised. The report has a field for name, email etc so that
feedback could be given with respect to the report. The Voluntary Safety Report is a
non-confidential mode of reporting and a non-reprisal policy is followed unless the event
has resulted from illegal activity or willful misconduct. In case the report received under
voluntary/confidential/anonymous is such that it does not pertain to safety, but is a
complaint of something other than safety, it will be given to the concerned department /
area and not included in the SMS Hazard Register.

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7.1.7 HOW TO REPORT?

All personnel are encouraged to bring to the notice of the Flight Safety
Department any hazards, deficiencies and safety or security concern including
reporting of hazards or concerns resulting from or associated with human
performance.

These reports may be Confidential and should be forwarded to Chief of flight

Safety. These Reports may be sent through Email or even telephonically to the
Executives/Officers of Flight Safety Department.

Whenever, a Voluntary Report is received with identity of reporter, an

acknowledgement will be sent before de-identifying the report. All reports
received by Flight Safety Department will be given reference number after de-
identification. These reports will be closed if no action is considered necessary
after review. However, if any issue is identified, the report will be marked
“OPEN”. It will be closed only after satisfactory action is taken by the concerned
departments. The corrective action taken shall also be informed to the personnel
who had raised the report.

Issues raised in Reports shall be analyzed to address Operational Deficiencies,

Hazards or Concerns identified through such reports. If a safety issue is
identified, a report shall be sent to responsible Operational Managers for
development and implementation of appropriate action to correct the situation.

Confidential/ Voluntary Reporting is Non-Punitive and absolute Confidentiality is

maintained.

It is important for the success of this program that all flight and Cabin crew
members share the common organizational responsibility of identified hazards in
order that action is taken to mitigate them.

The Safety concerns identified through this process along with the action taken
would be disseminated all concerned personnel through safety bulletin.

Information given will be de-identified at the level of Coordinator and alternate

cordinator.

It is assured that no punitive action will be taken on such voluntary reporting

made unless infringement relates to unlawful / criminal /deliberate gross
negligent unsafe action. However, this Voluntary Reporting System is not a
substitute for statutory mandatory incident reporting system, which will continue
to function.

Hazard is a situation that poses a level of threat to persons, property or

environment. Most hazards are dormant with a potential for risk or harm. The
Voluntary Safety Report and Confidential Safety report shall be used to report any
safety hazard observed by the personnel.

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Report may be submitted by the following means:-

a) Internet → GOOGLE ‘FLIGHT SAFETY AIR INDIA’ and go to “WELCOME TO AIR

INDIA CORPORATE SMS AND FLIGHT SAFETY WEBSITE” link. On the website, in
place of Staff No. type – ‘flight safety’ & in the password field type ‘safety’ &
click LOGIN. A page opens, giving you various options. Second option is “Online
Reporting”. Click on it. Use the ‘VOLUNTARY REPORT or CONFIDENTIAL REPORT.
The said reports have an option to select the organization. Air India Limited is
identified as IX in respective reported. Fill the report accordingly and click
“Submit”.
b) Communicated without delay to the Flight Safety Department of Air India
Limited utilizing any of the following:

TELEPHONE : +91 22 2615 7027

E-MAIL: [email protected] & [email protected]

c) Physical (Hard) copies: Voluntary and Confidential Report as referred in

Appendix- A & B at the end of this Manual must be used.
Fill up the paper copies of the above forms available in the department at
convenient places or with SMS Nodal Officers and place in the ‘VOLUNTARY
SAFETY REPORTS’ Drop Boxes in the Department.

Paper copies of reports shall be mailed to

Chief of Flight Safety,
Flight Safety Department,
Air India Limited,
Old Airport,
Kalina, Santa Cruz (E),
Mumbai-400029

Envelopes of reports shall be marked ‘CONFIDENTIAL’ if report is confidential in

Nature.

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7.1.8 On-line Reporting on the Corporate SMS and Flight Safety Website:
Reports are classified into Mandatory Reports which are those that are required to
be necessarily notified to the AAIB/DGCA and other routine occurrence reports.
The other classification is for SMS Reports which includes Voluntary Reports,
Confidential Reports and Anonymous Reports.

ON-LINE REPORTING

MANDATORY REPORTING / SMS REPORTING

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MANDATORY REPORTING

SMS REPORTING

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ACTIONS Issue-4 Rev-2 11 Dec 2020

VOLUNTARY REPORT FORM

7.1.8.1 Reports are collected to facilitate necessary analysis, through online reporting,
hard copy reporting, e-mails, telephone, SMS and Whatsapp messages as well as
management feedback to provide various sources of reporting hazards. All these
are collected in the SDCPS.
(Safety Data Collection and Processing Systems – Refer Chapter 8)

7.1.8.2 High-consequence reports and associated recommendations are addressed to and

reviewed by appropriate level of management, in Safety Review Meetings.

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7.1.8.3 VOLUNTARY SAFETY REPORTING SYSTEM IN ACCORDANCE WITH DGCA AIC

25/2020

As per DGCA AIC 25/2020 dated 04th Aug 2020, which supercedes AIC05/2020, in order to
make the Hazard reporting system more effective DGCA in addition to the Organizations
reporting system has introduced a Voluntary reporting system .

According to the same, anyone who witnesses or is involved or has knowledge of an

occurrence , hazard or situation which he or she believes possess potential threat to
flight safety is requested to report the same in prescribed performa mentioned in
Annexure A of the AIC.

Voluntary reports can be submitted to DGCA as follows:

By email on [email protected]

By post at: Voluntary Safety Reporting System

Air Safety Directorate, O/o Directorate General of Civil Aviation- HQ,
Opp. Safdarjung Airport, Aurobindo Marg, New Delhi-110003

DGCA has assured that no punitive action will be taken on such Voluntary Reporting made
unless infringement relates to Unlawful /criminal/ deliberate gross negligent unsafe action.

However the Voluntary Report is not a substitute for Statutory Mandatory Reporting
System, which will continue to function.

VOLUNTARY / CONFIDENTIAL SAFETY REPORTING TO DGCA:

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7.1.9 Hazard Reporting:

The DGCA CAR Section 1, Series 'C', Part I, Issue II, dated 27th July 2017, mandates all
Airlines and Service Providers including Subcontracted/Outsourced Agencies to implement SMS.
Air India Limited has taken a lead and implemented the SMS. The Corporate Safety
Management Manual applicable to all AOCs & subsidiaries covers all aspects/components of
SMS. This Manual has been uploaded on DMS for viewing by all personnel. Similarly, all
Departmental Manuals, including outsourced agencies also have SMS incorporated in their
manuals.

Besides mandatory reporting and investigation of occurrences (Reactive Reporting), SMS has an
Open & Non-Punitive System of Proactive Identification, Reporting and Risk Analysis of the
Hazards Database (Proactive Reporting) covering all areas of operations. As illustrated by
the Iceberg model depicted below, this exhaustive hazard database is a means to identify
latent hazardous conditions:

PROACTIVE & VOLUNTARY

REPORTING OF HAZARDS IS A
KEY TOOL TO CAPTURE A
LARGE NUMBER OF LATENT
CONDITIONS THAT HAVE
POTENTIAL TO CAUSE
INCIDENTS/ACCIDENTS

VOLUNTARY REPORTS or CONFIDENTIAL REPORTS can either be raised in the form of Hard
Copies OR On-Line by all employees through the following website:

flightsafety.airindia.in User ID: flightsafety Password: safety

The risks identified from the Voluntary Hazard Reports received from internal/external agencies
are analyzed and mitigated as per Corporate SMS Policy.

HENCE DO REPORT ANDMAKE THE AIRLINE SAFER.

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7.1.10 Effective safety reporting — five basic characteristics

7.1.11 Another source of data used to support SRM and SA processes is occurrence
reporting. This may range from the highest-consequence occurrences (accidents,
serious incidents) to lower-consequence events such as operational incidents,
system/equipment failures or defects. While regulatory requirements for
mandatory reporting of high-consequence occurrences (accidents, serious
incidents) are common, a mature safety management environment will provide for
the reporting of lower-consequence events as well. This will allow for the
necessary monitoring mechanisms to address all potential high-consequence
outcomes. The trend (rate of occurrence) of lower-consequence events is
inevitably a precursor of higher-consequence outcomes to come.

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7.2 .SAFETY DATA ANALYSIS PROCESS:

Safety data: A defined set of facts or set of safety values collected from various
aviation related

sources, which is used to maintain or improve safety.

Note. — Such safety data is collected from proactive or reactive safety-related

activities,

including but not limited to:

a) accident or incident investigations;

b) safety reporting;

c) continuing airworthiness reporting;

d) operational performance monitoring;

e) Inspections, audits, surveys; or

f) safety studies and reviews

Formal means of safety data collection include mandatory, voluntary and confidential
reporting systems.

Results of safety data analysis can highlight areas of high safety risk and
assist decision making and managers to:

a) take immediate corrective actions;

b) implement safety risk-based surveillance;
c) define or refine safety policy or safety objectives;
d) define or refine SPIs;
e) define or refine SPTs;
f) set SPI triggers;
g) promote safety; and
h) conduct further safety risk assessment.

In order to carry out an effective Safety Analysis and Performance

Management, an integrated approach is used, wherein SMS and QMS jointly
discuss and evaluate the effectiveness and performance of SMS programme.

Post monthly SAG, the SMS team and QMS jointly meet and discuss all the
ongoing and pending cases and review cases.

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As a Safety Enhancement measure and for effective implementation of SMS,

QMS auditors have a separate meeting the next day after the monthly SAG
meeting to discuss the following:

i. Repetitive QMS / SMS audit findings.

ii. SMS Training Plan implementation.
iii. Hazards are discussed
iv. FSD and SMS Safety Surveys and promotion.
v. Followup on open points of SAG, SRM,SRBM.

The minutes are documented for future reference and compliance

monitoring. One of the processes used to evaluate the effectiveness of
SMS is through feedback in the form of Safety Surveys.
These Surveys are conducted at frequent intervals and a trend analysis is
carried out to evaluate the number of safety surveys received every
quarter and then yearly.

The details of Corporate SAG and department SAG are mentioned in Chapter 6, Para 6.9
and 6.10

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TEMPLATE OF SAFETY SURVEY FORM :

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13.3: Safety Data Collection and Processing System (SDCPS):

As per DGCA issued SSP Circular 02 of 2020, Safety data collection and processing systems
(SDCPS) is a means to capture, store, aggregate and enable the analysis of Safety Data and
Safety Information to support the safety performance management activities.

The effective management of safety is highly dependent on the effectiveness of safety data
collection , analysis and overall management capabilities.
Air India follows an integrated approach to collection of the safety data that come from
different sources both internal and external to get a more accurate view of the safety risks
and to evaluate achievement of our safety objectives.

The reliable safety data and safety trends is needed to identify trends, make decisions and
evaluate safety performance in relation to safety targets and safety objectives and to assess
risk.

Air India has appropriately qualified personnel to collect, store safety data and the
personnel have the competencies needed to process the safety data.
Air India also has a designated custodian in the corporate SMS to apply the protection to
safety data, safety information and related sources for the purposes of maintaining or
improving safety as applicable.

The Safety data and safety information collected to support the Safety Performance
Management process and to make safety decisions are influenced by considerations such as
National and local conditions, priorities, data for establishing / monitoring / refinement of
the SPIs, data requirement for Safety Risk Management (SRM) Process etc.

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Minimum Safety Data and Safety Information which are required to be

maintained, as per SSP Circular 02 of 2020 are as follows:

Corporate SMS / Air Operator’s SMS Approved Maintenance Organization

 Mandatory Occurrence Reports.  Mandatory Occurrence Reports.
 Voluntary Reports  Voluntary Reports
 Flight Data Analysis  Safety Risk Assessments and Hazard
Register.
 Fatigue Risk Management System.
 SPIs / Trend Analysis.
 Recorded data- (Flight Data recorder,
cockpit voice recorder, video, ambient ,  Maintenance Records.
streamed data).
 External and Internal Audit reports.
 Safety Risk Assessments and Hazard
Register.  Reliability Programme Reports

 SPIs / Trend Analysis.  Training Records-Data of analysis of the

efficacy.
 Maintenance Records.
 Service difficulty reports.
 External and Internal Audit reports.
 In service occurrence reports.
 Reliability Programme Reports
 Maintenance and operational experience
 Training Records-Data of analysis of the reports
efficacy.
 Service Information, reports (faults,
 Dangerous Goods accident and incident malfunctions, defects)
reports.
 Unapproved Parts reports
 Special Air Reports (AIREPS)

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 AIR INDIA LIMITED
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL

HAZARD IDENTIFICATION

AND

RISK ASSESSMENT

CHAPTER – 8
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The Head of QMS and Corporate SMS shall ensure communication and coordination with
Chief of Flight Safety/Safety Officers and with operational managers in the management of
operational risk.

The Non-Conformances raised by the QMS department during the Audit is also considered
as Hazards. The open and closed non-conformances extracted from the data base of QMS
are shared on monthly basis to the flight safety department. The non-conformances are
maintained in a Hazard Register at the Flight Safety Department and will be used for
analysis purpose.

8.1.3 Hazard Register:-

8.1.3.1 SSP DIVISION CIRCULAR NO: 1 OF 2012, Rev.1 Dated 12.06.2020 OF DGCA

Safety Risk Management (SRM) Documentation :

CAR Section 1 Series C Part I requires scheduled or non-scheduled operator, general aviation
operator operating large or turbojet aeroplanes, aerodrome operators, ATS provider,
maintenance organisations, flying training organisations, organisations engaged in type design
and manufacture of aircraft, engines or propellers, to develop, establish and implement effective
Safety Management System in their respective organisations.

Appropriate documentation management regarding hazard identification is important as a formal

procedure to translate raw Operational Safety information in to Hazard-related Knowledge.
Continuous compilation and formal management of this Hazard-related knowledge becomes the
“Safety Library” of an Organization.

To Document the Hazards in an Objective manner, Hazard Register Template is utilized for
documentation and analysis purpose developed by DGCA.

Safety Risk Management (SRM) is a key component of safety management and includes hazard
identification, safety risk assessment, safety risk mitigation and risk acceptance. SRM is a
continuous activity because the aviation system is constantly changing, new hazards can be
introduced and some hazards and associated safety risks may change over time. In addition, the
effectiveness of implemented safety risk mitigation strategies must be monitored to determine if
further action is required.

Hazard identification is the first step in the SRM process followed by a safety risk assessment &
mitigation. This requires a clear understanding of hazards and their related consequences.

All the activities of Safety Risk Management should be documented, along with its probability
and severity assessment, and any safety risk mitigation actions taken.

Maintaining the data of identified hazards in a specified format minimizes the likelihood that the
organization will lose sight of its known hazards. Safety risk decision-making tools and processes

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can be used to improve the repeatability and justification of decisions taken by organizational
safety decision makers/authority to make safety risk tolerability decisions.

