global safety management manual (gsmm)

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Global Safety Management Manual (GSMM) REGULATORY COMPLIANCE

Approved by: Stefan Suri, Global SMS Date: September 6th, 2019 Signature:

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Uncontrolled when printed. Verify revision before use. of 42

Preamble This manual is compiled in accordance with the requirements of various National Aviation Authorities with respect to Safety Management Systems whilst also using ICAO 9859 (as revised) as a guide. Other regulatory references used are listed in section 1.2. The purpose of this manual is to define and provide clear and concise instructions for the continued safe performance of maintenance practices. This manual is managed and amended by the Global Safety Manager and is laid out in the following manner: Part 0: Control Pages Part 1: Safety Policy and Objectives Part 2: Safety Reporting System Part 3: Hazard Identification & Risk Assessment Part 4: Safety Investigation Part 5: Safety Assurance Part 6: Emergency Response Plan Safety management procedures and forms (SMP, SMF) are available on the corporate portal. The hierarchy is typical of most quality management systems throughout use at Panasonic Avionics Corporation (PAC):

Regulations

Manuals

Procedures

Documentation & Records

Forms

This manual is structured to use Corporate and Regional Manuals, Procedures, and Forms as much as possible to avoid duplication. Regional forms and procedures will/are being revised to conform to the PAC Technical Services SMS. PAC has National Aviation Authority approved facilities in the Americas, Europe, Middle East, Asia, Japan, New Zealand and Australia.

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Distribution This manual is controlled and distributed by the PAC Global SMS Manager and available on the internal SharePoint site & iWeb Intranet:

Manual ownership The GSMM, its revisions and amendments are published and issued by the Global SMS Manager or designee. The Global SMS Manager is responsible for its contents and keeping instructions and information current. The Global SMS Manager, or designee, shall submit proposed revisions to the National Aviation Authority for review and acceptance, as required, prior to publishing a revision. In order to maintain this document as a Global Safety Management Manual it may be necessary to define any specific requirements or procedures required to comply with a local NAA recommendation in a Supplement or other document as agreed with the NAA. The terms in the Supplement or other document agreed with the NAA will have precedence over the Global Safety Management Manual. Where changes in the Global Safety Management Manual require changes to the Supplement or other document agreed with the NAA, the proposed revisions to the Supplement or other document agreed with the NAA shall be submitted to the National Aviation Authority for review and acceptance, as required, prior to publishing a revision. Changes to the Supplement or other document agreed with the NAA due to local needs will be reviewed by the Global SMS Manager to ascertain whether those changes will be incorporated into the Global SMS manual. This manual must not be reproduced in whole or in part or otherwise disclosed to any third parties without prior written consent from Panasonic. Copies of this manual may be made available to certain contractors or industry partners with Non-Disclosure Agreements, but the ownership of those copies remains with Panasonic.

http://spfwss3/sites/QMS_Repair_Maintenance/SMS/default.aspx

http://spfwss3/sites/QMS_Repair_Maintenance/SMS/default.aspx

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Management of change requests including manual revisions The purpose of this procedure is to describe the management of significant changes to environments, documents, processes and templates.

Whether change is to be brought about through new projects, or through modifications to operating procedures, it will involve risks. There is a very strong link between change management and risk management—the two processes support each other and should be used together. The steps in the change process are: 1: Communicate and consult. 2: Develop the case. 3: Conduct risk assessment and planning. 4: Prepare the project plan. 5: Implement the change. 6: Ongoing monitoring and review. Throughout all steps in the process, there must be ongoing communication and consultation with all those involved. You must identify those who will be affected by the change, and work with them on each step of the process.

A request for revision or change may be initiated with a Change Request Form SMF-002 in accordance with the Change Management Procedure SMP-002. The originator will complete the SMS Change Request Form detailing the justification for the amendment along with any supporting documentation and send it to the Global SMS Manager. Upon receipt, the Global SMS Manager will allocate an amendment request number from the Change Management Worksheet SMF-002-01. The Global SMS Manager will review the request and coordinate all SMS changes with Regional Regulatory Compliance Managers, PTS Management and the Change Review Board as defined in SMP-002. A Regulatory Compliance Notice (RCN) will be issued for notification of amendments of the GSMM, forms and associated procedures. The Global SMS Manager will transmit the RCN to all respective departments and personnel.

Additional note This GSMM is applicable to all of Panasonic Technical Services (PTS) Line Maintenance & Repair facilities regardless of whether the station/facility holds CASA, CAAS, EASA, FAA Part-145 approval or other NAA approval or no approval at all.

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Definitions

Term Definition Accepted Industry Any well-defined and established standard practice adopted by an industrial/occupational sector.

ALARP

This term refers to reducing risk to a level that is "As Low As Reasonably Practical". In practice, this means that the business must show through reasoned and supported arguments that there are no other practicable options that could be reasonably adopted to reduce the risk further. Note: All efforts should be made to reduce risks to the lowest level possible until a point is reached at which the cost of introducing further safety measures significantly outweighs the safety benefit.

Cause Something that gives rise to or creates a hazard. Consequence Outcome of an event affecting objectives; An event can lead to a range of hazards. Control Measure that is modifying risk; i.e.: include any process, policy, device, practice or other action. Control Effectiveness A relative measure of the ability and reliability of a control to modify risk. Critical Control A control that, if removed or deteriorated, would results in a significant change in the risk. Employee Directors, employees, contractors and agents of Panasonic.

Event Change of a particular set of circumstances; can have several causes; An event can sometimes be referred to as an “incident” or “accident”.

Expected Consequence The common consequence based on our knowledge and the effectiveness of the control. Note: When assessing an occurrence, the consequence should consider what would be commonly expected to happen based on our knowledge of the controls, and not what actually eventuated.

Exposure Extent to which an organization and/or stakeholder is subject to a hazard. Frequency Number of events or outcomes per defined unit of time. Hazard Source of potential harm. Note 1 Hazard can be a risk source. HIRA Hazard Identification and Risk Assessment – The procedure described by this document.

Human Factors The minimization of human error and its consequences by optimizing the relationships within systems between people, activities & equipment, through the systematic application of human sciences.

Level of Risk Magnitude of a risk or combination of risks, expressed in terms of the combination of severity and their likelihood.

Likelihood

In risk management terminology, the word “likelihood” is used to refer to the chance of something happening, whether defined, measured or determined objectively or subjectively, qualitatively or quantitatively, and described using general terms or mathematically [such as a probability or a frequency over a given time period.

NAA National Aviation Authority. A national aviation authority or civil aviation authority is a government statutory authority in each country that oversees the approval and regulation of civil aviation.

Occurrence An unplanned event that happens in the workplace. Plausible Credible, foreseeable.

Practice Accepted industry practice/good practice generally represents a preferred approach; Good practice may change over time because of technical innovation, or because of increased knowledge and understanding.

Probability Measure of the chance of an something happening expressed as a number between 0 and 1, where 0 is impossibility and 1 is absolute certain.

Risk Effect of uncertainty on objectives. Note: Objectives can have different aspects (such as financial, health and safety, and environmental goals) and can apply at different levels (such as strategic, organization-wide, project, product and process).

Risk Analysis Process to comprehend the nature of risk and to determine the level of risk Risk Assessment The process for identifying (risk ID), analyzing (risk analysis) and treating (risk treatment) risk Risk Attitude Organization's approach to assess and eventually pursue, retain, take or turn away from risk Risk Description Elements: sources, events, causes and consequences

Risk Identification Process of finding, recognizing and describing risks. Note: Risk identification involves the identification of risk sources, events, their causes and their potential consequences

SAG Safety Action Group

Severity The plausible highest level of gain, injury or loss associated with the risk in the event all of the current controls fail.