The SRM outputs should be documented. This documentation should include the identified
hazard and any consequences, the safety risk assessment, any safety risk control actions taken
and tracking. This SRM documentation becomes a historical source of organizational safety
knowledge which can be used as reference when making safety decisions, justification of the
decisions taken and for safety information exchange. This safety knowledge provides material
for safety trend analyses and safety training and communication. It is also useful for internal
audits to assess whether safety risk controls and actions have been implemented and are
effective.

8.1.3.2 SOURCES OF HAZARD DATA

The following non-exhaustive list shows the potential sources for hazard data. A reminder: A
HAZARD is an event with the potential to cause risk (HARM).

i. Accident/Incident investigation.
ii. Flight Operation Quality Assurance (FOQA) – also known as Flight Data Monitoring.
iii. Cockpit Voice Recorder.
iv. Internal Safety Audits
v. Flight Reports – Including Operational report, Hazard reports, Incident Reports
vi. Maintenance Report
vii. Hazard Workshop (Proactive brainstorming)
viii. DGCA Regulatory Audits and Surveillance activities
ix. Mandatory occurrence report
x. Voluntary reporting system
xi. Safety survey
xii. Line Operation Safety Audits (LOSA)
xiii. Risk Assessment (for Operational changes)
xiv. Other Organisations’ Hazard Registers.
xv. Quality Audits
xvi. Manufacturers reports
xvii. Safety Information Exchange programmes
xviii. CAR-145 Audits
xix. External Audits conducted by External Regulatory authorities such as SAFA , FAA etc.

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TEMPLATE FOR Hazard Register:

Excel spread sheet for production of a Hazard Register- also known as risk register. The aim of
this is to identify the high risks the organization faces, to access them, identify mitigations and
put in place action to assure the risk control is implemented. The spread sheet must contain the
details as per Revision 1 of the SSP Circular 01 of 2012:

The Terminology and Explanation / Meaning of the words used in Hazard Register:

TERMINOLOGY MEANING
ID Unique Hazard ID number assigned by organisation ‐ this allows traceability of
the hazard (particularly if discovered via multiple sources)
Originator Name of organisation (as used by DGCA)
Source Method from which hazard was identified. Examples could include
accident/incident investigations, safety audits, proactive methods etc.
Location If applicable, the location of the hazard (identified by its ICAO designator if
relevant)
Functional area The area (or function) of the operation within which the hazard resides
Hazard description A short description of the hazard. For guidance on hazard types, see sheet 5
of this file which gives a non‐comprehensive list
Resultant risk of Document all the risk arising from the hazard.
hazard
Worst credible effect A short description of the worst credible effect of the hazard (what risk could
and reason the hazard potentially lead to?) and the reasons for the hazard leading to this
risk
Existing controls Identification of the existing mitigation (or controls) which prevent the hazard
leading to the end effect
Outcome pre An analysis of the risk, in terms of probability, severity and safety risk
mitigation description (Intolerable, tolerable or acceptable)
Additional risk controls If the risk is found to not be acceptable (or acceptable with additional
mitigations), additional controls will be shown here
Outcome post Following the implementation of additional controls, the new outcome (risk)
mitigation is analyzed for acceptability
Action Specific actions are identified to implement any new risk controls or stop the
activity
Owner Specific action owners are identified for each action - the responsibility for
implementation of the risk control lies with them
Deadline A deadline for the action should be fixed. It is not enough to identify risk
controls and leave them to be implemented in five years' time
Review period A review period should be specified, upon which the effectiveness of the new
controls should be assessed. Are they effective, or are new risk controls
necessary?

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8.2 HAZARD REPORT ANALYSIS AND CONFIDENTIAL RECORD KEEPING PROCESS:

8.2.1 The Hazard Reports (Voluntary & Confidential) are received online by very limited
personnel authorized by COFS and information is kept confidential.

8.2.2 Once report is received online the Corporate SMS-Nodal forwards the same to Master
Hazard Register Gatekeepers, to maintain records of all Hazard reports. The Master
Hazard Register Gatekeeper de-identifies personal information from Hazard Reports
(VR, CR) and includes in Hazard Register.

8.2.3 The Hazard reports received are scanned and stored in electronic form, kept confidential
and pass- word protected. The hard copies of all the Hazard Reports (VR, CR) are
destroyed after entries are made in Master Hazard Register.

8.2.4 The de-identified Master Hazard Registers are discussed,evaluated, categorised,

prioritised, analysed and processed for risk assessment. Risk is mitigated in
consultation with SMS Nodal Officers of the functional area. The High Risk Hazards are
addressed immediately on telephone or by personnel meetings with concerned
Functional Area Nodal Officers.

8.2.5 The Hazard reports received at departmental level in all functional areas are
immediately forwarded to Corp SMS office and same are included in Master Hazard
Register and are addressed in the same way as like online reports.

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8.3 SAFETY RISK ASSESSMENT AND MITIGATION

Air India Limited has developed and maintains a hazard identification and risk assessment
process that focuses on aviation safety as their fundamental context and ensures analysis,
assessment and control of the safety risks of the consequences of hazards during the provision
of its services.

The methodology for assessing risk includes the following:

a) Establishment of acceptable level of risk, according to the “as low as reasonably practical”
(ALARP) principle.

b) Assessment of risk taking into account the severity of safety outcome and probability of
occurrence

c) Assessment of the tolerability of risk

d) Evaluation of severity, likelihood, tolerability and preventive controls.

e) Determination as to whether the risk can be tolerated,eliminated, or mitigated to a tolerable

level

f) Assessment of residual risks and any new risks introduced as a result of mitigation
measures.

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8.4 SAFETY RISK MANAGEMENT

8.4.1 Air India Limited has a program that includes a combination of reactive and proactive methods
for safety data collection and analysis that are implemented and integrated throughout the
organization to ensure existing and potential hazards to aircraft operations are identified and
analyzed.

To be effective, reactive and proactive processes are used to acquire information and data,
which are then analyzed to identify any existing or potential hazards to aircraft operations.
Examples of processes that typically yield information or data that is used to identify existing
or potential hazards include:

i. Confidential or other reporting by personnel;

ii. Investigation of accidents, incidents, irregularities and other non-
normal events;
iii. Flight data analysis;
iv. Observation of flight crew performance in line operations and
training;
v. Quality assurance and safety auditing;
vi. Safety information gathering or exchange (external sources).

Processes are designed to identify potential hazards that might be associated with
organizational business changes (e.g. addition of new routes or destinations, acquisition of
new aircraft type(s), the introduction of significant outsourcing of operational functions).

Hazards, once identified, are assigned a tracking number and recorded in a hazard register or
database. Each register or database entry includes a description of the hazard, as well as other
information necessary to track associated risk assessment and mitigation activities.

In order to develop a streamlined process as also to have a cross reference with regard to the
conformances / non-conformances raised, a centralized database of reports of audits conducted
by the various agencies, shall be maintained by the Corporate SMS for effective Safety Risk
Assessment.

8.4.2 Air India Limited has a safety risk assessment and mitigation program that includes processes
implemented and integrated throughout organization to ensure:

i. Hazards are analyzed to determine the existing and potential safety risks to aircraft
operations;
ii. Safety risks are assessed to determine the requirement for risk mitigation action(s);
iii. When required, risk mitigation actions are developed and implemented in operations.
iv. Completed safety assessments are approved by the appropriate level of management.
v. Evaluation of the effectiveness of the corrective, preventive and recovery measures that
have been developed.
vi. Ensure a periodic review of completed safety assessments and documenting their
outcomes.

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To be completely effective, a risk assessment and mitigation program is implemented in a manner

that:

i. Is active in all areas of the organization where there is a potential for hazards that could
affect aircraft operations;
ii. Has some form of central coordination to ensure all existing or potential hazards that have
been identified are subjected to risk assessment and, if applicable, mitigation.
The safety risks associated with an identified hazard are expressed in two components:
i. Likelihood of an occurrence;
ii. Severity of the consequence of an occurrence
Matrices that quantify safety risk acceptance levels are developed to ensure standardization
and consistency in the risk assessment process. Separate matrices with different risk
acceptance criteria are sometimes utilized to address long-term versus short-term operations.

A risk register is employed for the purpose of documenting risk assessment information and
monitoring risk mitigation (control) actions.

8.4.3. Air India Limited has a flight safety analysis program that provides for the identification of
hazards and the analysis of information and data associated with aircraft operations, to
include:
i. Implementation of systematic processes for identifying and analyzing hazards and
potentially hazardous conditions;
ii. Production of relevant analytical information and data for use by operational managers
in the prevention of accidents and incidents.

The flight safety analysis program primarily provides operational hazard identification and data
analysis services for use by operational managers.

8.4.4 Air India Limited shall has a process for identifying and investigating irregularities and other
non-routine operational occurrences that might be precursors to an aircraft accident or
incident.

The investigation of irregularities or non-routine occurrences is a hazard identification

activity. Minor events, irregularities and occurrences occur often during normal operations,
many times without noticeable consequences. Identifying and investigating certain irregular
operational occurrences can reveal system weaknesses or deficiencies that, if left un-
checked, could eventually lead to an accident or serious incident. These types of events are
referred to as accident precursors.

A process to monitor operations on a regular basis permits the identification and capture of
information associated with internal activities and events that could be considered
precursors.

Such events are then investigated to identify undesirable trends and determine contributory
factors.

The monitoring process is typically not limited to occurrences, but also includes a regular
review of operational threats and errors that have manifested during normal operations.

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Monitoring of normal operations can produce data that further serve to identify operational
weaknesses and, in turn, assist the organization in developing system solutions.
As with the investigation of accidents and serious incidents, the investigation of minor
internal occurrences results in a report that is communicated to relevant operational
managers for analysis and the possible development of corrective or preventive action.

8.4.5 Air India Limited uses the flight data analysis (FDA) program that is non-punitive and
contains adequate safeguards to protect data sources.

The FDA program of Air India Limitedis integrated with the Corporate SMS and includes :-

i. A systematic download and management of electronically recorded flight data from

applicable aircraft;
ii. Analysis of data that is performed in a consistent and standardized manner
iii. Methods for developing and implementing corrective or remedial action to address
adverse events or trends;
iv. Policy and procedures for ensuring remedial actions ae taken in a non-punitive manner
v. Definition and application of safeguards that de-identify and ensure security of
program data and information.

The systematic download and analysis of recorded flight data is used to identify hazards,
evaluate the operational environment, validate operating criteria and establish training
effectiveness.

The analysis of recorded aircraft flight data includes the following elements:

i. A manager and staff of flight operations experts, provides verification and analysis of
the data collected from the aircraft fleet under the operator’s program;
ii. Aircraft designated within the fleet that provide downloadable flight data from onboard
recording systems, such as the flight data recorder (FDR) or quick access recorder
(QAR)
iii. A system for downloading and transferring recorded data from the aircraft to a data
analysis system;
iv. A data analysis system that transforms raw digital data into a usable form of
information that can then be verified, processed, categorized and analyzed by flight
operations experts for flight safety purposes;
v. A process for applying the output from flight data analysis to the management of risk
and assessment of flight operations performance;
vi. A process for management of the data, to include security and retention.

Certain of the elements are outsourced to an external party; however, the Air India Limited
retains overall responsibility for the maintenance of the program.

A comprehensive approach to flight data analysis is adopted by using a program that includes
not only systematic download and analysis of electronically recorded aircraft flight data (as
described above), but also acquisition, correlation and analysis of flight information derived
from other sources (as described below).

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8.4.6 Head-Corporate SMS is the responsible Manager for the performance and smooth functioning
of the FDA Program and ensures :-
i. Program Integration and risk management within the SMS;
ii. Coordinating with relevant operational areas of the organisation to ensure FDA findings are
subjected to additional validation and assessment, and addressed with appropriate follow-
up action
iii. Disseminating de-identified information to relevant operational managers as appropriate to
ensure an awareness of relevant FDA issues and results.
iii. Liaising with relevant external entities, including OEMs and regulatory authorities.’

8.4.7 The Policies and procedures; training and qualification of personnel performing the FDA,
documentation, record retention and archievalare detailed in the FSM manual of the respective
AOCs.

8.4.8 Air India Limited has processes in the FDA Program that ensures FDA findings (i.e. Hazards,
adverse events and trends, airworthiness issues) are coordinated with relevant operational
areas for further validation and assessment, and then for determination of appropriate follow-
up action. Such coordination and follow-up action shall be accomplished within SMS as
follows:-

i. Hazard identification and safety risk assessment and mitigation

ii. Event investigation
iii. Continuing airworthiness assessment in accordance with Maintenance Management
Manual procedures.

The primary aim of an FDA program is the continuous improvement of the overall safety
performance of Air India Limited. Therefore, the FDA program which monitors and measures
flight safety performance is integrated in the Safety Assurance component of the Air India’s
Corporate SMS.

The FDA program is also used for safety hazard identification and, is integrated in the Risk
Management component of the operator’s SMS.

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8.5 RISK MANAGEMENT & SAFETY MANAGEMENT SYSTEM - POLICY

The CMD / Functional Directors / CEOs / Exec. Directors & Departmental Heads of AIR INDIA
LIMITED of all AOCs and subsidiaries are actively committed to the organisation safety and
quality as the top priority. The corporate policy commits the Organisation to a culture that has
safety, security and quality as fundamental operational priorities and to continual improvement
of the management system.

SMS (Safety Management System) and Risk Management is an integral part of every area of
work and therefore an integral part of the entire organisation. Risk Management follows the
guidelines specified in SSP Circulars / DGCA Requirements and ICAO Doc.9859

8.5.1 SAFETY ACCOUNTABILITY

The CMD / Functional Directors / CEOs / Exec. Directors & Departmental Heads of AIR INDIA
LIMITED of all AOCs and subsidiaries are accountable and responsible for safety of their
functional and operational area as a part of the Safety Management System. They will be
responsible for :-

i. identification of safety hazards within their Department;

ii. ensuring that remedial action necessary to maintain an acceptable level of safety is
implemented;
iii. providing for continuous monitoring and regular assessment of the safety level achieved;
and
iv. aiming to make continuous improvement to the overall level of safety.
v. coordinating with the Flight Safety Department / QMS as applicable.

While all Departmental and functional Heads are responsible for safety in their own functional
area, Chiefs of Flight Safety will be overall responsible for all safety functions in the
organisation. Flight Safety Department will deal with all safety matters and operational risk.

QMS will deal with Organisational Risk, including Organisational policies, programmes,
processes, procedures with the aim of continuous improvement.

Accident and incident prevention is also the responsibility of all individuals. The Department
shall follow a proactive approach to safety management.

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8.6 SAFETY MANAGEMENT

Safety is a condition in which the risk of harm or damage is limited to an acceptable level. The
safety hazards creating risk may become evident after an obvious breach of safety, such as an
accident or incident, or they may be proactively identified through formal safety management
programmes before an actual safety event occurs. Having identified a safety hazard, the
associated risks must be assessed. With a clear understanding of the nature of the risks, a
determination can be made as to the “acceptability” of the risks. Those found to be
unacceptable must be acted upon.

Safety Management is centered on such a systematic approach to hazard identification and risk
management – in the interests of minimizing the loss of human life, property damage, and
financial, environmental and societal losses.

The process of hazard identification and risk management would be mandatorily completed
and documented for each safety relevant activity to be undertaken. The department will
maintain a register of each Hazard Identified, its associated Risks and mitigation measures, if
any, proposed to be implemented. Whenever mitigation measures are proposed, their
implementation would be audited and a periodic review of their effectiveness as well as
possibility of better mitigation strategies will be undertaken.

The Seven Step Assessment process

The risk assessment is to be carried out as per the following seven step process :-

Step 1 : Development of a complete description of the system to be evaluated and of the

environment, in which the system is to be operated;

Step 2 : Identification of Hazards;

Step3 : Estimation of the severity of the consequences of a hazard occurring;

Step 4 : Estimation of the likelihood of a hazard occurring;

Step 5 :Evaluation of risk;

Step 6 :Mitigation of risk; and

Step 7 : Development of safety assessment documentation.

8.6.1 RISK MANAGEMENT PROCESS

The Risk Assessment Team within the Department will develop and document the
understanding of hazards and its risk. Further, the team would develop mitigation for the
hazards and determine the level of risk acceptance. On the basis of risk probability and risk
severity, a risk rating matrix / risk factor assessment will be prepared and risk tolerability will
be determined.

Safety risk probability is defined as the likelihood or frequency that a safety consequence or
outcome might occur.

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Safety risk severity is defined as the extent of harm that might reasonably occur as a
consequence or outcome of the identified hazard.

Risk mitigation- The process of incorporating defences or preventive controls to lower the
severity and/or likelihood of a hazard’s projected consequence.

Controls : The controls in place to ensure the objective is met.

System Safety Deficiency : The circumstance that permit hazards of a like nature to exists.

8.6.2 RISK PROBABILITY

Probability of occurrence

Qualitative
Meaning Value
Definition
Frequent Likely to occur many times (has occurred frequently) 5

Occasional Likely to occur some times (has occurred infrequently) 4

Remote Unlikely, but possible to occur (has occurred rarely) 3

Improbable Very unlikely to occur (not known to have occurred) 2

Extremely
Almost inconceivable that the event will occur 1
improbable

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8.6.3 LIKELIHOOD - IATA

Category Description
5 Frequently
4 Likely
3 Occasionally
2 Seldom
1 Rarely

8.6.4 RISK SEVERITY

Severity of occurrences

Aviation
Meaning Value
Definition
Equipment destroyed
Catastrophic 5
Multiple deaths
A large reduction in safety margins,
physical distress or a workload such
that the operators cannot be relied
upon to perform their tasks accurately
Hazardous 4
or completely.
Serious injury or death to a number of
people.
Major equipment damage
A significant reduction in safety
margins, a reduction in the ability of
the operators to cope with adverse
operating conditions as a result of
Major 3
increase in workload, or as a result of
conditions impairing their efficiency.
Serious incident.
Injury to persons.
Nuisance.
Operating limitations.
Minor 2
Use of emergency procedures.
Minor incident.
Negligible Little consequences 1

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8.6.5 RISK SEVERITY - IATA

Severity Probability / Frequency

5 - Catastrophic 5 – Certain / Immitent
4 – Severe 4 – Probable
3 – Major 3 – Likely
2 – Minor 2 – Occasional
1 - Negligible 1 – Remote / Unlikely

8.6.6 RISK FACTOR ASSESSMENT

Severity and probability may be viewed in five grades, which users can define by
money, damage or any other useful concept.

Risk Probability Risk Severity

Catastrophic Hazardous Major Minor Negligible
(A) (B) (C) (D ) (E)
5 – Frequent 25 20 15 10 5
(5A) (5B) (5C) (5D) (5E)
4 – Occasional 20 16 12 8 4
(4A) (4B) (4C) (4D) (4E)
3 – Remote 15 12 9 6 3
(3A) (3B) (3C) (3D) (3E)
2 – Improbable 10 8 6 4 2
(2A) (2B) (2C) (2D) (2E)
1 – Extremely 5 4 3 2 1
improbable (1A) (1B) (1C) (1D) (1E)

INTOLERABLE 16-25 CMD/Accountable

(Unacceptable/Extreme Risk) (4A,4B,5A,5B) Executive
INTOLERABLE 15 Head of Department
(Undesirable/High Risk) (3A,5C) (EDs)/Post Holder
TOLERABLE 9-12 ED/GM
(with action/Moderate Risk) (2A,3B,3C,4C,5D)
TOLERABLE 5-8 Dy GM/Senior Managers
(with monitoring /Low Risk) (1A,2B,2C,3D,4D,5E)
4
(4E*)
Acceptable 1-4 SMS Nodal Officer
(Negligible Risk) (1B,1C,1D,1E,2D,2E,3E representing the Deptt
)

* (4E) falls in the Tolerable (with monitoring/Low Risk) category,although its numeric value is four.

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NOTES:The Safety Risks are assessed as Acceptable, Tolerable and Intolerable and the
action required to address the same is as follows:

Intolerable Risk: Take Immediate action to mitigate the risk or stop the activity. Perform priority
safety risk mitigation to ensure additional or enhanced preventative controls are in place
to bring down the safety risk index to tolerable.

Tolerable Risk: Can be tolerated based on the safety risk mitigation. It may require management
decision to accept the risk.

Acceptable Risk: Acceptable as is. No further safety Risk mitigation required.

Risk Factor Values range from 1 to 25. The acceptable level of risk is from 1 to 4. The
unacceptable level of risk is from 16 to 25. The levels in between are acceptable only
after reducing the risk factor by suitably mitigating the risk and establishing controls.
Generally,between 5 to 8 risk is only acceptable after review of the operations and
suitable monitoring. Between 9 and 12, it is moderate risk which is acceptable with
action, wherein performing or reviewing risk mitigation is necessary. Between 13 and 15
is undesirable where high risk exists with caution. It has to be ensured that risk
assessment has been satisfactorily completed and declared preventive controls are in
place. Risk control and mitigation is required which may require a management decision.

An Operational Risk Assessment for safety critical tasks will be carried out internally by
every Department (using their own SMS members) and decisions will be taken by the
Departmental Heads to mitigate the risk, with a copy to Flight Safety, provided it
involves only their own Department. Flight Safety will be involved for all Risk
Assessments where more than one Department is involved, or if the risk factor
determined by the Department is more than 4. However, in case it is observed that the
risk assessment provided by the department is inadequate, the Flight Safety Department
will review the same and work with the departments to mitigate the risk.
On doing the Risk Factor Assessment, if the risk is acceptable, the operations pertaining to
the Department can be undertaken. If the risk is marginal, then the operation can only be
acceptable with certain risk controls and monitoring actions, in coordination with the Flight
Safety Department as applicable. This could be done by the Flight Safety representative in
the Standardization / SAG / SRM / Safety Risk Assessment Meetings or by formally
presenting to the Flight Safety Department a written report giving the risk matrix and
seeking acceptance of Flight Safety Department. If the operational risk mitigation requires
amendment of a policy and / or process, QMS representative shall be involved. If the risk
is unacceptable, that is beyond a risk factor of 16, the operation pertaining to the
Department / Airline will not be undertaken.

While SMS and Flight Safety support the risk assessments carried out by the departments,
the safety accountability for all decisions taken rests with the Head of the Department
concerned.

Note: Designations of those responsible for risk acceptability may be held by equivalent
position with regard to Air India Express, Alliance Air, AIESL and AIATSL.

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8.6.7 Risk Management Flow Process

A safety concern is perceived

Feedback & Identify hazards and assess risks

record the
hazard Define the level Define the level
identification of severity of probability
& assessment Define the level
and / or / risk of risk
mitigation
Is the risk level acceptable? No

Take action & Yes

continue the
operations Can the risk be eliminated? No

Take action &

continue the Yes
operations
Yes Can the risk be mitigated?

Take action &

Yes Can the residual risk No
continue the be accepted (if any) ?
operations

Cancel the
operation

8.6.8 Safety Risk Assessment / Analysis Form:

Safety Risk Assessment must be carried out in a common template as referred in Appendix-C at
the end of this Manual.

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 AIR INDIA LIMITED
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL

SAFETY PERFORMANCE
MONITORING AND
MEASUREMENT

CHAPTER – 9
 CORPORATE SAFETY AI–ORG-SMS-001
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AND MEASUREMENT Issue-4 Rev-0 01 JUN 2018

9.1 GENERAL

Air India Limited has developed and maintains Safety Assurance Processes to ensure
that the safety risk controls developed as a consequence of the hazard identification
and safety risk management activities achieve their intended objectives.

Safety assurance processes shall apply to an SMS whether the activities and/or
operations are accomplished internally or are outsourced.

Corporate SMS and QMS have processes for setting performance measures as a means
to monitor operational safety performance of Air India Limited and to validate the
effectiveness of safety risk controls. The SPIs are in correlation with safety objectives of
Air India Limited.

Corporate SMS and QMS has a process to identify changes within or external to the
organization that have the potential to affect the level of safety risks associated with
aircraft operations, and to manage risks that may arise from or are affected by such
changes.

Air India Limited has a process to carry out safety performance review which is verified
with reference to the safety performance indicators and safety performance targets of
the SMS in support of the established safety objectives.

The development of targets and indicators are based upon variety of data. Such data
includes, but are not limited to, the data used for hazard identification complemented by
safety studies, surveys, audits and investigations.

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9.2 SAFETY PERFORMANCE MONITORING AND MEASUREMENT – POLICY

9.2.1 Air India Limited, as part of the SMS safety assurance activities, shall develop and
maintain the necessary means to verify the safety performance of the organization in
reference to the safety performance indicators and safety performance targets of the
SMS, and to validate the effectiveness of safety risk controls.

9.2.2 Safety performance monitoring and measurement means shall include the following:

i. hazard reporting systems;

ii. safety audits;
iii. safety surveys;
iv. safety reviews;
v. safety studies; and
vi. Internal safety investigations.

9.2.3 The hazard reporting procedures shall set out the conditions to ensure effective
reporting, including the conditions under which disciplinary/ administrative action shall
not apply.

9.2.4 Performance of these SPIs are monitored and remedial action initiated in case of
unacceptable or abnormal trends.

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9.3 SETTING UP PERFORMANCE MEASURES

Air India Limited has processes for developing, maintaining set of Safety Performance
Indicators (SPI), and their associated performance targets as a means to monitor the
operational safety performance of the organization and to validate the effectiveness of safety
risk controls.

Setting measurable safety objectives is included in the safety performance monitoring and
measurement element of the Safety Assurance component of the SMS framework.

By setting performance measures, Air India Limited is able to track and compare its
operational performance against a target (i.e. the performance objective, expressed as a rate
or number reduction) over a period of time (e.g. one year). Achievement of the target (or
objective) represents an improvement in the operational performance. The use of
performance measures is an effective method to determine if desired safety outcomes are
being achieved, and to focus attention on the performance of the organization in managing
operational risks and maintaining compliance with relevant regulatory requirements.

In addressing operational performance, meaningful measures focus on lower level (i.e. lower
consequence) occurrences or conditions that are considered by the operator to be precursors
to serious events. Performance measures may be specific to a certain area of operations or
may be broad and apply to the entire system.

In addressing compliance, meaningful measures, focus on compliance with significant

regulatory requirements in all operational areas.

Performance measures are designed to be challenging, which, in turn, enhances the

effectiveness of the risk management system.

Performance measures may be set in almost any operations or maintenance area. Some
possible examples include:

i. Flight operations (e.g., landing tail strikes, unsatisfactory line or training evaluations);
ii. Operational control (e.g., fuel diversions due to fuel);
iii. Engineering and maintenance (in-flight engine shutdowns, aircraft component /
equipment failures);
iv. Cabin operations (inadvertent slide deployments);
v. Ground handling (aircraft damages due to vehicles or equipment);
vi. Cargo operations (dangerous goods spills);
vii. Operational security (unauthorized interference or access events).

Expanded guidance may be found in the ICAO SMM, the IATA Introduction to SMS and other
IATA documents.

The use of performance measures is an effective method to determine if desired safety

outcomes are being achieved, and to focus attention on the performance of the organization in
managing operational risks and maintaining compliance with relevant regulatory requirements.
In addressing operational performance, meaningful measures focus on lower level (i.e. lower
consequence) occurrences or conditions that are considered to be precursors to serious events.
Performance measures may be specific to a certain area of operations or may be broad and
apply to the entire system.

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9.3.1 Lower consequence indicators:

Safety performance indicators pertaining to the monitoring and measurement of lower-

consequence occurrences, events or activities such as incidents, non-conformance findings or
deviations. Lower consequence indicators are sometimes referred to as proactive/predictive
indicators.

9.3.2 High consequence indicators:

Safety performance indicators pertaining to the monitoring and measurement of high

consequence occurrences, such as accidents or serious incidents. High-consequence
indicators are sometimes referred to as reactive indicators.

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9.4 SAFETY PERFORMANCE MONITORING AND MEASUREMENT & SMS

9.4.1 As per ICAO Doc. 9859, the primary task of safety assurance is control. This is achieved
through safety performance monitoring and measurement, the process by which the safety
performance of the organization is verified in comparison with the safety policy and
approved safety objectives. Safety assurance control is conducted by monitoring and
measuring the outcomes of activities that operational personnel must engage in for the
delivery of services by the organization.

9.4.2 The international quality management standard, ISO-9000, supplies the following definition
of process:

“… an interrelated set of activities that transform inputs into outputs.” The emphasis on
“activities” as basically “the things people do” is the reason why so much emphasis is
placed on human error and workplace conditions in the discussions on safety and safety
management. It is these conditions that are at the root of most hazards, and it is these
conditions that are the focus of most safety risk controls. Thus, most assurance activities
under safety performance and monitoring are focused on conditions in the workplace that
affect how people perform necessary activities for the delivery of services. It is for this
reason also that the SHEL model — a model of the systems that support accomplishment
of the operational activities that make up the delivery of services — is proposed as the
guide for system description and gap analysis.

9.4.3 The following provides a list of generic aspects or areas to be considered to “assure
safety” through safety performance monitoring and measurement:

i. Responsibility - Who is accountable for management of the operational activities

(planning, organizing, directing, controlling) and its ultimate accomplishment.
ii. Authority - Who can direct, control or change the procedures and who cannot as
well as who can make key decisions such as safety risk acceptance decisions.
iii. Procedures - Specified ways to carry out operational activities and that translate the
“what” (objectives) into “how” (practical activities).
iv. Controls - Elements of the system, including, hardware, software, special procedures
or procedural steps, and supervisory practices designed to keep operational activities
on track.
v. Interfaces - An examination of such things as lines of authority between
departments, lines of communication between employees, consistency of procedures,
and clear delineation of responsibility between organizations, work units and
employees.
vi. Process measures - Monitoring performance of the SPIs including remedial action
procedure whenever unacceptable or abnormal trends are triggered. Means of
providing feedback to responsible parties that required actions are taking place,
required outputs are being produced and expected outcomes are being achieved.