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Table of Contents Preamble ....................................................................................................................................................... 2

Distribution ............................................................................................................................................... 3

Manual ownership .................................................................................................................................... 3

Management of change requests including manual revisions ................................................................. 4

Additional note ......................................................................................................................................... 4

Definitions ................................................................................................................................................. 5

Table of Contents .......................................................................................................................................... 6

Summary of changes ..................................................................................................................................... 9

1 Part 1 - Safety Policy and Objectives............................................................................................... 11

1.1 Requirements for SMS ............................................................................................................ 11

1.2 SMS regulatory requirements: ................................................................................................ 12

1.3 Additional factors defining SMS .............................................................................................. 12

1.4 Safety Policy statement .......................................................................................................... 13

1.5 Safety Objectives ..................................................................................................................... 14

1.6 Positive safety culture ............................................................................................................. 15

1.6.1 Continuous improvement ................................................................................................... 16

1.6.2 Unacceptable behavior ....................................................................................................... 16

1.6.3 PAC recognition and rewards system ................................................................................. 17

1.7 Scope of the Safety Management System .............................................................................. 17

SMS Framework .................................................................................................................................. 17

1.8 Management personnel .......................................................................................................... 19

1.8.1 Management duties and responsibilities ............................................................................ 21

Organization chart .............................................................................................................................. 21

1.8.2 Top Management ................................................................................................................ 22

1.8.3 Safety Review Board ........................................................................................................... 26

1.8.4 Global Safety Executive Meeting ........................................................................................ 27

1.8.5 All Employees ...................................................................................................................... 27

2 Part 2- Safety Reporting System ..................................................................................................... 28

2.1 Reporting Policy .......................................................................................................................... 28

Safety Reporting System ..................................................................................................................... 28

2.2 Safety notification types ......................................................................................................... 29

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2.2.1 Product Incident Reporting ................................................................................................. 29

2.2.2 Personnel Incident and Accident (non-product) ................................................................. 29

2.2.3 Voluntary hazard reporting (HIRA) ..................................................................................... 30

2.2.4 Quality Incident Report ....................................................................................................... 30

2.2.5 Safety notification review ................................................................................................... 31

3 Part 3- Hazard Identification & Risk Assessment ............................................................................ 31

3.1 Hazard identification ............................................................................................................... 31

3.1.1 Hazard Identification processes .......................................................................................... 32

3.1.1.1 Reactive ............................................................................................................................... 32

3.1.1.2 Proactive ............................................................................................................................. 32

Risk Management Flowchart .............................................................................................................. 32

3.2 Risk Assessment & mitigation process .................................................................................... 33

3.2.1 Risk concept ........................................................................................................................ 33

3.2.2 Risk management ................................................................................................................ 33

3.2.3 Risk probability .................................................................................................................... 33

3.2.4 Risk severity ........................................................................................................................ 33

3.2.5 Risk assessment matrix ....................................................................................................... 33

3.2.6 Risk mitigation ..................................................................................................................... 35

3.2.6.1 Cost considerations ............................................................................................................. 35

4 Part 4 - Safety Investigations .......................................................................................................... 35

4.1 Evaluation................................................................................................................................ 35

4.2 Data gathering......................................................................................................................... 35

4.3 Interview ................................................................................................................................. 36

4.4 Analysis ................................................................................................................................... 36

4.5 Findings and recommendations .............................................................................................. 36

5 Part 5- Safety Assurance ................................................................................................................. 36

5.1 Safety contributing factors...................................................................................................... 36

5.2 Information acquisition ........................................................................................................... 37

5.3 Record keeping ....................................................................................................................... 37

5.3.1 Safety records, general ....................................................................................................... 37

5.3.2 Control of access to records................................................................................................ 37

5.3.3 Retention of records ........................................................................................................... 38

5.3.4 Disposal of records .............................................................................................................. 38

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5.3.5 Lost or destroyed records ................................................................................................... 38

5.3.6 The following records will be maintained: .......................................................................... 38

5.4 Safety training ......................................................................................................................... 38

5.4.1 Policy ................................................................................................................................... 38

5.4.2 Training syllabus .................................................................................................................. 39

5.4.3 The scope of required training is as follows: ...................................................................... 39

5.5 Safety communication ............................................................................................................ 40

5.5.1 Purpose ............................................................................................................................... 40

5.5.2 Medium ............................................................................................................................... 40

5.5.3 Third party inclusion ........................................................................................................... 40

5.6 Site evaluations ....................................................................................................................... 41

5.7 SMS audits ............................................................................................................................... 41

5.8 Safety culture surveys ............................................................................................................. 41

6 Emergency Action planning ............................................................................................................ 42

6.1 Emergency Action Plan ........................................................................................................... 42

6.2 Emergency Action Plan web page ........................................................................................... 42

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Summary of changes

Iss. Effective Date Section/ Part

Pages Summary

1 30 Nov 15 All All First Issue

2 05 Jan 18

Changes made in coordination with NZCAA Manual Ownership amended to include local supplements and control. Table of Contents and Revision changed Definitions: Added NAA Item 1.1 changed last dot point to cover all aspects of safety not just aviation 1.5:

i. enhanced objective 2 to include "workplace and human factors" & improved definition for the associated indicator;

ii. changed indicator at objective 3 and merged with objective 4.

iii. Added proactive objective for meeting attendance 1.6, terminology changes & added SMP-006 reference in point 5 1.6.1 Added Continuous Improvement Process 1.8 Management Personnel includes reference to regional supplement to GSMM 1.8.2, duties and responsibilities précised.

i. Replaced reference to ‘Civil Aviation’ with ‘a recognized NAA’

1.8.4 Added SAG to identify SAG role requirements; added site evaluation role. 1.8.6 1.8.7: specific definitions for Global and Regional SRB. 1.8.6:

i. Added 'or his delegate' for Global SMS Manager ii. Added 'meet every quarter at a minimum' to allow

meeting frequency 1.8.7, added 'or his delegate' for Global SMS Manager 1.8.8, added SMP-006 Just Cause Procedure. 2.2, updated flow chart for Safety reporting System. 2.2.1, added link for MDCCRs. 2.2.3, added link for Voluntary Hazard Report. 2.2.4 added Safety notification review 3.2.1, amended to read correctly. 4.3, added link for Supervisors Incident Report Form 1-05-02 . 5.2, added SMP-007 Safety Interactions Procedure. 5.4.1 Training Policy supplemented with effectiveness level.

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Iss. Effective Date Section/ Part

Pages Summary

5.5.2 Added Read and Sign notifications to list of mediums. 5.5.3 Added Supplier Audit, induction process for visitors/contractors 5.6, added Site Evaluation. 5.7, assigned QA staff to perform SMS audits. Item 5.8 Added Safety Culture Survey to clarify what the SMF 127 is

3 25 Jan 2018

Changes made in coordination with NZCAA for clarity Manual Header “Year” corrected to 2018 Global document change to reference Global SMS Manager and Regional SMS Manager for clarification Revised Management of Change Process on page 4

4 06 Sep 2019

all all

Minor formatting improvements & alignment – non content adjusting Replaced reference to MDCCR to PIR Removed gender specific references “His” etc.

1

Formatted to reflect current standards Signature block amended Removed reference to Line and Repair as this is not necessary to note- this manual is the only main SMS in PAC

2 Preamble added Moved “About this Manual” to preamble section

4 CQAN replaced with RCN (Regulatory Compliance Notice) New Safety Policy inserted 11 Updated ICAO safety statement 19 Updated Accountable Manager job title 21 Updated Organizational chart 32 Updated and added roles to roles and responsibilities section 1.8.1 21 Org chart updated 1.8.2 22 Title & responsibility alignments/clarifications 1.8.3 26 Removed. Details held in 1.8.2

Small org chart removed as this is replaced by new one in 1.8.1 Clarified regional/global meeting frequency.