Information for safety performance and monitoring comes from a variety of sources,
including formal auditing and evaluation, investigations of safety-related events, continuous
monitoring of day-to-day activities related to the delivery of services, and input from
employees through hazard reporting systems. Each of these types of information sources
may exist to some degree in every organization. However, specifications about what these
sources should be or what they should “look like” should be left at an operational level,
allowing individual organizations to tailor them to the scope and scale appropriate for the
size and type of organization. Information sources for safety performance monitoring and
measurement include:

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i. hazard reporting;
ii. safety studies;
iii. safety reviews;
iv. audits;
v. safety surveys; and
vi. internal safety investigations.

9.4.5 Hazard reporting and hazard reporting systems are essential elements in hazard
identification. Nobody knows actual system performance better than operational
personnel. An organization that wishes to know how it really operates daily, as opposed as
to how it should operate as per “the book”, should ask operational personnel, hence the
importance of reporting systems. There are three types of reporting systems:

i. mandatory reporting systems;

ii. voluntary reporting systems; and
iii. confidential reporting systems.

9.4.6 In mandatory reporting systems, people are required to report certain types of events or
hazards. This necessitates detailed regulations outlining who shall report and what shall be
reported. Since mandatory systems deal mainly with “hardware” matters, they tend to
collect more information on technical failures than on other aspects of operational
activities. To help overcome this bias, voluntary reporting systems aim at acquiring more
information on those other aspects.

9.4.7 In voluntary reporting systems the reporter, without any legal or administrative
requirement to do so, submits voluntary event or hazard information. In these systems,
regulatory agencies and/or organizations may offer an incentive to report. For example,
enforcement action may be waived for events that are reported underlining errors or
unintentional violations. The reported information should not be used against the
reporters, i.e. such systems must be non-punitive and afford protection to the sources of
the information to encourage the reporting of such information.

9.4.8 Confidential reporting systems aim to protect the identity of the reporter. This is one way
of ensuring that voluntary reporting systems are non-punitive. Confidentiality is usually
achieved by de-identification, and any identifying information about the reporter is known
only to “gatekeepers” in order to allow for follow-up or “fill in voids” in the reported
event(s). Confidential incident reporting systems facilitate the disclosure of hazards leading
to human error, without fear of retribution or embarrassment, and enable broader
acquisition of information on hazards.

While the basic processes underlying reporting systems are standardized, the actual
reporting requirements may vary among States and organizations. It is also important to
note, in order to ensure the success of the reporting systems, that there is a normal
reluctance by operational personnel to report. This statement is valid for all types of
reporting, and particularly applicable where self-reporting of errors is involved. There are
reasons for this reluctance: retaliation, self-incrimination and embarrassment just to
mention the topmost three. Education in terms of the importance of safety reporting in
hazard identification systems, and the protection of the sources of safety information are
essential strategies to circumvent reluctance to report and to ensure an effective safety
reporting environment. Typical qualities of successful safety reporting systems include:

i. the reports are easy to make;

ii. there are no disciplinary actions as a result of the reports;

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iii. the reports are confidential; and

iv. feedback is rapid, accessible and informative.

9.4.9 Safety studies are rather large analyses encompassing broad safety concerns. Some
pervasive safety issues can best be understood through an examination in the broadest
possible context. An organization might experience a safety concern which is of a global
nature, and which may have been addressed on an industry- or Statewide scale. For
example, an airline may experience an increase in approach and landing related events
(unstable approaches, deep landings, landings with excessive airspeed and so forth). At a
global level, the industry has been concerned with the frequency and severity of approach
and landing accidents (ALA) and has undertaken major studies, produced many safety
recommendations and implemented global measures to reduce such events during the
critical approach and landing phases of flight. Thus, the airline in question can find in
these global recommendations and studies convincing arguments for its own, in-house
safety analysis. Such arguments are necessary to achieve large-scale changes requiring
significant data, appropriate analysis, and effective communication. Safety arguments
based on isolated occurrences and anecdotal information may not be enough. Because of
their nature, safety studies are more appropriate to address system safety deficiencies
rather than identify specific, individual hazards.

9.4.10 Safety reviews are conducted during introduction and deployment of new technologies,
change or implementation of procedures, or in situations of a structural change in
operations. Safety reviews are a fundamental component of the management of change.
They have a clearly defined objective that is linked to the change under consideration. For
example, an airport is considering implementing airport surface detection equipment
(ASDE). Therefore, the objective of the safety review would be to assess the safety risks
associated with implementing an ASDE at XYZ airport by evaluating the appropriateness
and effectiveness of the safety management activities related to the project. Safety
reviews are conducted by Safety Action Groups (SAG), which look for effective
performance of the following safety management activities under the proposed changes:
i. hazard identification and safety risk assessment/mitigation;
ii. safety measurement;
iii. management accountabilities;
iv. operational personnel skills;
v. technical systems; and
vi. abnormal operations.

Once performance of each safety management activity under the proposed changes is
reviewed, the SAG produces a list of hazard concerns for each activity, the
response/mitigation proposed by the line manager, and an assessment of the
appropriateness and effectiveness of the mitigations to address the hazards. The mitigation
will be appropriate if it actually addresses the hazard. The mitigation will be effective if it
consistently manages the safety risks under normal operating conditions in order to reduce
the safety risks to ALARP. The SAG also proposes a prioritization of the
responses/mitigations, by allocating importance and urgency to each hazard. Safety reviews
thus ensure safety performance during periods of change, by providing a roadmap to safe
and effective change.

9.4.11 Audits focus on the integrity of the organization’s SMS and periodically assess the status of
safety risk controls. As with other requirements, the auditing requirements are left at a
functional level, allowing for a broad range of complexity, commensurate with the
complexity of the organization. While audits are “external” to the units involved in
activities directly related to the provision of services, they are still

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“internal” to the organization as a whole. Audits are not intended to be in-depth audits of
the technical processes but rather they are intended to provide assurance of the safety
management functions, activities and resources of line units. Audits are used to ensure
that the structure of the SMS is sound in terms of staffing, compliance with approved
procedures and instructions, levels of competency and training to operate equipment and
facilities and maintain required levels of performance, etc.

9.4.12 Safety surveys examine particular elements or procedures of a specific operation, such as
problem areas or bottlenecks in daily operations, perceptions and opinions of operational
personnel and areas of dissent or confusion. Safety surveys may involve the use of
checklists, questionnaires and informal confidential interviews. Since surveys are
subjective, verification may be needed before corrective action can be taken. Surveys may
provide an inexpensive source of significant safety information.

9.4.13 Internal safety investigations include occurrences or events that are not required to be
investigated or reported to the State, although in some instances organizations may
conduct internal investigations notwithstanding the fact that the event in question is being
investigated by the State. Examples of occurrences or events that fall within the scope of
internal safety investigations include: in-flight turbulence (flight operations); frequency
congestion (ATC); material failure (maintenance), and ramp vehicle operations
(aerodrome).

9.4.14 In conclusion, the contribution of safety performance and monitoring information

sources to an organization’s SMS can be summarized as follows:

i. hazard reporting is a primary source of information on hazards in operations;

ii. safety studies are a source of information on generic safety concerns and/or
systemic safety deficiencies;

iii. safety reviews are linked to the management of change and ensure safety
performance under changing operational conditions;

iv. audits ensure the integrity of SMS structures and processes;

v. safety surveys sample expert opinion and perceptions on specific problem areas
in daily operations; and

vi. internal safety investigations address outcomes of minor magnitude that are not
required to be investigated by the State.

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9.5 PERFORMANCE MEASURES - SMS & QMS

AIR INDIA LIMITED has a process for setting performance measures as a means of
evaluating the organisational risk management system and the effectiveness of:-

i. preventing accidents, incidents and acts of unlawful interference;

ii. maintaining compliance with regulations and other requirements relevant to the
quality, safety and security of operations.
iii. maintaining Organisational goals of higher productivity & efficiency.
iv. maintaining high levels of customer service and customer satisfaction
v. proper utilization of resources and manpower
vi. proper financial management
vii. monitoring and control of outsourced activities, wet lease & dry lease
operations, external service providers and product control

The SMS supported by QMS shall establish a performance measure, which is similar to
a goal or objective, identifies a target number or rate of occurrences in any functional
area and then track and compare the actual performance against the target rate or
number over a period of time (usually one year). It is an effective method for
measuring functional performance to determine if desired outcomes are being achieved
and for focusing attention on and creating an awareness of the performance of the
organisation in managing the risks associated with all functions and compliance with
relevant regulatory requirements.

The Head of Corp. SMS and Head of Corp. QMS, Exec. Director-Flight Safety and all
functional Heads should ensure that in addressing the safety and security of operations
for Operational risk management, meaningful measures would not focus on major
events, such as accidents or actual acts of unlawful interference, but rather would
concentrate on lower level occurrences or conditions that are considered by the AIR
INDIA LIMITED to be precursors to more serious events.

Effective performance measures might include rates for specific minor occurrences or
irregularities determined by AIR INDIA LIMITED to be precursors. Performance
measures may be focused and specific or may be broad and apply to the entire
operation. Performance measures may include numbers or rates of occurrence.

In addressing compliance, meaningful measures, as a minimum, would focus on

compliance with significant regulatory requirements (as determined by AIR INDIA
LIMITED) in all operational areas.

Ideally, performance measures are designed to be challenging, which, in turn,

enhances the effectiveness of the risk management system.

Performance measures may be set in almost any functional area. Some possible
examples include:

i. flight operations (e.g., landing tail strikes, unsatisfactory line or training

evaluations);

ii. operational control (e.g., fuel diversions due to fuel);

iii. engineering and maintenance (in-flight engine shutdowns, aircraft

component/equipment failures)

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iv. cabin operations (inadvertent slide deployments)

v. ground handling (aircraft damages due to vehicles or equipment)

vi. cargo operations (dangerous goods spills);

vii. operational security (unauthorised interference or access events)

ii. HR Policies

iii. Commercial decisions

iv. Training

v. Customer satisfaction

vi. On-time performance

vii. Fuel management

viii. Cost reduction

ix. Introduction of new measures for Organisational efficiency

x. Emergency response

xi. Profitability

All Functional Heads, Executive Directors of Ground Handling, Cargo, Engineering &
Maintenance, Security, Operations and Inflight Services shall ensure, that their
operational areas meet all the safety and security related regulatory requirements at all
times.

It is the responsibility of the SMS and QMS to track the compliance of all the above
functional areas with the regulatory requirements. To enable this, the above functional
areas shall submit a certificate issued once every six months on the 30 th of June and
31st of December every year in the form of a certificate indicating regulatory
compliance, to the Head of SMS and QMS.

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9.6 SAFETY PERFORMANCE INDICATORS

Safety Performance Indicators constitute a key tool in analysing large quantities of data,
helping to identify safety threats. These indicators often reflect changes in the number of
events. Analysing the events themselves and their causes uncovers key safety threats and
unfavorable trends, and helps in finding measures to prevent or mitigate them. The
effectiveness of Safety Performance Indicators is evaluated on an annual basis. It is a data
based parameter used for monitoring and assessing safety performance. It is used as a
measure of the safety performance of a department. Safety indicators should be easy to
measure and be linked to the major components of a company’s SMS. Safety indicators
will therefore differ between departments.

9.6.1 Safety Objective : The safety performance monitoring requires a surrounding dimension
that provides shelter to safety performance indicators (SPI) and safety performance
targets (SPT). The Safety objectives provide this sheltering frame works. Air India Limited
has clear safety objectives and identifies various safety concern to improve its safety
performance. They are mentioned in Chapter 5 of this manual.

9.6.2 Safety performance: The safety performance is the joint consideration of safety
achievements by an airline and effectiveness of the intervention implemented to realise
safety achievements. It is a state or service provider’s safety achievement as defined by
its safety performance targets and safety performance indicators.

9.6.3 Safety performance indicators: It is a data based parameter used for monitoring and
assessing safety performance . It is used as a measure of the safety performance of a
department. Safety indicators should be easy to measure and be linked to the major
components of a company’s SMS. Safety indicators will therefore differ between
departments.

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9.6.4 Safety performance targets: Targets are determined by considering what safety
performance levels are desirable and realistic for individual departments. It is the planned
or intended objective for safety performance indicator(s) over a given period of time .
Safety targets should be measurable, acceptable and consistent with SMS.

While the Air India Air India Limited shall strive to monitor performance indicator as
indicated by the State Safety Programme, the following SPIs shall be monitored which can
be modified from time to time as per the requirement:

9.6.4.1 SAFETY PERFORMANCE INDICATORS OF FLIGHT SAFETY DEPARTMENT:

1. Number of PIB incidents per 10,000 flight hours per Quarter

2. Number of PIB incidents per 10,000 flights per Quarter
3. Total number of SMS reports received per quarter
4. Percentage of reports actioned per quarter
5. Percentage of pending enforcement actions
6. Number of OPEN audit findings per quarter (pending action)
7. No. Of Serious Incidents per 10,000 flight hours per Quarter
8. SAFA Ratio to be maintained below 2.

Flight Safety Department also has to monitor the SPIs mandated by DGCA
State Safety Programme (SSP) for the Airline, which are listed below :

1. Number of TCAS RA in Controlled Airspace leading to Breach of Separation per Quarter

2. Number GPWS/EGPWS warning per Quarter
3. Unstabilized Approach :
a. Number of Unstabilized Approaches per Quarter
b. Number of Unstabilized Approaches that Continued to land per Quarter
c. Number of Unstabilized Approaches when performing a precision approach per
Quarter
d. Number of Unstabilized Approaches when performing a non-precision approach per
Quarter
e. Number of Unstabilized Approaches when performing a visual approach per Quarter
4. Loss of Control Precursor events
5. Actual Stick Shaker Events per Quarter
6. Low speed during approach events per Quarter
7. Low speed during cruise events per Quarter
8. Bank Angle Exceedance events per Quarter
9. Wind shear below 500ft per Quarter
10. Number of runway incursion per Quarter
11. Number of runway excursion per Quarter
12. Number of Ground/Ramp Incidents per quarter
13. Number of Wildlife Strike (Animal/Bird) events per 10,000 flights per quarter.
14. Number of Maintenance Error per Quarter:
15. Failure to follow published technical data or local instruction
16. Using unauthorized procedure not referenced in technical data
17. Supervisor/staff failure to follow maintenance instructions and approved data
18. Failure to document maintenance task properly in maintenance records
19. Inadequate/unrecognized maintenance
20. Incorrectly installed hardware on aircraft/engine
21. Performing unauthorized modification on the aircraft
22. Failure to conduct a tool inventory after completion of the task
23. Personnel not trained or certified to perform the task

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24. Ground support equipment improperly positioned for the task

25. Number of Level 1 findings from QMS and Flight Safety.

9.6.4.2 SPIs OF OPERATION DEPARTMENT:

1. Total hours of FDTL extension per total flying hrs per quarter.
2. Total number of SMS report received per quarter
3. Percentage of report actioned per quarter.
4. Number of employees trained on SMS per quarter.
5. Number of Level 1 findings from QMS and Flight Safety.

9.6.4.3 SPIs OF FLIGHT DESPATCH DEPARTMENT:

1. Flight Plan deviation (Error in fuel calculation, routing, weather information, ATC
information, different flight level assigned etc.) per quarter
2. Flight following (Diversion due to flight dispatch/ operation control, pertaining to safety
consideration, etc.) per quarter
3. Total number of SMS report received
4. Percentage of report actioned per quarter.
5. Number of employees trained on SMS per quarter.
6. Number of Level 1 findings from QMS and Flight Safety.

9.6.4.4 SPIs OF CABIN SERVICES DEPARTMENT :

1. Cabin Operations (Inadvertent slide chute deployment) per quarter

2. Cabin crew / Passenger injury per quarter
3. Cabin incidents of smoke / fire / fumes per quarter
4. Number of employees trained on SMS per quarter.
5. Number of Level 1 findings from QMS and Flight Safety per quarter
6. Total number of SMS report received per quarter
7. Percentage of report actioned per quarter.

9.6.4.5 SPIs OF ENGINEERING DEPARTMENT :

1. Number of Maintenance Error per Quarter:

a. Failure to follow published technical data or local instruction
b. Using unauthorized procedure not referenced in technical data
c. Supervisor/staff failure to follow maintenance instructions and approved data
d. Failure to document maintenance task properly in maintenance records
e. Inadequate/unrecognized maintenance
f. Incorrectly installed hardware on aircraft/engine
g. Performing unauthorized modification on the aircraft
h. Failure to conduct a tool inventory after completion of the task
i. Personnel not trained or certified to perform the task
g. Ground support equipment improperly positioned for the task

2. Number of delays due to maintenance per 10000 hrs

3. Number of AOG per 10,000 hrs per quarter
4. Total number of SMS report received per quarter
5. Percentage of report actioned per quarter
6. Number of MEL extension beyond permissible time period per quarter
7. Number of premature component replacement per total number of component replaced
per quarter

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8. Dispatch reliability per quarter.

9. Number of Level 1 findings from QMS and Flight Safety.
10. Number of employees trained on SMS per quarter.
11. Number of In-flight shutdowns per quarter.
12. Aircraft utilization per quarter.

9.6.4.6 SPIs OF GROUND HANDLING DEPARTMENT:

1. Number Of ground/Ramp incident per 10,000 flights per quarter.

2. Total number of SMS report received per quarter
3. Percentage of report actioned per quarter.
4. Employees trained on SMS per quarter.
5. Number of Level 1 findings from QMS and Flight Safety.
6. Number of Load Sheet errors per quarter.
7. Number of DG non-compliance per quarter.

9.6.4.7 SPIs OF TRAINING DEPARTMENT :

1. Number of pilots whose licenses has lapsed ( due medical/ recurrent training etc.) with
respect to total pilot strength per quarter
2. Total number of SMS report received per quarter
3. Percentage of SMS reports actioned per quarter.
4. Total red FOQA Exceedance per 10,000 cycles per quarter.
5. Number of Level 1 findings from QMS and Flight Safety.
6. Number of employees trained on SMS per quarter

9.6.4.8 SPIs OF CARGO DEPARTMENT :

1. Number of DG related incidents per 10000 flights per year

2. Percentage of employees who have completed SMS training per quarter.
3. Total number of SMS report received per quarter.
4. Percentage of SMS reports actioned per quarter.
5. Number of Level 1 findings from QMS and Flight Safety.

9.6.4.9 SPIs OF SECURITY DEPARTMENT :

1. Number of Bomb threat incidents per 10000 flights per quarter

2. Number of High-jack events per 10000 flights per quarter
3. Number of security breach / violations per 10000 flights per quarter
4. Percentage of employees who have completed SMS training per quarter.
5. Total number of SMS report received per quarter
6. Percentage of SMS reports actioned per quarter.
7. Number of Level 1 findings from QMS and Flight Safety.

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9.6.4.10 SPIs OF FINANCE DEPARTMENT :

1. Percentage reduction in insurance premium per aircraft compared to previous year.

2. Deferment of discretionary spending – capital expenditure, training, advertising, etc.
3. Loss of valuable suppliers/ vendors.
4. Percentage of outsourced/ temporary contract personnel (ex: expat pilots, flight
dispatcher, maintenance personal etc.) with respect to total employees.
5. Revenue per available seat kilometer per quarter
6. Aircraft utilization
7. Cost per available seat kilometer per quarter
8. Operating cost
9. Total number of SMS report received
10. Percentage of report actioned per quarter

9.6.4.11 SPIs OF COMMERCIAL DEPARTMENT :

1. Number of passenger compliant per quarter.

2. Number of delay or cancellation per 10,000 departure per quarter
3. Load factor per quarter.
4. Total number of SMS report received per quarter.
5. Percentage of report actioned per quarter

9.6.5 Safety Alerts:

A corresponding alert level is identified for each safety performance indicator, quantifying the
unacceptable performance threshold (abnormal occurrence rate) during a specified monitoring
period. The use of objective data-based criteria for setting alert levels is essential to facilitate
consistent trending or benchmarking analyses. An alert level setting separates the acceptable
from the unacceptable performance regions of a safety indicator chart and is the primary
trigger (caution/alarm bell) for remedial action related to a particular safety indicator. A breach
of an alert level warrants follow-up investigation as to the cause of the alert and consequent
corrective or mitigating actions where necessary. Follow-up actions involve coordination with
affected areas to identify root causes, hazards and associated risks as applicable.

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9.6.6 Refinement of SPIs and SPTs:

Refinement of SPIs and SPTs

SPIs and associated SPTs are periodically reviewed to determine if they are providing the
information needed to track the progress being made toward the safety objectives and to
ensure that the targets are realistic and achievable. Refinement/review of SPIs and SPTs are
undertaken as and when necessary.

Some reasons to continue, discontinue or change SPIs and SPTs include:

a) SPIs continually report the same value (such as zero per cent or 100 per cent); these
SPIs are unlikely to provide meaningful input to senior management decision- making;
b) SPIs that have similar behavior and as such are considered a duplication;
c) The SPT for an SPI implemented to measure the introduction of a programme
or targeted improvement has been met;
d) another safety concern becomes a higher priority to monitor and measure;
e) to gain a better understanding of a safety concern by narrowing the specifics of SPI (i.e.
reduce the “noise” to clarify the “signal”); and
f) safety objectives have changed and as a consequence the SPIs require updating to
remain relevant.

Review and termination of SPIs:

Whenever the safety concern does no longer exist and the desired outcome is achieved, the
concerned SPI reviewed and proposed to senior management for removing from existing
SPIs. Once senior management approves, it ceases to be an SPI.

Document protection and record keeping:

The SPI report once finalised is printed in and distributed to Corp. SMS office at Mumbai and
Delhi as controlled copies. The Soft copy is preserved in the Safety Data Protection System for
future reference.

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9.6.7 . Linking Safety Objectives with SPIs:

Safety performance indicator.It is s data-based parameter used for

monitoring and assessing safety performance.

This chapter covers process of developing the SPIs which are linked to the Safety
Objectives, Deciding of SPI targets, safety action plan to achieve the target,
action plan to deal with safety issues identified during the safety performance
monitoring (i.e when and how to review the action plan when if an adverse
trend is notice during the SPI achieved performance during the monitoring
period. This chapter also explain the process of monitoring and bench marking
of Air India Safety performance with the acceptable level of safety
performance established by the State through the National Safety
Performance plan.

The State Safety plan (SSP) covers the management of safety in the State, in
order to achieve an acceptable level of safety performance in civil aviation. In
order to monitor and control the safety performance, it is to be measured as we
cannot manage what we cannot measure.

Safety Objectives:

Safety objectives are brief, high-level statements of safety achievements or

desired outcomes to be accomplished. Safety objectives provide direction to
the organization’s activities and should therefore be consistent with the safety
policy that sets out the organization’s high-level safety commitment. They are
also useful to communicate safety priorities to personnel and the aviation
community as a whole. Establishing safety objectives provides strategic
direction for the safety performance management process and provides a
sound basis for safety related decision-making. The management of safety
performance should be a primary consideration when amending policies or
processes or allocating the organization’s resources in pursuit of improving
safetyperformance. The safety policy is signed by the accountable executive
(CMD) and Safety Objectives are enumerated in the safety policy.

As the Safety is one of the core business functions of Air India Limited
covering all Air Operator Permits, subsidiaries and Strategic Business
Unit (SBU) functions, all safety objectives are aimed to achieve
highest level of Safety performance.

The use of performance measures is an effective method to determine if desired safety outcomes are
being achieved, and to focus attention on the performance of the organization in managing operational
risks and maintaining compliance with relevant regulatory requirements.

In addressing operational performance, meaningful measures focus on lower level (i.e. lower
consequence) occurrences or conditions that are considered to be precursors to serious events.
Performance measures may be specific to a certain area of operations or may be broad and apply to
the entire system.

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In addressing compliance, meaningful measures, as a minimum, would focus on compliance with

significant regulatory requirements (as determined) in all operational areas.
Ideally, performance measures are designed to be challenging, which, in turn, enhances the
effectiveness of the risk management system.
Performance measures have been set in all operations or maintenance area.

SPIs linked to Safety Objectives:

The safety objectives of Air India Ltd. are expressed as a top-level statement describing the
organization’s commitment to achieving safety, which are as follows:

DGCA Mandated SPIs as per National Aviation

Safety Plan

1. Airborne Conflicts

1 To reduce the risk of Operations Number of risk bearing AIRPROX per

airborne conflict occurring 10,000 flights
through tracking and
Number of TCAS RA in controlled
actively managing events
airspace leading to breach of
that can lead to a
separation per 10,000 flights
collision.
Number of Aircraft not or incorrectly
complying with ATC instructions

Number of Airprox attributable to

ATC/System failure

Communication Errors

2.Controlled Flight into Terrain

2 To reduce the risk of CFIT Operations Number of GPWS/EGPWS

events occurring through warnings per 10,000
tracking and actively departures
managing events that can
lead to a collision.

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3. Runway excursions and overrun

3 To reduce number of Operations 3.1 Number of

runway excursions Unstablised approaches
per 10,000approaches

Operations Number of unstablised approaches that

continue to land per 10,000 approaches

Operations Number of unstablised approaches

when performing a precision
approach per 10,000approaches.

Operations Number of unstablised approaches

when performing a non-precision
approach (no vertical guidance) per
10,000 approaches

Operations Number of unstablised approaches

when performing a visual approach
per 10,000approaches

Operations Number of ‘near’ runway excursions per

10,000approaches

Operations Number of runway excursions per

10,000Approaches

4. Loss of Control in Flight

4 To reduce the number of operations Actual stick-shake and alpha floor per
loss of control pre- cursor 10000 departures:
events.
 Actual stick-shaker/alpha floor

 Low speed during approach

events

 Low speed during cruise events

 Bank angle exceeding

(maximum permitted) as per

• AFM for aircraft type.

 Windshear below 500ft

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5. Ground collision and Ramp Safety

5 To reduce the number of operations Number of runway incursions

ground collisions between (aircraft) per 10000
departures
aircraft, ground
Ground Handling Number of runway incursions
collisions between vehicles
(vehicle) per 10000
and aircraft and the number
departures
of fatalities and serious
injuries occurring on the ramp Operations Number of runway incursions
(person) per 10000
departures

Operations Number of runway incursion

incidents involving loss of situational
awareness by pilots, non-
familiarisation with aerodrome
layout, distraction per 10000
departures

Ground Handling Number of ramp incidents that result in

damage to aircraft, vehicles or loss of
life/serious injury to personnel per
10000 departures

6. Deficient Maintenance

6 To improve the maintenance Engineering Incident involving

of component/system failure per 10000
aircraft, thereby reducing the departures
number of incidents relating to
Number of Maintenance errors per
maintenance issues.
10000 departures

7.Aviation procedures and Documendation

7 Regulatory audit findings related Regulatory DGCA Objective - (measured in terms of

to procedures percentage of total findings)

Regulatory audit findings related Regulatory DGCA Objective - (measured in terms of

to work place manuals percentage of total findings)

Regulatory audit findings related Regulatory DGCA Objective-(measured in terms of

to documendation percentage of total findings)

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9.7 Management of change

9.7.1 Air India Limited, as part of the SMS safety assurance activities, has committed to develop
and maintain a formal process for the management of change.

9.7.2 The formal process for the management of change is to :-

i. identify changes within the organization which may affect established processes and
services;
ii. establish arrangements to ensure safety performance prior to implementing changes;
and
iii. eliminate or modify safety risk controls that are no longer needed due to changes in
the operational environment.

Details are in Chapter 14 of this Manual.

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9.8 SAFETY ASSURANCE

The Corporate SMS and QMS carries out safety and quality assurance for operational and
non-operational areas across the organisation for all the AOCs.

The planned safety and quality audits have been effective in performance monitoring in not
only safety aspects but across the organizational level.

The Corporate QMS audits the entire Organisation, and all Departments for Safety, quality
and security assurance. It also audits Flight Safety Departments of the three AOCs and the
SMS for each AOC. The audits of each and every Department include the SMS component
within the Department.

For details refer chapter 10, 12, and 14 of this Manual and Flight Safety Manuals of the AOCs

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9.9 SAFETY ASSURANCE & SMS

9.9.1 As per ICAO Doc.9859, Safety risk management requires feedback on safety performance to
complete the safety management cycle.

Through monitoring and feedback, SMS performance can be evaluated and any necessary
changes to the system effected.

As part Safety Assurance process, the risk mitigations and controls are being verified and
audited periodically to confirm their effectiveness.

In addition, safety assurance provides stakeholders an indication of the level of safety

performance of the system.

9.9.2 Assurance can simply be defined as “something that gives confidence”. The safety risk
management process in the SMS starts with the organization obtaining a good
understanding of its operational processes and the environments in which it operates;
progresses through hazard identification, safety risk assessment and safety risk mitigation,
and culminates in development and implementation of appropriate safety risk controls. Once
controls for the safety risks of the consequences of hazards are designed, deemed to be
capable of controlling safety risks, and put into operation, safety assurance takes over
safety risk management.

9.9.3 Once safety risk controls are developed and implemented, it is the responsibility of Air India
Limited to assure that they continue to be in place and that they work as intended. Under
the above definition of “assurance,” this consists of processes and activities undertaken to
provide confidence as to the performance and effectiveness of the controls. Air India Limited
continually monitors its operations and the environment to assure that it recognizes changes
in the operational environment that could signal the emergence of new and unmitigated
hazards, and for degradation in operational processes, facilities, equipment conditions, or
human performance that could reduce the effectiveness of existing safety risk controls. This
would signal the need to return to the safety risk management process to review and, if
necessary, revise existing safety risk controls or develop new ones.

9.9.4 A process of permanent examination, analysis and assessment of these controls continue
throughout the daily operation of the system. The safety assurance process mirrors that of
quality assurance, with requirements regarding analysis, documentation, auditing, and
management reviews of the effectiveness of the safety risk controls.