1.8.4 27 Absorbed into 1.8.2 1.8.5 Deleted. Absorbed into roles and responsibility section

Removed 3.1.1.3 as Predictive hazard identification is part of proactive identification

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1 Part 1 - Safety Policy and Objectives 1.1 Requirements for SMS Although major air disasters are rare events, lesser safety events may be masking underlying safety problems. Ignoring these underlying safety hazards could pave the way for an increase in the number of more serious accidents. Accidents and incidents may result in the serious consequence of injury to persons, as well as the secondary factor of financial cost. In addition, there are fewer tangible costs such as the loss of confidence of the traveling public. In order to meet the necessary standards of safety the SMS:

• Defines policies & standards affecting safety. • Allocates resources to sustain risk management activities. • Identifies & evaluates safety hazards. • Takes action to eliminate risks or reduce the level of risk to what has been decided as

being an acceptable level of risk. • Incorporates technical advances in the design & maintenance of equipment. • Conducts safety oversight & safety program evaluation. • Investigates accidents & serious incidents. • Adopts the most appropriate & best industry practices. • Promotes safety excellence as an integral part of all activities. (including exchange of

safety related information).

Safety: The state in which risks associated with aviation activities, related to, or in direct support of the operation of aircraft, are reduced and controlled to an acceptable level.

ICAO 9859 Fourth edition, 2018

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1.2 SMS regulatory requirements:

ICAO Annex 19 Safety Management ICAO Document 9859, Safety Management Manual (SMM) Australia CASA AC 172-01, Guidelines for Preparing a Safety Management System (SMS) Australia/New Zealand Standard – AS/NZS 4360:1999 – Risk Management Transport Canada TP13739B, Introduction to Safety Management Systems Transport Canada TP14326E, Safety Management System Assessment Guide Transport Canada TP14343E, Safety Management Systems Implementation Procedures Guide

for Air Operators and Approved Maintenance Organizations Peru DGAC RAP145 Chapter C, Brazil ANAC RBAC145, IS 145.214-001 Chile DGAC DAN 154 Appendix 1 Argentina ANAC Part 145, CA 145-7 UK CAA CAP 760, Guidance on the Conduct of Hazard Identification, Risk Assessment and the

Production of Safety Cases BCAA ANTR Part III Chapter 9, Safety Programs GCAA CAR Part X, Safety Management System Requirements Bahrain CAA ANTR 145.A.65, Safety and Quality Policy, maintenance procedures and quality

System Singapore CAAS AC 1-3(4), US FAA AC 120-92, Safety Management Systems for Aviation Service Providers CAANZ Rule Part 100 Safety Management and Advisory Circular 100-1 Safety Management

1.3 Additional factors defining SMS In addition to the regulatory requirements of safety, the SMS system shall be guided by the following factors:

• Aviation Legislation, which defines the broad responsibilities, accountabilities, and authorities for fulfilling the objectives of State Regulators.

• Manufacturing & trade laws, which govern the production & sale of safe aeronautic equipment & services.

• Labor laws (including Occupational safety & Health- OSH laws) which set the rules for the work environment in which aviation employees are expected to perform their work.

• Security laws, which contribute to safety in the workplace by governing who may enter into operational areas and under what terms. They may also protect sources of safety information.

• Environmental laws.

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1.4 Safety Policy statement

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1.5 Safety Objectives Panasonic Avionics Corporation recognizes safety as a prime consideration at all times. We recognize the Human Factors philosophy and will provide an infrastructure to embrace its principles. Panasonic strives to provide a safe, healthy work environment for all personnel and to improve the overall quality of our maintenance processes, products and services related to airworthiness safety by identifying, mitigating and eliminating risk and hazardous conditions. Safety performance targets will be created, based on the safety objectives, in order that the organization remains aware of whether the relevant objectives are being met. These safety performance targets will be measured and monitored with the use of safety performance indicators. Panasonic’s safety objectives are: 1. Minimize the number of flight safety incidents related to maintenance.

i. Indicator: Measured by how many incidents have happened by month/year. 2. Minimize accidents/incidents attributable to organizational, workplace and human factors.

i. Indicator: Measured by results of proactive hazard reporting vs reactive accident/incident reporting attributable to organizational, workplace and human factors reported by month/year.

3. Management of risks to an ‘acceptable’ level. i. Indicator: Measured through CAR/PAR – Measured through implementation and to an

acceptable mitigation of “As Low as Reasonably Practical” (ALARP) 4. Provide SMS training/education to all Line and Repair personnel.

i. Ensure implementation of training schedule – Measured through test scores, and number of relevant personnel trained.

5. Participation in Safety Meetings i. Indicator: Review of attendance to Regional Safety meetings- 80% of available invited

attendees.

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1.6 Positive safety culture Panasonic Avionics Corporation is committed to a culture whereby our beliefs, norms, attitude and practices are focused on reducing the exposure of all people affected by our work activities to dangerous or hazardous conditions. Our Safety Culture is integral to the Safety Management System and to the success of Panasonic Avionics Corporation. We are committed to an integrated approach where we utilize and develop existing systems across safety, security, emergency response and occupational health. The Panasonic Avionics Corporation Safety Culture is characterized by five key elements that must be actively supported by all team members, managers and contractors. These elements shall be consistently demonstrated as to embody trust and a genuine commitment to keeping the airline’s and Panasonic safety our highest priority. Leadership, commitment and example setting will drive this culture. 1. Flexible Operational and Quality Procedures are both necessary and mandatory in our business. Panasonic Avionics Corporation is committed to adapting to changing demands effectively while minimizing operational risk. Constantly seeking better practices through the continuous improvement cycle will ensure flexibility. The maintenance of safe practices will not be compromised as work processes change. 2. Informed Panasonic Avionics Corporation will provide all team members with the tools to enable effective safety and risk decision making on a daily basis. We will collate, assess and analyze safety data, transforming this data into information that will drive better decision making. 3. Learn As a learning organization, Panasonic Avionics Corporation is committed to learn from internal errors and those of other organizations. We will make necessary changes and we will be proactive in our observation and evaluation of our systems and processes and constantly seek continuous improvement and identification of vulnerabilities. 4. Report PAC actively supports and encourages an atmosphere where all team members report information about hazards or safety concerns. This will contribute to proactively identify current and potential risks thereby preventing incidents and accidents and facilitating continuous improvement. We will provide all team members with the tools to facilitate reporting. There is a strong management commitment to evaluate all safety issues and make decisions about resolving these issues and risks. 5. Just Critical to a Just Culture is the management of individual behavior in line with organizational values. Panasonic Avionics Corporation will ensure that an unintentional error will not result in disciplinary action. Gross negligence, deliberate unsafe acts, recklessness, intentional or unjustifiable acts will not be accepted. The conclusions or outcome will be shared into the organization with the purpose to improve the environment of trust and coaching where appropriate. This can be achieved through such means as SMS bulletin and updating training syllabus etc.

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1.6.1 Continuous improvement

Continuous improvement is measured through the monitoring of the SMS performance indicators. Progress is related to the maturity and effectiveness of the SMS. Safety assurance processes support improvements to the SMS through continual verification and follow-up actions. Processes that will facilitate continual improvement include: • Review of safety performance targets and indicators. • Safety culture surveys to staff. • Ensuring that all effective practices are documented, and then communicated as the new

standard expected. • Periodically monitoring and reviewing the risk management process, • Implementing recommendations from incident investigations. • Implementing recommendations from audit reports. • Involving all personnel in safety meetings. • Networking with other similar organizations and sharing safety information.

In combination with appropriate statistical tools to analyze data, all processes are periodically revised in a systematic way. Improvements should be assessed to ensure they are reasonable to be carried out. The assessment should take into account wider operational and business benefits. 1.6.2 Unacceptable behavior In the rare event that an employee acts irresponsibly in any of the following ways, they may be subject to Human Resource disciplinary action, which may include termination of employment.

• Premeditated, willful or deliberate actions with the purpose or effect of leading to harm or potential harm to guests, employees or members of the public and or damage to property.

• Failure to report safety, security or material risk issues as required by company policy/standard operating procedures.

• Actions or decisions involving reckless disregard for safety or security outcomes, negligence or dereliction of duty.

A team member’s willingness to report and their honest participation in the process will be considered in a positive manner when determining any appropriate disciplinary action. The five elements of our Safety Culture are recognized and supported throughout the global aviation community. Collectively, these elements form a commitment that each employee of Panasonic Avionics Corporation ensures the safety and security of all people affected by our work activities.

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1.6.3 PAC recognition and rewards system To encourage a positive safety culture, PAC PTS utilizes the “High 5 Program” to reward the employees that have had the greatest positive impact on PTS Safety Management System. The Recognition Program allows individuals to show their appreciation for their colleagues’ outstanding performance and everyday excellence. Here, you have the opportunity to recognize each other for beyond safety contributions that matter each day. 1.7 Scope of the Safety Management System In aircraft maintenance and aeronautical product repair, risk potential may be created by the conditions under which the maintenance/repair is conducted. The Safety Management System is designed to be far reaching and it will embrace the following issues while recognizing the ICAO and NAA models. SMS Framework

ManagementCommitment

Safety

Efficiency Effectiveness

Safety Risk Management

Panasonic CommunityStakeholders

Safety Policy, Objectives and PlanningManagement commitment and responsibility

Safety accountabilities of managers

Appointment of key Safety Personnel

SMS implementation plan

Third party interfaces

Coordination of the emergencyresponse plan

Documentation

SMS Framework

Hazard identification processes

Risk assessment and mitigation processes

Safety Trainingand Promotion

Training and education

Safety communication

Safety Assurance

Safety performance monitoring and measurement

Internal safety investigations

The management of change

Continuous improvement of the safety system

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Organizational issues:

Time pressures vs production turn-around-time. Procedures and operating practices (documentation and checklists). Outsourcing of services to subcontractors. New technologies requiring new tools, new work procedures. Retraining.

Workplace Issues:

• Environmental factors (e.g. lighting, temperature, noise, vibration, etc.) • Design of equipment. • Availability and accessibility of spares, tools, documentation, etc. • Requirements for having ready access to technical information.

Human Factors Issues:

• Organizational and workplace conditions (as stated above). • Human performance (medical condition & physical limitations). • Scheduling (e.g. shift work, night work and overtime) versus adequate rest periods. • Inadequate procedures. • Quality of supervision. • Communications—medium, terminology and language. • Adequacy of handovers at shift changes and record keeping. • Boredom.

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1.8 Management personnel Accountable Manager Mr. Sean Gavin – Senior Vice President, Customer Support Services Tel: Office: +1 949 462 1261 Cell: +1 949 632 8101 E-mail: [email protected] Global SMS Manager Mr. Stefan Suri– Head Regulator & Global SMS Tel: Office: +1 972 745 1256 Cell: +1 949 293 9254 E-mail: [email protected] Regional SMS Manager If required by the regional NAA the Regional SMS Manager Role and reporting path will be defined in a regional supplement to this document or as agreed with the Aviation Authority. Regulatory Compliance Director Mr. Paul Lee – Director Regulatory Compliance Tel: Office: +44 (0)1753 741 472

Cell: +44 (0)7748 768 3 47 E-mail: [email protected]

mailto:[email protected]



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Safety Action Group (s)

(SAG) receives SMF-120

Global SMS Responsibility Structure

Global SMS Manager

and PTS Manager review

SMF-120 for assignment to SAG

members

YES

SAG members conduct risk

assessments to create mitigation plans if

required

SAG Issues CAPA to

appropriate department

SAG teams report monthly to Global SMS Manager for

quarterly reporting to regional SRB of

all hazards and risk mitigations

PTS Employee submits Hazard

identification ReportSMF-120

NO

Explanation to employee why no risk mitigation will

be conducted

SRB conducts review of

hazards and risk mitigation plans

NO

Acceptance

SRB teams report annually to Global Safety

Executive Meeting for reporting on all hazards and

risk mitigations

Mitigation Plans not accepted by SRB will be sent back to SAG teams

for evaluation of risk mitigation plans

YES

NO

NO

Mitigation Plans not accepted by Executives will be actioned back to SRB and SAG teams for

evaluation of risk mitigation plans

Report

Annual report to employees from

Accountable Executive on health of SMS

NO

NO

Explanation of risk

mitigation reported to employee

Explanation of actions

reported to employee

Global Safety Executive Meeting

Receives SRB reporting on all hazards and risk

mitigations for acceptance

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1.8.1 Management duties and responsibilities Our organization is composed of many types of employees who all contribute to our success. Each employee interacts with safety in some way, but the degree of SMS involvement varies for each position. Those employees who have direct contact with safety management have greater responsibilities, while employees who are involved in technical areas will have fewer. Management and personnel need to refer to their local MOE, MOM or RSQCM for their regional regulatory duties & responsibility. Organization chart

Chief Executive Officer

Chief Operating Officer

Sr. VPCustomer Support Services

Head ofLine Maintenance

Head ofRepair

Regional Heads Regional Heads

Site Representatives Site Representatives

Safety Coordinator

Safe

ty R

evie

w B

oard

Safe

ty A

ctio

n G

roup

Global Safety Manager

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1.8.2 Top Management Top management of this organization has ultimate responsibility for the SMS and will provide the resources necessary to implement and maintain the SMS. The responsibility and authority to accomplish many of the required SMS functions and tasks have been assigned to some of the persons discussed below. Ultimate accountability for the SMS is still retained by top management. The Chief Executive Officer (CEO) is ultimately responsible for the Safety Management System and provides the necessary resources to implement and maintain the program. The CEO has designated the Accountable Manager (Senior VP Customer Support Services) to be the member of management who:

• Ensures that processes needed for the SMS are established, implemented, and maintained.

• Reports to top management on the performance of the SMS and specific areas in need of

improvement.

• Promotes awareness of the SMS throughout Panasonic.

Sr. Vice President – Customer Support Services (Accountable Manager)

(a) The Sr. Vice President – Customer Support Services holds overall accountability for operation and the implementation of the SMS.

(b) Responsibilities include: i. Provisioning and allocating manpower, technical, financial and other resources necessary

for the effective implementation of SMS and continuous improvement in operation. ii. Implementation of the Safety Management System and associated safety policy and

objectives. Ensure all employees and applicable third parties are aware of the company’s SMS program and adhere to policies and procedures.

iii. Establishing Safety Policy and Objectives that effectively govern and promote the Safety Culture.

iv. Ensuring safety issues are mitigated to As Low As Reasonably Practicable, and there is no high risk in safety while conducting the business.

(c) The Sr. Vice President – Customer Support Services may appoint senior persons responsible for safety management (Global Safety Manager) and SMS administrative personnel (Safety Coordinator).

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Global Safety Manager

(a) Responsible for the development, operation and continuous improvement of the Safety Management System including:

i. Monitoring Hazard Report and escalating the safety concerns to senior management as applicable.

ii. Oversight/Chair of Safety Risk Assessment and Risk Mitigation activities. Evaluate the results of risk assessments and mitigation activities and ensure the company’s safety standards are maintained.

iii. Maintaining SMS manual and associated forms. Ensure policies and procedures reflect current company operations and are written to ensure compliance with applicable regulations.

iv. Planning and developing adequate personnel training related to SMS program in conjunction with the Training Department.

v. Monitoring safety concerns in the aviation industry and any potential impact on PTS operations.

vi. Coordinating and communicating with NAAs along with the Regulatory Compliance and Quality Assurance team for Aviation Safety related matters.