As a means of assuring attainment of organizational objectives, quality assurance

techniques are applicable to safety assurance. In order to use these techniques for safety
assurance, the organization must be careful in setting and measuring objectives with
respect to safety.

9.9.5 Air India Limited has designed and implemented all operational processes in such a manner
as to incorporate safety risk controls based on a sound application of safety risk
management principles and to provide assurance of those controls.

In a properly deployed SMS, there is no conflict between safety risk assurance and regulatory
compliance assurance. Regulations are a part of the system design, and regulatory
compliance and safety risk management are parts of the same whole. Compliance with
regulations is still an expectation and should be within the purview of safety assurance as an
activity aimed at “giving confidence” in the performance of the SMS.

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9.9.6 Senior management ensures that safety satisfaction and customer satisfaction objectives
are balanced in order to maintain business viability while maintaining safety of operations.

9.9.7 The safety assurance activities include procedures that ensure that corrective actions are
developed in response to findings of reports, studies, surveys, audits, evaluations and so
forth, and to verify their timely and effective implementation. Organizational responsibility
for the development and implementation of corrective actions should reside with the
operational departments cited in the findings. If new hazards are discovered, the safety risk
management process should be employed to determine if new safety risk controls should be
developed.

9.9.8 The QMS – Quality Assurance includes the Safety Assurance as well, and they work in
integration with the Corporate SMS.

9.9.9 Air India Air India Limited has an established Safety Review Committee (SRC) and Safety
Action Group (SAG). The important issues pertaining to Safety and SMS are discussed during
the various SAG, SRM and SRBM meetings carried out as per the approved plan, wherein the
remedial actions shall be proposed for implementation and the same is documented. details
provided in Chapter 8 of this manual.

9.9.10 The guidance for composition and functions of SRC/SAG are referred from the ICAO Doc
9859.

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SAFETY RELATED INVESTIGATIONS

AND REMEDIAL ACTIONS
CHAPTER – 10
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10.1 GENERAL

The sole objective of the investigation of an accident/serious incident or

incident shall be to identify the root cause and recommend measures to
prevent recurrence, including their correlation with the organisation’s SMS
hazard identification and risk management system.

AIR INDIA LIMITED has a defined process for investigation of Safety related
occurrences as per DGCA CAR requirements and reporting of the same to the regulatory
authority, DGCA.
The details are provided in the respective Flight Safety Manuals of the AOCs. The Flight
Safety Department is the nodal department carrying out independent Investigation of
incidents / accidents/ occurrences as per DGCA requirements

DGCA will evaluate each occurrence report received to decide which occurrence requires
investigation by the DGCA or by the concerned operator under the supervision of the
DGCA.

The Serious Incidents and Accidents are investigated by AAIB, Govt of India in
accordance with the Procedures Manual of Aircraft Accident /Incident Investigation
Procedures.

Air India Limited has adopted the following:

i. Procedures to ensure that reported accidents and incidents are investigated internally,
as given in the Flight Safety Manual.
ii. Dissemination of completed investigation reports internally as well as to the DGCA as
applicable.
iii. A process for ensuring that corrective actions taken or recommended are carried out and
for evaluating their outcomes/effectiveness.
iv. Procedure on disciplinary inquiry and actions associated with investigation report
outcomes.
v. Clearly defined conditions under which punitive disciplinary action would be considered
(e.g. illegal activity, recklessness, gross negligence or wilful misconduct).
vi. A Just Culture wherein personnel are not punished for actions, omissions or decisions
taken by them which are commensurate with their experience and training, but where
gross negligence, wilful violations and destructive acts are not tolerated.
vii. Defined safety policy statement which clearly indicates which types of behaviours are
unacceptable related to the aviation activities and includes the circumstances under
which disciplinary action would not apply;
viii. Enhanced its existing disciplinary procedure/ policy with due consideration of
unintentional errors or mistakes from deliberate or gross violations.
ix. A process to ensure that investigations include identification of active failures as well as
contributing factors and hazards.
x. Investigation procedure and format provides for findings on contributing factors or
hazards to be processed for follow-up action by the organisation’s hazard identification
and risk management system where appropriate.

The details of above processes are elaborated in the relevant chapters of the Flight
Safety Manual.

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10.2 INVESTIGATION OF AIRCRAFT ACCIDENTS AND INCIDENTS:

Air India Limited has a process for the investigation of aircraft accidents and incidents, to
include reporting of events in accordance with requirements of the State.
Accident and incident investigation is considered a reactive hazard identification activity in
an SMS. A primary purpose of accident and incident investigation is hazard identification,
which is an element of the Safety Risk Management component of the SMS framework.
Investigations result in a report that describes the factors that contributed to the event,
which is then made available to responsible senior operational managers to permit them
to evaluate and implement appropriate corrective or preventive action.

An effective investigation process includes:

i. Qualified personnel to conduct investigations (commensurate with operation size);
ii. Procedures for the conduct of investigations;
iii. A process for reporting investigative results;
iv. A system for implementing any corrective or preventive action;
v. An interface with relevant external investigative authorities (when applicable);
vi. A process for the dissemination of information derived from investigations.

To ensure awareness among operational personnel, information derived from

investigations is disseminated to relevant areas throughout the organization.

In the event of a major accident, Air India Limited responds to participates in an

investigation in accordance with DGCA requirements and provisions contained in ICAO
Annex 13. Such capability requires Air India Limited to maintain an ongoing interface with
relevant investigative authorities to ensure preparedness in the event a major accident
occurs.

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10.3 INVESTIGATIGATION OF IRREGULARITIES AND OTHER NON-ROUTINE

OPERATIONAL OCCURRENCES:

Air India Limited has a process for identifying and investigating irregularities and other non-
routine operational occurrences that might be precursors to an aircraft accident or incident.

Investigation of operational irregularities is considered a reactive hazard identification

activity in an SMS. A primary purpose of investigating non-routine operational occurrences is
hazard identification, which is an element of the Safety Risk Management
component of the SMS framework.

The investigation of irregularities or non-routine occurrences is a hazard identification

activity. Minor events, irregularities and occurrences occur often during normal operations,
many times without noticeable consequences. Identifying and investigating certain irregular
operational occurrences can reveal system weaknesses or deficiencies that, if left un-
checked, could eventually lead to an accident or serious incident. These types of events are
referred to as accident precursors.

A process to monitor operations on a regular basis permits the identification and capture of
information associated with internal activities and events that could be considered
precursors. Such events are then investigated to identify undesirable trends and determine
contributory factors.

The monitoring process is not limited to occurrences, but also includes a regular review of
operational threats and errors that have manifested during normal operations. Monitoring of
normal operations can produce data that further serve to identify operational weaknesses
and, in turn, assist the organization in developing system solutions.

As with the investigation of accidents and serious incidents, the investigation of minor
internal occurrences results in a report that is communicated to relevant operational
managers for analysis and the possible development of corrective or preventive action.

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10.4 FLIGHT DATA ANALYSIS (FDA) PROGRAM

Air India Limited has a flight data analysis (FDA) program that is non-punitive and contains
adequate safeguards to protect data sources. The program shall include for aircraft of a
maximum certified takeoff mass in excess of 20,000 Kgs (44093 lbs) a systematic download
and analysis of electronically recorded aircraft flight data.

Flight data analysis is considered a reactive and proactive hazard identification activity in an
SMS. A primary purpose of an FDA program is hazard identification, which is an element of
the Safety Risk Management component of the SMS framework.

The systematic download and analysis of recorded flight data has been used by
international airlines for many years to identify hazards, evaluate the operational
environment, validate operating criteria and establish training effectiveness.

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SAFETY RELATED INVESTIGATIONS
AND REMEDIAL ACTIONS Issue-4 Rev-0 01 JUN 2018

10.5. THE CONCEPT OF ACCIDENT CAUSATION:

Apart from establishing findings and the root causes of accidents/incidents, the investigation
exercises at Air India Limited also uncover hazards/threats. An effective and comprehensive
investigation process is enabled that includes the identification of and discrimination
between an ultimate consequence, an unsafe event and hazards/threats that contribute to
the accident/incident. This includes any systemic, latent or organizational factors within the
entire aviation system framework. As a proactive safety management environment, there is
an important and necessary integration between an accident/incident investigation process
and a hazard reporting/identification process. Investigation reporting forms have clear
provision that hazards/threats uncovered during the investigation process, which would
require separate follow-up action by the organization’s hazard identification and risk
mitigation process are documented. Air India Limited Has an interlinked accident/incident
investigation and hazard identification processes.

The Root causes are identified as per the following model:

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10.5.1 Being an important reactive component of the elements contained in the SMS and
SSP frameworks, accident investigations contribute to the continuous improvement of
the aviation system by providing the root causes of accidents/incidents and lessons
learned from analysis of events. This can support decisions regarding the
development of corrective actions and corresponding allocation of resources and may
identify necessary improvements to the aviation system including SMS, SSP as well as
the State accident investigation process. While it is common for mandatory State-
level investigations to be limited to accidents and serious incidents, a mature safety
management environment may provide for the investigation of lower-consequence
events as well.

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SAFETY RELATED INVESTIGATIONS
AND REMEDIAL ACTIONS Issue-4 Rev-0 01 JUN 2018

10.6. JUST CULTURE - NON PUNITIVE AND DISCIPLINARY ACTION:

Air India Limited has a policy that provides rules and guidelines for administering
disciplinary action to employees, who violate safety rules and procedures or who, by their
record or actions, indicate a disregard for safety. In some of these voluntary programs,
information received by the regulatory authority must be assessed against regulatory
requirements. If a violation of civil aviation code exists, the information is processed
through normal means, which often results in a punitive action against the report
submitter. Only when no violation of aviation code is identified can a report submitter be
assured that the information will be treated in a non-punitive manner. At the root of all of
these issues, and the key to successful error mitigation, is management's commitment to
safety - first and foremost, and the commitment of the individual to error prevention. In
effect, a company's "safety" culture will only be effective if it is just and based on the
fundamental tenets of fairness, respect, and trust.

A Just Culture exists wherein personnel are not punished for actions, omissions or
decisions taken by them which are commensurate with their experience and training, but
where gross negligence, wilful violations and destructive acts exist, they are not tolerated.

While the Flight Safety Department carries out the investigations as per DGCA CAR and
further makes safety recommendations including that of corrective training and/ or
remedial measures; wherever disciplinary action is required, the respective departmental
heads will carry out the enforcement action.

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 CORPORATE SAFETY AI–ORG-SMS-001
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AND REMEDIAL ACTIONS Issue-4 Rev-0 01 JUN 2018

10.7 ROOT CAUSE ANALYSIS AND REMEDIAL ACTION:

Root Cause Analysis is an in-depth process or technique to identify the most basic factor(s)
which cause a variation in the performance (problem) that has lead to the accident/incident.

In Aircraft Accident/ Incident Investigation process and audit analysis , the Root Cause
Analysis (RCA) forms an important constituent for prevention of similar occurrences in future.

Definition: Root Cause: The original event(s), action(s), and / or condition (s) generating
(directly or in cascade) an actual or potential undesirable condition, situation, non conformity
or failure.

Root Cause Analysis:

RCA is a tool designed to help identify not only what and how an event occurred, but
also –

1. Understand why the safety event happened.

2. Establish precursors to danger, and
3. Establish underlying causes for safety issues.

10.7.1 Why do you perform RCA?

RCA is typically used as a reactive method of identifying event(s) causes, revealing problems
and solving them. Analysis is done after an event has occurred. Insights in RCA make it
potentially useful as a pre-emptive method. In that event, RCA can be used to forecast or
predict probable events even before they occur.

RCA can be used to guide and support the investigating teams to –

a. Improve the quality of their investigations.
b. Help them analyze the accident/incident with accuracy, relevancy, and completeness to
decide the corrective and preventive action.

Correctly identifying the root cause will prevent re-occurrence of the event.

RCA does not have to be a lengthy or involved process, but it should be a systematic and
documented look into the cause and effect of the occurrence.

10.7.2 Regulatory and FSM References:

1. ICAO Doc 9859, SMM Third edition 1983, Safety Culture and Investigation of Accidents and
Incidents - Para 2.6.1 and 2.10.6 respectively.

2. FSM, Chapter 4, Para 4.2.

10.7.3 How to Determine a Root Cause:

To determine the exact root, which is an essential component of SMS, the responsible
Investigator Investigating Team will have to go in depth for basic factor which lead to reach
the organization to this risk level.

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The six stage cycle needs to be followed to determine the problem behind the Aircraft Occurrence /
Incident/ Accident.

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10.7.5 Tools for Root Cause Identification:

An effective root cause analysis is required to decide corrective and preventive action(s) to
enable mitigation of re-occurrence of the Incident / Accident. Root cause analysis is also
required while submitting corrective and preventive actions by the auditee for closure of
findings raised during internal and external audits.

10.7.5.1 Five Whys:

Simply keep asking the question ‘Why’ until you reach the underlying problem.
5 Whys analysis is one of the most common ways to perform RCA. 5 Whys essentially
involves starting at a hazardous condition and asking “Why did this happen?”
Each time the “Why” is asked, the answer must be written down. For each answer the
question should be repeated. This question “Why” is repeated generally 5 times, until the
Investigating Team arrives at the actual root cause(s).

The Root cause is established here.

Simply keep asking the question ‘Why’ until you reach the underlying problem.

example:

Air Loss of Fuel Fuel Wing Debris

Crash Engine Leak Cell Damage on
power on a/c Damage Runway

How to Know the Root Cause is achieved:

With root causes, you are basically repeating the following basic steps:
1. Analyze the circumstances of the accident/incident; and
2. Ask, “Why did this happen?”
This process will be repeated over and over until the root cause is identified. You know when a root
cause has been identified when your answer to “why” is:
“Simply because it is”.
What this means is that root causes will have no specific reason for being present that are within
anyone’s control. Or, there will be no discernible explanation for “why”.

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10.7.5.2 Cause and Effect Diagram / Fishbone Diagram:

Fishbone diagrams, also known as cause and effect diagrams, are another popular root cause
analysis technique. A fishbone diagram derives its name from its fishlike appearance, with a head
several fins. Each “fin” or “branch” of a fishbone diagram describes a different category of the
situation, such as the categories “Human” or “Machine.” The head of the fishbone is describes the
hazard/Top Event.

 This model is a visual tool that helps to identify, sort and display possible causes of a specific
problem.
 It demonstrates the relationship between a given outcome and all the factors that influence
the outcome.
 Categories/headings are not fixed for this technique and can be selected to suit the
investigation although it is quite common to find:
 Manpower, Methods, Materials, Management or Measurement and Machinery (known as 5Ms),
and
 System, Policies, Programme and Processes (known as 1S and 4Ps).

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10.7.5.3 Fault Tree Analysis (FTA)

 It provides a standardized method to evaluate and control hazards.

 It is used to solve a wide variety of problems such as safety, reliability and management
issues.

Top Undesired Event

Logic Gate

Basic Events

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 AIR INDIA LIMITED
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL

SAFETY TRAINING AND

COMMUNICATION
CHAPTER – 11
 CORPORATE SAFETY AI–ORG-SMS-001
MANAGEMENT SYSTEM MANUAL CHAPTER - 11
SAFETY TRAINING AND
COMMUNICATION Issue-4 Rev-0 01 JUN 2018

11.1 GENERAL

Corporate SMS of Air India Limited develops and maintains formal safety training and
safety communication activities to create an environment where the safety objectives
of the organization can be achieved.

At the AOC and SBU level, the respective Chiefs of Flight Safety and Safety Officers
ensure the same, with the support of Corporate SMS Office.

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11.2 SAFETY TRAINING

All AOCs and SBUs shall, as part of their safety promotion activities, develop and
maintain a safety training programme that ensures that personnel are trained and
competent to perform their SMS duties.

i. Corporate SMS has a controlled documentation with regard to training syllabus,

eligibility and requirements.
ii. There is a validation process that measures the effectiveness of training.
iii. The training includes initial, recurrent and update training, where applicable.
iv. The organisation’s SMS training is a part of the organisation’s overall training
programme
v. SMS awareness is incorporated into the employment or indoctrination
programme
vi. The training includes safety communication processes /channels within the
organisation.

The scope of the safety training shall be appropriate to the individual’s involvement in
the SMS.

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11.3 SAFETY COMMUNICATION

All AOCs and SBUs shall, as part of their safety promotion activities, develop and
maintain formal means for safety communication, to:

i. ensure that all staff are fully aware of the SMS;

ii. convey safety-critical information;
iii. explain why particular safety actions are taken;
iv. explain why safety procedures are introduced or changed; and
v. convey generic safety information.

Formal means of safety communication shall include inter alia:

i. safety policies and procedures;

ii. newsletters;
iii. bulletins; and
iv. websites.

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11.4 EFFECTIVE COMMUNICATION

The Corporate SMS has a communication system that enables an exchange of

information relevant to the conduct of operations throughout the management system
and in all areas where operations are conducted.

An effective communication system ensures the exchange of operational information

throughout all areas of the organization, and includes senior managers, operational
managers and front line personnel. To be totally effective, the communication system
would also include external organizations that conduct outsourced operational
functions.

To be effective, methods are as uncomplicated and easy to use as is possible, and

facilitate the reporting of operational deficiencies, hazards or concerns by operational
personnel.

Corporate SMS & Flight Safety Website also communicates relevant safety information.

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11.5 SMS TRAINING PLAN

11.5.1 The Corporate SMS has a program that ensures personnel throughout the organization
are trained and competent to perform SMS duties. The scope of such training shall be
appropriate to each individual’s involvement in the SMS. SMS training is an element of
the Safety Promotion component of the SMS framework. Within an SMS management
and non-management personnel are expected to complete SMS training.

Everyone in the Organisation has responsibility for aviation safety. It is important that
all staff members are competent to carry out their roles and responsibilities. This is
achieved through training and ongoing assessment of individuals. This training will
include the Air India Corporate SMS, safety policy, reporting procedures, safety
responsibilities and how individuals can contribute at all levels.

11.5.2 Safety training will include ab-initio, periodic / refresher training. It shall be ensured
that SMS should be included in the refresher training for all operational staff. The
periodicity of the refresher training shall depend on the respective departmental job
functions. The Non operational staff shall undergo refresher training every three years.
To achieve this for all staff members, a record of their training will be held, staff will be
actively encouraged to identify and report hazards. Training will make aware the safety
hazards connected with their duties and lesson learned will be disseminated effectively.

11.5.3 The plan shall include training to personnel of external service providers, to ensure that
personnel of external services providers that perform operational functions for Air India
are trained and competent to perform SMS duties. The scope of such training shall be
appropriate to the individual’s involvement in in SMS.

11.5.4 The Department shall develop and maintain a safety training programme that ensures
that personnel are trained and competent to perform the SMS duties. Training
requirements and activities should be documented for each area of activity within the
Departments. A training file should be developed for each employee, to assist in
identifying and tracking employee training requirements and verifying that personnel
have received the planned training.

11.5.5 The training programme will specify safety training responsibilities, including contents,
frequency, validation and safety training records management. The contents should
include the definition of hazards, consequences and risks, the safety risk management
process, including roles and responsibilities and, quite fundamentally, safety reporting
and the organization’s safety reporting system. A training curriculum typically includes
on overview of the elements of SMS and modules that address :

i. Hazard Reporting;
ii. Event investigation and analysis techniques;
iii. Hazard Identification;
iv. Risk Assessment and mitigation;
v. Audit Principles and methodology;
vi. Communication Techniques;
vii. SMS implementation, analysis and continual improvement;
viii. Emergency response preparedness.

Safety training for Managers and Supervisors will address safety responsibilities,
including promoting the SMS and engaging operational personnel in hazard reporting.

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In addition to the training objectives established for operational personnel, training

objectives for Managers and Supervisors should include a detailed knowledge of the
safety process, hazard identification and safety risk assessment and mitigation, change
management and safety data analysis.

An SMS specifies initial and recurrent safety training standards for personnel that
perform operational functions, to include managers and supervisors, senior managers
and the Accountable Executive. The training duration for Pilots, Cabin Crew and
Engineers is conducted as per the Training Programme specified in their respective
Manuals.

11.5.6 The content of such training is appropriate to the individual's responsibilities and
involvement in the SMS, and typically includes or addresses some or all of the following
subject areas, as appropriate for the functions performed by the personnel being
trained:

 Organisational safety policies, goals and objectives;

 Organisational safety roles and responsibilities related to safety;
 Organisational SMS Processes and procedures;
 Basic safety risk management principles;
 Safety reporting systems;
 Safety management support (including evaluation and audit programmes)
 Lines of communication for dissemination of safety information;
 A validation process that measures the effectiveness of training;
 Initial indoctrination and recurrent training requirements.
 Human Factors.

The duration of SMS Training will be as follows :-

a) Accountable Executive - 4 hours

b) Senior Management i.e. Departmental Heads - 1 day
c) Head of Corporate SMS - 5 days
d) Head of Corporate QMS - 3 days
e) Chief and Dy. Chief of Flight Safety - 3 days
f) SMS Nodal Officers of Departments - 2 days
(If carrying out Risk Assessment, then atleast 3 days)
g) Airport & Station Managers - 2 days
h) Flight Safety and QMS Auditors - 2 days
i) Line Pilots / Cabin Crew / Flight Dispatchers / Ground
Handling / Cargo / Security / Maintenance/Other Staff - 3 hours
j) SMS Trainers - 5 days

The training will include the organization’s safety policy, safety roles and responsibilities,
SMS principles related to safety risk management and safety assurance, as well as the
use and benefits of the organization’s safety reporting system(s).

11.5.7 The safety training programme includes a session designed specifically for the
Accountable Executive. This training session should be at a high level providing the
Accountable Executive with an understanding of the SMS and its relationship to the
organization’s overall business strategy.

The Accountable Executive shall receive safety awareness training regarding:

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i. safety policy and objectives;

ii. SMS roles and responsibilities;
iii. SMS standards; and
iv. safety assurance.

This training is carried out by the Corporate SMS for a duration of 4 hours.

11.5.8 Safety training for senior managers should include content related to compliance with
national and organizational safety requirements, allocation of resources and active
promotion of the SMS including effective inter-departmental safety communication. In
addition, safety training for senior managers should include material on establishing
safety performance targets and alert levels. Training for SMS Trainers and Senior
Management - EDs / Postholders / equivalent, etc. will be carried out by Corporate SMS.

11.5.9 Air India Limited has a programme that ensures personnel of external service providers
are trained to understand SMS responsibilities and perform associated duties if Air India
outsources operational functions to external service providers.

The scope of such training shall be appropriate to individual involvement in the Air
India’s SMS. Initial and Recurrent training standards have been defined to ensure
training of service provider personnel is consistent with and meets the requirements of
its own SMS.

Recurrent training for personnel of service providers, although recommended has been
specified at the option of the Air India SMS. Training in accordance with this provision
may be conducted by the Air India, or by the service provider or other organization as
long as the content and delivery of such training satisfies the SMS requirements of Air
India.

Air India considers any of the following options as means for ensuring personnel of
service providers complete training that satisfies the requirements of its own SMS:

a. If a service provider has an SMS, accept the service provider’s SMS training;

b. If a service provider has an SMS, specify training in addition to that of the service
provider,(i.e gap training) as applicable to ensure its own SMS requirement are
satisfied;

c. Have applicable personnel of service providers complete the operator’s own SMS
training;

d. Deliver targeted or specific SMS training to personnel of service providers (e.g

hazard recognition, use of operational safety reporting system).

The training syllabus and content shall be consistent with the contents mentioned in
para 11.5.6 above.

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11.6 SAFETY TRAINING FOR OPERATIONAL PERSONNEL

In addition to the above, Air India Ltd. personnel engaged directly in flight operations will
require more specific safety training with respect to:
a. Procedures for reporting accidents and incidents.
b. Unique hazards facing operational personnel.
c. Procedures for hazard reporting.
d. Specific safety initiatives, such as safety committee, seasonal safety hazards and
procedures (winter/low visibility operations, etc.) and emergency procedures.

No For Whom Core skills & knowledge Training

experience
required
1 Accountable General awareness of SMS, including SMS Formal SMS Course
Executive/ Roles and responsibilities, safety policy &
CMD objectives, safety risk management and Min 4 Hrs
safety assurance.
Encouraging Safety Reporting.
Knowledge of DGCA SMS regulations
2 
Head of Corporate All elements of SMS.
SMS  Development, implementation and Formal SMS
administration of SMS Course
Understanding of SMS requirements and
all key components/ elements/policies Min 5 Days
Safety Policy and Objectives, Safety
Reporting System, Safety Risk
Management, Safety Assurance and Safety
Promotion.
Safety Data Analysis.
SMS documentation and records
Conducting internal SMS audits
Safety data analysis, safety assurance and
promotion
3 
Head of Corporate Development, implementation and
QMS administration of SMS Formal SMS
Understanding of SMS requirements and Course
all key components/ elements/policies
SMS documentation and records Min 3 Days
 Conducting internal SMS audits
 Safety data analysis,
 Safety assurance.
4 Senior Management
 Implementation and Formal SMS
i.e. Departmental administration of SMS Course
Heads Understanding of SMS requirements and
all key components/ elements/policies Min 1 Days
SMS documentation and records
Safety Reporting System,
Safety Risk Management,
Hazard Identification and Safety Risk
assessment.
Safety Promotion.

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No For Whom Core skills & knowledge Training

experience
required
5 
Chief and Dy.Chief All elements of SMS. Formal SMS
of Flight Safety  Development, implementation and Course
administration of SMS
Understanding of SMS requirements and Min 3 Days
all key components/ elements/policies
Safety Policy and Objectives, Safety
Reporting System, Safety Risk
Management, Safety Assurance and Safety
Promotion.
Safety Data Analysis.
SMS documentation and records
Conducting internal SMS audits
 Safety data analysis, safety assurance and
promotion
6 SMS Nodal Officers
 Development, implementation and
of Departments administration of SMS Formal SMS
Understanding of SMS requirements and Course
all key components/ elements/policies
SMS documentation and records. Appropriate risk
Safety Reporting System, management training
Safety Risk Management,
Hazard Identification and Safety Risk Min 3 Days
assessment.
Safety Promotion.
7 Station Managers / Safety Policy, safety roles and SMS familiarization
Airport Managers responsibilities, knowledge of SMS process,
including hazard identification. Min 2 days
Safety Reporting System,
Hazard Identification ,
Safety Promotion.
8 Flight Safety and Familiar with all elements of SMS. Formal SMS
QMS Auditors Conducting internal SMS audits Course
Min 3 Days
SMS Auditing
Min 2 Days

9 Operational Safety Policy, safety roles and SMS training

personnel: responsibilities, knowledge of SMS process, during
Line Pilots / Cabin Safety Reporting, Induction
Crew / Flight including hazard identification.
Dispatchers / Min 3 hrs
Ground Handling /
Cargo / Security /
Maintenance/Other
Staff

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No For Whom Core skills & knowledge Training

experience
required
10 SMS Trainers Familiar with all elements of SMS.
Safety Policy, safety roles and Formal SMS
responsibilities, knowledge of SMS process, Course
including hazard identification and risk Min 5 Days
management, management of change, Train The Trainers
safety data analysis, safety assurance course.
and promotion
Qualitative risk assessment, analysis,
mitigation, control and review.

11.6.1 REFRESHER TRAINING:

Refresher training shall be conducted by trained SMS instructor. The refresher training shall
be scheduled not later than three years for non operational areas it will be carried out along
with regular refresher courses for all operational areas as per their respective DGCA approved
training syllabus .
The duration of the refresher shall be for minimum of 2 hours. The refresher shall revise the
principles of SMS and specifically cover the hazard reports, incidents and occurrences related
to specific department and encourage the personnel for reporting.

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 AIR INDIA LIMITED
CORPORATE SAFETY
MANAGEMENT SYSTEM MANUAL

CONTINUOUS IMPROVEMENT AND

SMS AUDIT
CHAPTER – 12
 11DEC2020
22 11DEC 2020

Safety and Quality

 CORPORATE SAFETY AI–ORG-SMS-001
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CHAPTER - 12
CONTINUOUS IMPROVEMENT AND
SMS AUDIT Issue-4 Rev-0 01 JUN 2018

safety or quality assurance department or another sub-organization as directed by

senior management). The internal evaluation function also requires auditing and
evaluation of safety management functions, policymaking, safety risk management,
safety assurance and safety promotion. These audits provide the management
officials designated responsibility for the SMS to inventory the processes of the SMS
itself.

12.1.5 QMS uses the process of auditing for monitoring of external organisations. These
typically include Quality Audits, Product Audits, Supplier Audits, Random Samplings,
and other monitoring methods.

a) To ensure that the products acquired from external sources conform to the
required quality standards, an audit may be carried out by following methods
i) Onsite audits;
ii) Postal audits/mail audit (if the applicable products have the regulatory
approvals).

b) To ensure that the electronic data acquired from suppliers conform to level of
integrity commensurate with the intended application, the audit may be carried
out by:

i) Onsite audits of the Electronic Nav Data supplier;

ii) Postal/Mail audits (if the supplier is approved by the applicable
regulatory authority).
iii) Audit of process and procedures followed by Operations / Despatch /
Engineering to ensure that the Electronic Nav Database is compatible
with the equipment in which it is installed.
iv) Audit of process and procedures for distribution of the database to
ensure that current data is inserted without any alterations.
v) Audit the process of internal checks carried out by Operations/
Despatch/ Engineering to ensure iii) & iv) above.

Air India Air India Limited includes auditing as a process for the monitoring of
external service providers, which includes Operations, Flight Despatch/Operational
Control, Flight Training and TRTO, Maintenance, Ground Handling, Cargo, Cabin and
Catering. Other methods might include systematic review and risk assessment of
reported hazards and/or occurrences, monitoring of performance output (KPIs),
reporting and governance processes; monitoring and analysis of targeted risk areas,
as well as the establishment of an effective two-way communication link with the
service provider.