(b) The Safety Manager shall be consulted on all risk assessment and mitigation plans within the company.

Safety Coordinator

(a) Coordinates and tracks day-to-day SMS activities carried out by assigned personnel within PTS. The function includes but not limited to:

i. Preparing reports and facilitating Safety Review Board Meetings. ii. Maintain Safety Performance Indicators (SPIs) and Safety Performance Targets (SPTs).

Provide periodical reports to Safety Manager and Management staff. iii. Maintaining records related to SMS activities. iv. Monitoring progress of risk assessment, risk mitigation and site assessment. Coordinate

with responsible management personnel to ensure all safety actions are processed in timely manner.

v. Establishing effective communication with employees. Prepare Safety Newsletters, Safety Bulletins and other communication materials to promote the Safety Culture within the company.

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Head of Line Maintenance/Repair

(a) Responsible for the overall process in Aircraft Maintenance and Component Maintenance respectively. They shall organize the Safety Action Group (SAG) and ensure:

i. Organizations are structured in such a way to clearly identify all operational and safety responsibilities in each region.

ii. Safety levels are maintained universally across the regions to the required standards and that a culture of continuous improvement is maintained.

Regional Head of Line Maintenance/Repair

(a) Responsible for the day to day operations at the regional level. The responsibilities include but are not limited to:

i. Ensuring that the safety level at assigned site(s) are maintained. ii. Promoting safety culture across site(s) where safety is perceived, valued and prioritized

in an organization. iii. Monitoring safety performance and action items at the assigned site(s). Ensure Site

Management personnel and operations are aligned with the organizational Safety Policy and Objectives.

iv. Providing a monthly update to the Head of Line Maintenance/Repair, Safety Manager and Coordinator pertaining to assigned safety action items.

(b) Regional Heads of Line Maintenance/Repair may appoint SMS Regional Focal(s) (SAG Member) to track safety actions and ensure they are completed in timely manner.

Site Manager

(a) A manager assigned at a line maintenance station or repair shop. (b) Functions include but not limited to:

i. Providing safe working environment to employees, and ensuring work is performed in accordance with the applicable regulations, Quality Management System and SMS. Ensure annual Site Evaluation is conducted.

ii. Scheduling the production in such a manner that Human Factors related safety risks are minimized, and tasks are assigned to competent staff who have been appropriately trained and qualified.

iii. Ensuring all staff are aware of and adhere to Panasonic’s Safety Policy and Safety Objectives.

iv. Monitoring open HIRAs and taking necessary action. v. Promoting positive safety culture and proactive hazard/incident reporting. Provide

feedback to any safety concerns raised by employees.

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Director, Regulatory Compliance

(a) Responsible to ensure that the company establishes policies and procedures that meet the applicable aviation regulations and operates within the framework of this SMS procedure. The function in SMS includes but not limited to:

i. Serving on behalf of the Accountable Manager as the primary contact for coordinating with NAAs.

ii. Evaluating change in aviation regulations and analyzing impact to the SMS program. iii. Planning and arranging SMS Audits, and appointing SMS Auditor. iv. Director, Regulatory Compliance will receive notification for all Product and Aviation

related incidents in order to file the required safety report to NAAs and customers, as needed.

Employees All employees and contractors are responsible for safety in this organization. Every employee, whether top management or a new-hire, must consider the safety implications of all activities performed. Each individual has the responsibility to communicate relevant safety-related information and to strive to achieve the highest possible level of safety in our organization. Safety Action Group (SAG) Members

(a) The SAG is organized by the Head of Line Maintenance/Repair and comprised of Maintenance/Repair representatives from operation sites.

(b) Their roles include but are not limited to:

i. Oversight of operational safety. ii. Implementation of safety risk mitigations.

iii. Ensuring that safety action is achieved within agreed timescales. iv. Reviewing the effectiveness of SMS program and safety risk mitigations. v. Meeting regularly to review:

• Safety performance against the organization’s safety policy, objectives and

performance indicators. • New and ongoing risks and mitigation efforts. • Open safety related action items. • Audit performance and findings.

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1.8.3 Safety Review Board PAC has established a formal Safety Review Board (SRB) to accomplish many of the duties required by the SMS. The SRB consist of the Global SMS Manager, Regional Managers, Regional Directors (Heads), Regional Line Maintenance and Repair Managers. The SRB’s provide a forum for discussing safety-related issues from different perspectives and is thus comprised of members from each of our operating departments. This multidisciplinary expertise provides a natural forum for sharing ideas and assessing safety performance from a system perspective. The Global SMS Manager or delegate will chair the SRB meeting and record on SMF-128. The Board will meet quarterly and include a global and regional summary. During SRB meetings the following topics, based on SMF-128, will be reviewed and include:

• Open action items. • Suitability of Safety Policy and Safety Objectives. • SMS performance to objectives. • Audits, self-evaluations and findings. • Customer feedback (SMS/Safety related.) • Process conformity. • SMS-related PARS and CARS. • Changes that will or could affect the SMS in the future. • Assign any new action items.

The responsibilities of the Safety Review Boards include:

Act as a source of expertise and advice on safety matters to top management. Review the progress of actions taken in response to identified hazards, incidents and

accidents. Accept risk control strategies that affect multiple departments. Coordinate with each department to ensure timely implementation of risk controls. Review internal SMS Audit reports for company-wide trends. Review safety reports to be presented to top management. Provides the annual report for the Global Safety Executive Meeting to discuss and review

safety-related issues. The Global SMS Manager or delegate will provide assistance to the Board and any of its sub-committees. All Board members have the opportunity to submit potential agenda items to the Global SMS Manager.

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1.8.4 Global Safety Executive Meeting Our organization has established a formal Global Safety Executive Meeting (GSEM). The GSEM consist of company Executives and Regional Directors. The Global SMS Manager or delegate will chair the GSEM and record the meeting on SMF-128. This board will meet annually and as needed to discuss SMS activities and requirements. During the meetings, the following topics will be reviewed based on the SMF-128 and include a review of:

• Open action items. • Suitability of Safety Policy and Safety Objectives. • SMS performance to objectives. • Audits, self-evaluations and findings. • Customer feedback (SMS/Safety related.) • Process conformity. • SMS-related PARS and CARS. • Changes that will or could affect the SMS in the future. • Assign any new action items.

The responsibilities of the Global Safety Executive Meeting include:

Provide the resources (personnel, funding, and support) necessary to fulfill SMS requirements.

Facilitate implementation of the SMS across the organization. Foster a strong safety culture within the organization. Promote awareness of safety requirements throughout the organization. Develop safety targets and measures. Review safety data reports to determine the safety status of the organization.

The Global SMS Manager will provide assistance to the Executives and any of its sub-committees.

1.8.5 All Employees All employees and contractors are responsible for safety in this organization. Every employee, whether top management or a new-hire, must consider the safety implications of everything they do. Each individual is responsible for the safety of his or her actions. Each individual has the responsibility to communicate relevant safety-related information and to strive to achieve the highest possible level of safety in our organization. All employees are reminded that our organization has instituted a just culture as described in this manual. While unintentional acts that inadvertently compromise safety will not be punished, the concealment of such information will not be tolerated. See part 1.6 for Positive Safety Culture.