12.1.6 Air India Limited has processes to ensure the management of safety risks in
outsourced operational functions conducted by external service providers, including
all 3 AOCs (Air India, Air India Express and Alliance Air) and subsidiaries (AIATSL &
AIESL):-

(i) If Air India Limited outsources such functions with external service
providers that do not have a valid SMS, QMS shall have a process to:

(a) Identify and define specific SMS elements that must be implemented
by the provider to ensure the management of safety in operations
conducted for Air India Limited;

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(b) Ensure the provider's personnel are trained to perform duties as

appropriate to each individual's involvement in the defined SMS
elements as specified in item a).

(ii) If Air India Air India Limited outsources such functions with external
service providers that have a valid SMS, QMS shall have coordination and
monitoring processes that ensure the management of safety in operations
conducted for Air India Limited.

12.1.7 Internal audits are an important tool for managers to use to obtain information
with which to make decisions and to keep operational activities on track. The
primary responsibility for safety management rests with those who “own” the
organization’s technical activities supporting the delivery of services. It is here
where hazards are most directly encountered, where deficiencies in activities
contribute to safety risks, and where direct supervisory control and resource
allocation can mitigate the safety risks to ALARP.

While internal audits are often thought of as a test or “grading” of an organization’s

activities, they are an essential tool for safety assurance, to help managers in
charge of activities supporting the delivery of services to control that, once safety
risk controls have been implemented, they continue to perform and are effective in
maintaining continuing operational safety.

External audits of the SMS may be conducted by DGCA, including Foreign

Assessments such as SAFA/FAA, code-share partners, customer organizations, or
other third parties selected by the organization. These audits not only provide a
strong interface with the oversight system but also a secondary assurance system.
Refer Appendix ‘D’ of this Manual on SAFA and FAA Guidance Manual
available on the DMS Website.

Continuous improvement of the SMS thus aims at determining the immediate

causes of below standard performance and their implications in the operation of the
SMS, and rectifying situations involving below standard performance identified
through safety assurance activities. Continuous improvement is achieved through
internal evaluations, internal and external audits and applies to:

i. Proactive evaluation of facilities, equipment, documentation and procedures,

for example, through internal evaluations;
(form of evaluation / audit); and
ii. Reactive evaluations in order to verify the effectiveness of the systm for control
and mitigation of safety risks, for example, through internal and external
audits.

As a conclusion, continuous improvement can occur only when the organization

displays constant vigilance regarding the effectiveness of its technical operations and
its corrective actions. Indeed, without ongoing monitoring of safety controls and
mitigation actions, there is no way of telling whether the safety management process
is achieving its objectives. Similarly, there is no way of measuring if an SMS is fulfilling
its purpose with efficiency.

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12.2 QUALITY POLICY

The Corporate Quality Policy as approved by the Accountable Executive who is the
Chairman and Managing Director of Air India Limited is reproduced below :-

“AIR INDIA LIMITED covering all AOCs, subsidiaries and Strategic Business Units are
committed to providing our customers with the highest level of product and service
quality derived from a Quality and Safety Management system whose foundation lies
in a culture of safety, quality, customer satisfaction and continuous improvement.

AIR INDIA LIMITED will ensure compliance with relevant statutory quality, safety and
environmental requirements which will be reviewed regularly. We will actively pursue
improving quality, through programmes that enable each employee to do their job
“Right the First Time” and “Every Time” thus fulfilling our customers expectations
without compromising the safety and quality of our operations.

Quality Performance is a commitment to excellence by each employee. It is achieved

by teamwork and a process of continuous improvement.

The objectives of the Quality Management System are:

12.2.1 To maintain an effective Quality Management System complying with international

standards and regulatory requirements.

12.2.2 To ensure compliance with relevant statutory, quality and safety requirements.

12.2.3 Providing a safe and secure operation as the first and most fundamental obligation to
our customers and employees, as well as to the communities we serve.

12.2.4 To achieve and maintain a level of quality and safety which enhances the Company's
reputation with customers. Constantly meeting customer expectations is both our
collective duty and foundation of our success.

12.2.5 To endeavour, at all times, to maximize customer satisfaction.

12.2.6 To implement innovative methods of management taking advantage of best practices in

Air Transport.

12.2.7 To ensure the existence of necessary facilities, workplaces, equipment and supporting
services as well as work environment to satisfy operational safety, quality, security and
continual improvement.

12.2.8 To commit to environmental protection and sustainable development, by use of modern

technology and optimization of our operation, by striving to reduce the negative impacts
of air transport on the environment and the society.

Every employee has an inherent responsibility for an ongoing commitment to quality

and to the promotion of a quality culture.”

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12.3 QUALITY MANAGEMENT SYSTEM

Quality Management System (QMS) ensures continued suitability, adequacy and

effectiveness of the entire organisation. It ensures continual quality, safety and security
improvements in all areas of operation including the Safety Management System for all
AOCs, SBUs and Subsidiaries. It is headed by the Head of QMS. The QMS covers the
Safety, Quality & Security Assurance functions across the Organisation. The Manager of
the Quality Assurance Program (Head of QMS) is ‘operationally independent’ in a manner
that ensures objectivity is not subject to bias due to conflicting responsibilities and has
appropriate qualifications that include :

i. Formal training or certification as a Quality Auditor

ii. Relevant operational and auditing experience
iii. Formal training in Risk Management

In Air India Limited, Head of QMS with appropriate qualifications, authority and
independence is responsible for:

i. The performance of the quality assurance program;

ii. Ensuring communication and coordination with operational managers in the
management of operational risk.

12.3.1 The CMD, Accountable Executive has nominated the Head of Corporate QMS,
independent from operational and line management activities, to be responsible for the
Quality Management System and the internal evaluation programme throughout the
Organisation, as the Head of the Quality Management Systems(QMS), who shall report
directly to the CMD.

With reference to DGCA CAR on Safety Management System, the QMS covers the
Quality & Safety Assurance Programme, the conduct of Audits of SMS, the coordination
of Emergency Response Planning, conduct of Safety Audits and the continuous
improvement of Safety System.

12.3.2 The Head of Corporate QMS has direct access to the Accountable Manager, his
independence is totally ensured and he has access to all areas of the Organisation. The
Head of QMS should not be one of the nominated post holders and should be a pilot
(may be a permanently medically grounded pilot) / operational pilot, which satisfies
DGCA and IOSA requirements. The Head of QMS should have operational and quality
experience and should have served Air India Air India Limited for a minimum of ten
years. The experience in quality must include experience with all functional areas for a
minimum of 4 IOSA audits and adequate training as a Quality Auditor, through an
Accredited Organisation / QMS Department and formal training and certification in
Safety Management System.

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12.3.3 The Head of Corporate Quality Management Systems shall :

i) be responsible to the Accountable Manager for the implementation, control

and management of the quality management system within the Company i.e.
Definition, implementation, compliance and monitoring of the appropriate
procedures to comply with the airline quality policy;
ii) ensure organisation wide improvement in quality and safety on a continual
basis;
iii) ensure the Quality, Safety & Security Assurance Programme runs effectively
and the programme contains procedures designed to verify that all operations
are being conducted in accordance with all applicable requirements, standards
and procedures;
iv) ensure the conduct of organisation-wide internal audits encompassing all
safety and quality critical operations and activities at regular planned intervals
to ensure conformity with regulatory and management system requirements;
v) establish a planned and documented audit programme, taking into
consideration the status and importance of the processes and functions to be
audited including the results of previous audits. The audit programme shall
include a specified time period for completion of the audit plan;
vi) define the audit process such that its application is consistent, has integrity
and operates within an ethical framework;
vii) ensure that sufficient auditors are made available to enable completion of the
audit programme. The selection of auditors and conduct of auditors shall
ensure competence, objectivity, integrity and impartiality of the audit process.
Auditors shall be independent and shall not audit their own work; and
viii) ensure the requirements for corrective and preventative actions are met.
ix) monitor compliance with and adequacy of procedures required to ensure safe
operational practices and airworthy aeroplanes;
x) ensure a regular feedback system to the Accountable Manager to ensure
corrective action as necessary;
xi) verify, by monitoring activity in the fields of flight operations, maintenance,
crew training and ground operations that the standard required by the
authority and any additional requirements defined by AIR INDIA AIR INDIA
LIMITED are being carried out under the supervision of the relevant
nominated post holder;
xii) have a process to review the management system at intervals not exceeding
one year to ensure its continuing suitability, adequacy and effectiveness;
xiii) monitor compliance of all regulatory requirements and organisational
requirements.

12.3.3.1 Audit Reports:

All the AOCs and Subsidiaries must ensure that the Audit Reports (Internal & External)
along with the corrective and preventive actions must be submitted on a regular basis to
Corporate QMS and the Corporate SMS Office as a part of the Safety Data Collection and
identification of Hazards. This would facilitate continuous improvement.

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12.3.4 Organization Chart – Corporate QMS

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Such review permits senior management to consider significant issues of non-

compliance in areas of the organization that impact operational safety and security,
and to;

i. Continually monitor and assess operational safety and security outcomes;

ii. Ensure appropriate corrective or preventive actions that address the relevant
compliance
iii. issues have been implemented and are being monitored for effectiveness;
iv. Ensure continual improvement of operational safety and security performance.

12.4.3 Air India Limited has a means for disseminating information from the quality & safety
assurance program to management and non-management operational personnel as
appropriate to ensure an organizational awareness of compliance with applicable
regulatory and other requirements.

Promulgation of safety information is an element of the Safety Promotion component

of the SMS framework.

The quality & safety assurance program includes a process for promulgating and
disseminating information for the purpose of maintaining an ongoing awareness of
compliance issues that might impact operational safety or security. Such dissemination
of information includes an up-to-date status of operational performance against stated
performance measures. The process ensures a method of dissemination which
includes a magazine, newsletter or bulletin issued periodically.

Electronic media in various forms are also used in the timely dissemination of
information.

12.4.4 For Safety Audits, the following manuals must be referred:

i) Refer the Flight Safety Manuals of all AOCs for details

ii) Refer Quality Audit Manual covering Quality and Safety Audits for details. The QMS
carries out audits across the Organisation and complies with the DGCA CARs on
SMS, CAR on Accident Prevention and Flight Safety as well as other CARs on the
subject pertaining to Operations, Engineering and other operational areas.

12.4.5 QMS prepares the Audit Plan covering all areas of Quality, Safety & Security as a
Corporate Audit Plan.

For all the AOC holders, the respective Chief of Flight Safety prepare their respective
Safety Inspection / Audit Plan, and submit it to Head-Corporate QMS by 15th
December latest every year for the subsequent year. QMS ensures that the proposed
Audit Plan for each AOC pertaining to Flight Safety Department are approved by the
Accountable Executive. The Audit Plan is made to ensure that every functional
operational area is audited at least once a year by QMS. Every station is to be audited
at least once in two / three years as applicable depending on safety risk assessment.

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SMS RECORDS MANAGEMENT

CHAPTER – 13
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13.1 SMS Records Management:

Air India Limited has a SMS Records Management System that shall ensure that the SMS
records are appropriately generated, recorded, filed and archived for retention of all
records that are generated in conjunction with the implementation and operation of the
SMS.

a) The SMS Records shall include hazard reports, risk assessment reports, safety action
group/safety meeting notes, safety performance indicator charts; SMS audit reports and
SMS training records.

b) The Records shall be traceable for all elements of the SMS and be accessible for routine
administration of the SMS as well as internal and external audits plan.

13.1.1. All SMS records are retained for at least 5 years, and archived as soft copy in DMS.

13.1.2 SMS Documentation shall include the following:

i. Corporate SMS Manual.

ii. SMS hazards Log and record of actual reports;
iii. SPI / SPT Annual report
iv. Record of completed or in-progress safety assessments;
v. SMS internal review or audit records;
vi. Change Management Records,
vii. Safety promotion records;
viii. Personnel SMS/safety training records;
ix. Safety Analysis Group (SAG) meeting minutes;
x. Safety Review Board meeting minutes,
xi. Safety Analysis Meeting minutes,
xii. Safety Review Meeting Minutes,
xiii. Risk Mitigation exercises record,
xiv. SMS implementation plan and Gap Analysis (during implementation process).
xv. Safety Promotion Records.

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13.2 PROTECTION OF SAFETY INFORMATION:

As per CAR Section1,Series C Part 1, DGCA SDCPS is required to conform to safety information,
similarly the Airline SDCPS is required to conform to the safety information and protection
thereof.
All data pertaining to Records / Evidences collected to support Aircraft Accident and Incident
investigations (AAIB), Reports (Mandatory Reports, Confidential Reports, Voluntary reports
etc.), Data collected from DGCA Oversight, Self-disclosure reporting systems, including
automatic data capture systems are appropriately protected.
In order to appropriately safeguard the confidentiality of data, the computers that are used to
generate records shall be password protected. Additionally all personnel are made to sign a
Non Disclosure Agreement to ensure that information is protected and it is the responsibility of
each personnel to protect and maintain confidentiality.
The above mentioned data shall constitute and shall be considered as Safety Information and
shall qualify for protection from inappropriate use according to specified conditions that will
include, but not necessarily be limited to, collection of information for explicit safety purposes
and disclosure of such information would inhibit its continued availability.
Safety information shall not be used in a way different from the purposes for which it was
collected.
The SMS Data group shall apply all possible protection regarding the disclosure of the
information, unless:
a) There is a consent of the originator of the information for disclosure; or
b) There is a reason that release of safety information is in accordance with the principles of
exception

Principles of Exception

Exceptions to the protection of safety information shall only be granted when:

a) DGCA / CoFS / The Head of Corporate SMS / QMS considers that circumstances reasonably
indicate that the occurrence may have been caused by conduct with intent to cause
damage or conduct with knowledge that damage would probably result, equivalent to
reckless conduct, gross negligence or wilful misconduct.

b) Review by DGCA / CoFS / The Head of Corporate SMS / QMS determines that the release
of the safety information is necessary for the proper administration of justice, and that its
release outweighs the adverse domestic and international impact and such a release may
have on the future availability of safety information.

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Public Disclosure:
Subject to the principles of protection and exception outlined above, any person seeking
disclosure of safety information shall justify its release. Formal criteria for disclosure of safety
information shall be established to include, but not necessarily be limited to, the following:

i. Disclosure of the safety information is necessary to correct conditions that compromise

safety and/or to change policies and regulations.
ii. Disclosure of the safety information does not inhibit its future availability in order to
improve safety.
iii. Disclosure of relevant personal information included in the safety information complies
with applicable privacy laws.
iv. Disclosure of the safety information is made in a de-identified, summarized or aggregate
form.

It shall be the responsibility of the all the Data Management Groups and relevant groups to apply
all possible protection regarding the disclosure of the information, unless:

i. There is a consent of the originator of the information for disclosure; or

ii. There is a reason that release of safety information is in accordance with the

Principles of exception.
i. PIB Data Group,
ii. SMS Data Group,
iii. Data Management Group and
iv. DMS and FSDS Group.

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