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2 Part 2- Safety Reporting System

2.1 Reporting Policy Employees are encouraged to report incidents and hazards which have the potential for serious consequences for the safety of persons, equipment and property without fear of punitive reprisal from management or colleagues. The report process is intended to be as simple as possible in order to encourage participation. The report form (SMF-120) is structured in such a way as to be brief and confidential but participants are encouraged to include all information to capture all necessary facts. The focus of the Safety Reporting System is on the detection of and recovery from an unsafe condition. Safety Reporting System

Incident/Hazard needs to be

reported

Personnel incident / accident?

PTS personnel generate Incident / Accident Reporting Ref P-QOP-29-12

YES

Product incident?

Submit Hazard Identification

report SMF-120

NO

Yes

No

HR/Safety and Security define if investigation is

required

SAG members conducts risk assessment

process

SMS and PTS Managers review

SMF-120 for assignment to SAG

members

Global SMS Manager review

and route to proper Dept for action

Feedback to employee/entity

about actions taken

If it is Compliance related the SAG issue CAPA to

appropriate Dept,

YES

PTS and PAC local regulatory compliance

define reporting needs (NAA or

Customer)

PAC regulatory compliance will coordinate and report to NAA

PTS and local PAC regulatory

compliance will coordinate and

report to Customer

NAA CustomerSafety and Security Officer & HR take

actions

YES

NO

Third party Incident/Hazard

reported

Contractor or Subcontractor

lead the investigation?

Yes

NO

HR/Safety and Security Identify

Hazard?

YES

NO

YES

Sent to the Contractor/Sub-contractor for

analysis

Submit MDCCR iaw WI-22-05-06

Product/Hazard?

Product

Hazard

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2.2 Safety notification types There are four types of notifications for reporting safety-related items; Product, Personnel, HIRA and Quality. 2.2.1 Product Incident Reporting NAA Reporting - Panasonic is affected by mandatory reporting programs that require notification of aircraft accidents, incidents, occurrences, malfunctions and defect reports that fit the required reporting by the local NAA regulations. These reports and notifications will be coordinated and reported to the Local NAA by the local PAC Regulatory Compliance Manager. PAC personnel, per the NAA regulations, still have the ability to report any product incident directly to their local NAA. Customer Reporting - For PTS activities the Operator will be responsible for submitting Product Incidents to the NAA. It is the responsibility of PTS Staff to report any unsafe condition immediately to an operator prior to the aircraft being signed off for flight. PTS in coordination with PAC Regulatory Compliance group may submit a Product Incident on behalf of the airline if requested. Every effort shall be made to ensure duplicate reporting does not take place. Panasonic Avionics Corporation has an internal reporting process for reporting the failure of Product and safety-related occurrences to management and the Product Safety Officer. Per corporate policy, any Product Incident shall be reported and routed to the Product Safety Office utilizing the PIR form per P-WI-22-05-02. The incident shall be reported immediately for emergency/urgent incidents within 24 hours. Link to the PIR Reporting Form: http://spf01/sites/PAC-Quality/RI/_layouts/15/start.aspx#/SitePages/Home.aspx The PIR form is also available via the iWeb Intranet: Home > Departments > Quality > Links > under header “Corporate Quality”>Submit Risk/Incident (PIR Form) Follow instructions in BLO-QOP-22-05 which can be found in the Agile PLM application on the iWEB. 2.2.2 Personnel Incident and Accident (non-product) Instances which involve injury to personnel or damage to property (non-product) while at work or while conducting company business must be reported to the local HR management as soon as possible and will be investigated by the facility manager or supervisor. The employee shall complete the “PAC Critical Incident Reporting Form (Non ISM)” P-QOP-29-12-1. The manager or supervisor shall complete the “Near Miss/Incident Report (P-QOP 29-20-4)” while conducting the investigation. The report forms must be submitted to local HR management and Safety & Security department in Lake Forest California. Forms are here: http://spf01/sites/PAC-Quality/RI/_layouts/15/start.aspx#/SitePages/Home.aspx and via the iWeb: Home > Departments > Safety and Security > Global Environmental Health, Safety and Security > Accident and Near Miss.

http://spf01/sites/PAC-Quality/RI/_layouts/15/start.aspx#/SitePages/Home.aspx

http://spf01/sites/PAC-Quality/RI/_layouts/15/start.aspx#/SitePages/Home.aspx

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2.2.3 Voluntary hazard reporting (HIRA) Employees who work daily in the operational areas of the company are in the best position to be aware of hazards. Thus, all personnel are strongly encouraged to report all current or potential hazards, where our procedures did not adequately ensure the proper level of safety. Also, reports should be made when procedures were not followed for either inadvertent or intentional reasons. Reports may be made verbally to any staff member of the Safety Office, but it is preferred that the report is made in writing to the local manager and Global SMS Manager using SMF-120 with a full explanation of all related details, from which an analysis can be conducted. Any staff member of the Safety Office who receives a verbal report will complete SMF-120 for submittal to the local Manager with a copy to Global SMS Manager.

Voluntary Hazard Reporting is a confidential program that protects the identity of the reporter. Only the Global SMS Manager, or designee, will know the identity of the reporter and will keep that identity confidential. The Global SMS Manager, or designee, may contact the reporter to obtain additional information necessary to fully analyze the situation. Further use of the reported information outside of the Safety Office will not contain any facts that can identify the reporter. The Global SMS Manager may report the supplied information to the regulator, without revealing the identity of the reporter.

Additionally, the Voluntary Reporting Program is a non-punitive program that does not use the reported information to punish employees but is instead focused upon developing process improvements to eliminate the identified hazards or control the risks associated with the report. It is recognized that the vast majority of incidents and accidents are due to inadequate procedures or the training given to employees about the procedures, so there is no benefit in allocating personal blame in these cases. However, this non-punitive policy does not apply to illegal acts or blatant disregard of regulations or procedures. The SMF-120 form is available to staff through the SMS share portal. http://spf01/sites/PAC-Quality/RI/layouts/15/start.aspx#/SitePages/Home.aspx Access is also via the iWeb Intranet: Home > Departments > Quality > Safety Management System > Safety Management Forms 2.2.4 Quality Incident Report Where an event has already occurred and did not affect flight safety or personal injury, the following link directs the user to the form and instructions: file://data-bot/data/QA-QC/Share/IQS/Inc%20Mgt/Incident%20Management%20OI%20Template.xlsm

http://spf01/sites/PAC-Quality/RI/layouts/15/start.aspx#/SitePages/Home.aspx

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2.2.5 Safety notification review Safety notifications will be collated into a report for review by the Regional members during the scheduled meetings and by Executive members during the annual review. The input to the report is shown in the diagram below.

3 Part 3- Hazard Identification & Risk Assessment 3.1 Hazard identification Hazard identification is an ongoing process where hazards are identified and managed so that safety is not compromised. A hazard may be identified from company’s voluntary reporting system, accident/incident reports, audits and surveys, as well as industry incident/accident reports. For full Hazard identification and Risk assessment see SMP-003. It is important to distinguish between: a) HAZARD A condition b) CONSEQUENCE Result or effect c) RISK Likelihood & Severity

Product Reporting

HR / Security Reporting

QMS Reporting

SMF 003 HIRA Reporting

Review Report

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3.1.1 Hazard Identification processes 3.1.1.1 Reactive Reactive method responds to the events that have already happened, such as incident and accidents. The process of employing mitigating action following the occurrence of an accident/incident and using the analysis of the causes to prevent reoccurrence. e.g. trend analysis.

3.1.1.2 Proactive Proactive method looks actively for hazards that pose safety risks through the analysis of the organization’s activities like mandatory reports, company’s voluntary reporting system, safety & quality audits and surveys. An approach which emphasizes prevention through the identification and the introduction of risk mitigation measures before the risk bearing event occurs and adversely affects safety performance. Risk Management Flowchart

Preparation

Reactive

Proactive

Invo

lve S

take

ho

lde

rs an

d

Co

mm

un

icate

Identification Evaluation / Assessment Control Implementati

on & Review

Record and Store

Document

Assess & Prioritize

Determine Risk Factor

Evaluate Existing Controls

Determine Probability

Determine Needed Controls

Reassess Modified Controls

Assess Actions

QA & SM Review

Control Approval

Publish & Educate

Compliance Integration

Do

cum

en

tatio

n

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3.2 Risk Assessment & mitigation process 3.2.1 Risk concept

Risks may be categorized into 3 broad groups:

a. Risks that are so high that they are unacceptable. b. Risks that are so low that they are acceptable. c. Risks in between a) & b) where consideration needs to be given to the various trade-

offs between risks and benefits. 3.2.2 Risk management Risk management is the identification, analysis and mitigation of risks associated with the hazards of the organization. Risk assessment uses conventional breakdown of risk into 2 components – probability of Likelihood and Severity of the projected consequence should it occur. Acceptability of a risk is based on the use of a risk index matrix and its corresponding acceptability/ decision criteria. 3.2.3 Risk probability This is the likelihood that a situation of danger that might occur. 3.2.4 Risk severity Risk severity measures the possible degree of harm of the consequences of a situation of danger. All credible outcomes should be analyzed in case a consequence with lower severity has such a greater likelihood that it results in higher risk. Severity may be defined in terms of property, health, finance, liability, people, environment, image or public confidence. 3.2.5 Risk assessment matrix Table 1 Risk. (Likelihood of Occurrence.):

Level Likelihood Descriptor

5 Almost certain Imminent–is expected to occur in most circumstances.

4 Likely Once in the next month, will probably occur in most circumstances.

3 Possible Once in the next 12 months, might occur at some time. 2 Unlikely Once in the next 1–5 years, could occur at some time. 1 Rare Once in the next 5-10 years–may occur only in exceptional

circumstances.

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Table 2 Consequence Rating. (Severity of Occurrences.):

Level Severity Descriptor

5 Severe Catastrophic (at least one fatality, huge financial loss). 4 Major Major (extensive injuries to one or more people, major financial loss). 3 Moderate Moderate (medical treatment required, high financial loss). 2 Minor Minor (first aid treatment at the workplace, medium financial loss). 1 Negligible Insignificant (no injuries, low financial loss).

Table 3 Risk Index Matrix:

Severity

1 2 3 4 5

Neg

ligib

le

Min

or

Mod

erat

e

Maj

or

Seve

re

Like

lihoo

d

5 Almost Certain 6 7 8 9 10

4 Likely 5 6 7 8 9

3 Possible 4 5 6 7 8

2 Unlikely 3 4 5 6 7

1 Rare 2 3 4 5 6

Table 4 Risk Acceptability Table:

> 7 Extreme Risk Needs senior management detailed treatment plan as required

6 to 7 High Risk Needs senior management attention and treatment plan as appropriate

4 to 5 Medium risk Manager-level attention and monitoring as appropriate.

< 4 Low risk Manage by procedures / work Instruction

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3.2.6 Risk mitigation Risk mitigation is the process of implementing actions or defenses to eliminate or reduce the probability or severity of risks associated with hazards. Three basic strategies in risk mitigation will be used:

AVOIDANCE - the operation or activity is cancelled because risks exceed the benefit of continuing the operation or activity.

REDUCTION - the frequency of the operation or activity is reduced, or action is taken to

reduce the magnitude of the consequences of the accepted risks. SEGREGATION OF EXPOSURE - action is taken to isolate the effects of risks or ensure there is

built-in redundancy to protect against it. i.e. reduce the severity of risk 3.2.6.1 Cost considerations During the process of evaluating mitigation actions or additional defenses it is necessary to strike a balance between production and safety goals. Hazardous conditions or risks may exist which may not be cost-effective to eliminate totally. Operations may continue as long as safety risks have been mitigated to a level that is as low as reasonable possible PROVIDED that level is determined to be acceptable using the Risk Matrix criteria.

4 Part 4 - Safety Investigations 4.1 Evaluation

The responsible manager or delegate will complete a formal investigation to identify underlying causes and potential hazards.

4.2 Data gathering

The investigation will gather all relevant information from a variety of sources including but not limited to:

Physical examination of the equipment used during the event. On-site investigation. Maintenance records and logs. Personal records/logbooks, certificates and licenses. In-house personnel and training records. Work schedules. Operator’s manuals and SOPs. Training manuals and syllabi. Manufacturer’s data and manuals. Regulatory authority records. Simulations. Incident databases.

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If applicable, specialist advice will also be sought from the vendors, manufacturers, external repair shops, and any relevant parties as applicable.

4.3 Interview Interviews are an integral part of the data collecting phase. Interviews will be conducted with individuals directly or indirectly involved in the maintenance activity. These can provide a principal source of information for the investigation. In the absence of measurable data, interviews may be the only source of information. Interviews are confidential and are conducted as soon as practicable after the incident has occurred. Each interview is documented in the form of interview statements, signed and acknowledged by the interviewee. 4.4 Analysis The available data is reviewed and evaluated. Once the (actual or potential) human errors/violations have been identified, considering their causes will help to identify effective intervention measures. 4.5 Findings and recommendations A Near Miss/Incident Report, presenting the findings of the investigation will be submitted to local HR representative, Safety & Security and Global SMS Manager. The Safety Investigation records and activities are stored and retained by HR and Safety & Security department. This will facilitate ease of retrieval and allow for the analysis of trends in the type’s maintenance-induced errors and its contributing factors. Any significant abnormal trend would warrant appropriate investigation (See section 2.2.2) into potential hazards or risks associated with such deviation. The Near Miss/Incident Report form can be located at: https://iweb.panasonic.aero/employee-gateway/employee-centre/safety-security/accident-near-miss-reporting The report form is also available via the iWeb Intranet: iWeb Home > Departments > (under HR) Global Environmental Health, Safety and Security > In the “Safety” Section > Accident & Near Miss Reporting.

5 Part 5- Safety Assurance 5.1 Safety contributing factors

The primary purpose of our safety assurance process is to assure the performance and effectiveness of our risk controls. Safety assurance includes Site-Evaluations, SMS Audits, data tracking/analysis and investigations. Audits and evaluations support the essential function of the SMS by ensuring that safety objectives have been met. Site-Evaluations are carried out within each site by local Management/SAG members.

https://iweb.panasonic.aero/employee-gateway/employee-centre/safety-security/accident-near-miss-reporting

https://iweb.panasonic.aero/employee-gateway/employee-centre/safety-security/accident-near-miss-reporting

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5.2 Information acquisition

Information relevant to SMS Audits or site-evaluations shall be acquired from a variety of sources:

A. PAC utilizes the following specific sources of information: 1. Mandatory reporting programs. 2. Voluntary Safety Hazard Reporting. 3. The SMS audit process. 4. The site-evaluation process. 5. Accident and incident investigation. 6. Change management. 7. Internal evaluation.

B. Interviews conducted with individuals. These can provide a principal source of

information for any investigation. In the absence of measurable data, interviews may be the only source of information.

C. Direct observation of actions performed by operating or maintenance personnel in their work environment. This can reveal information about potential unsafe conditions. However, the persons being observed must be aware of the purpose of the observations.

D. Specialist advice - Investigators cannot be experts in every field related to the operational

environment. It is important that they realize their limitations. When necessary, they must be willing to consult with other professionals during an audit or evaluation.

5.3 Record keeping

5.3.1 Safety records, general

Safety activities are recorded using the Safety Management Form Templates listed in part 5.3.6. The documents are produced electronically and the format of the record cannot be manipulated by the user.

5.3.2 Control of access to records

Access to SMS electronic records is managed through the Compliance portal that allows read only permissions to nominated technical staff and management. Hard copy records are locked in secure storage and under control of the local PTS facility. The NAA may request access to the records at any time.

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5.3.3 Retention of records Hard copy records will be retained for a minimum of 5 years. The records will be retained with due regard to fire, flood, theft and falsification. Electronic records are retained for a minimum of 5 years. The portal (database) is safeguarded by back-up procedures in the event of system failure. 5.3.4 Disposal of records If records are to be disposed of, they will be destroyed via shredding or electronically. 5.3.5 Lost or destroyed records If records are lost or destroyed, they may be re-created using known and verifiable data to substantiate the new record. 5.3.6 The following records will be maintained:

(i) SMS Audit Reports SMF-005. (ii) Periodic Analyses of Safety Trends & Indicators. (iii) Minutes of Safety Management meetings SMF-128. (iv) Hazard Identification & Risk Register and Assessment Worksheets SMF-003. (v) Safety Culture Surveys SMF-127. (vi) Hazard Identification Reports SMF-120. (vii) Site-Evaluation Checklists SMF-004. (viii) Change Management Worksheets SMF-002-01. (ix) Change Management Request Forms SMF-002. (x) Any relevant documents to the above records.

Safety Review and meeting records and their associated documents will be maintained for the life of the controls that have been implemented from the risk assessments. 5.4 Safety training

5.4.1 Policy

It is the intention that all personnel understand the organization’s safety philosophy, policies, procedures and practices and understand their roles and responsibilities within the safety management framework. Safety training will begin with the initial indoctrination of employees and continue throughout their employment. Specific safety management training will be provided for staff who occupy positions with particular safety responsibilities. The Line and Repair Management have the responsibility to ensure all employees complete their respective SMS training. Effectiveness of training will be measured through testing at the end of the SMS courses. The employees must score a minimum of 80% or must continue retraining and testing until 80% or higher is achieved. This will ensure the competence, knowledge, and skill of the personnel.

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5.4.2 Training syllabus The Global SMS Manager will, in conjunction with the department functional heads, review the job descriptions of all staff and identify those positions that have safety responsibilities. The training program will ensure that the safety policy and principles of the organization are understood and adhered to by all staff and that all staff are aware of the safety responsibilities of their positions. The level/mode of training shall be appropriate to the individual’s involvement in the SMS. SMS training may be integrated with related training programs and syllabus shall include the following:

a) Conveying safety lessons/information. b) Explaining why SMS related activities are introduced or changed. c) Conveying SMS activity updates. d) Educating personnel on the procedure for hazard reporting.

e) Promotion of the Company’s safety objectives, targets and culture. The medium for such communication may include notices or statements on safety policy/objectives, newsletters, bulletins and/or safety seminars/workshops 5.4.3 The scope of required training is as follows: All SMS training is documented in the LMS system. Recurrent training is also scheduled through the LMS system.

Position/JobEndorsement

Knowledge/Skill/AbilityCertification Needed Ac

coun

tabl

e M

anag

emen

t

SMS

Man

ager

Dire

ctor

s an

d Re

gion

al D

irect

ors

Man

ager

s Re

pair

Oper

atio

ns a

ndM

anag

ers

Line

Mai

nten

ance

Op

erat

ions

Regi

onal

Qua

lity

Man

agem

ent

Safe

ty P

erso

nnel

Repa

ir St

atio

n an

dLi

ne S

tatio

n St

aff

The 7 SMS courses noted below are required Training

Employees

SMS Introduction I I I I I I ISite-Evaluation R2 R2 R2 R2 R2SMS Audit R2 R2 R2 R2

Change Management R2 R2 R1 R1 R1 R1Hazard Identification & Risk Assessment R2 R2 R2 R2 R2 R2 R2

Safety Investigation R2 R2 R1 R1 R1Emergency Response Plan R2 R2 R2 R2 R2 R2 R2

I = One Time Training; R1 = Recurrent Training Annually; R2 = Recurrent Training 2 Years

Top Management SAG Teams

SMF-007 SMS Training Matrix

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5.5 Safety communication

5.5.1 Purpose The purpose of communicating the organization’s SMS processes and activities is to:

a) Ensure that all staff members are aware of the SMS. b) Communicate safety lessons learned/information. c) Explain why SMS related activities are introduced or changed. d) Communicate SMS activities updates. e) Dissemination of completed safety assessments to concerned personnel. f) Educating personnel on procedure for hazards reporting. g) Promotion of the company’s safety objectives, goals and culture. h) Third party inclusion to the SMS.

5.5.2 Medium The medium for such communication/promotion may include notices or statements on safety policy/objectives, Regulatory Compliance Notice, newsletters, bulletins, safety seminars, Read and Sign notifications, orientation program. 5.5.3 Third party inclusion It is recognized that these procedures can be successfully utilized as a model to provide a vehicle to ensure third parties are embraced by the Panasonic SMS or if the third party operates an SMS, the two systems are fully integrated. Suppliers are audited and managed by Corporate Quality prior to being listed as approved suppliers. Local procedures will ensure that visitors and contractors receive induction training to highlight the known hazards, emergency procedures and operational requirements. Induction training will be recorded and stored as part of the SMS records. Panasonic shall use lessons learned in the implementation of the SMS to modify these procedures and migrate them into this SMS manual.

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5.6 Site evaluations Site-Evaluations (SMP-004) are used to ensure that the structure of the SMS is sound. This process also measures the knowledge, skill and attitudes of the personnel through the interview process. The protocol for conducting a site-evaluation should be no different from a system audit. Site-Evaluations will be recorded on a SMF-004 form. The overall scope of a site-valuation shall include:

Levels and accountability of staff for safety. Compliance with SMS hazard/risk evaluation procedure. Adequacy of staff training for their technical/SMS roles. Measure the effectiveness of SMS training.

5.7 SMS audits Annual SMS audits (SMP-005) are used to ensure that the structure of the SMS is sound. The protocol for conducting a SMS audit (from planning to final corrective action closure) should be no different to any other system audit. SMS audits will be recorded on a SMF-005 form. The overall scope of a SMS Audit shall include:

Levels and accountability of staff for safety. Compliance with SMS hazard/risk evaluation procedure. Adequacy of staff training for their technical/SMS roles. Availability of safety performance targets and indicators.

A SMS Audit may be conducted by a single individual or a team, depending on the scope of the audit. The QA auditors that conduct an audit should have practical experience in disciplines relevant to the area being audited and a good knowledge of the relevant regulatory requirements and the company’s SMS. They should also have been trained in auditing procedures and techniques. 5.8 Safety culture surveys The Safety Culture Survey SMF-127 may be employed as a complimentary procedure to SMS Audits for examining particular elements, processes or a specific operation for any potential hazard/risk. Such targeted safety surveys may be initiated in view of information feedback or voluntary/confidential reports involving issues as:

Problem area or bottlenecks in daily operations. Perceptions and opinions about personnel’s actions with possible safety

implications. Poor teamwork and cooperation between employee groups or departments

(especially involving safety/operational/technical functions). Areas of dissent or perceived confusion (especially involving

safety/operational/technical functions). Unsafe working procedures or conditions.

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6 Emergency Action planning 6.1 Emergency Action Plan

The purpose of the emergency action plan is to outline actions required by the organization in the event of a major safety related incident or accident resulting in an emergency or crisis situation.

• Planned actions to minimize indirect or consequential damage upon the occurrence of a crisis or emergency situation.

• Provision to preserve/modify product/services/equipment to avoid subsequent

safety/quality/continuity problems.

• Recovery actions and procedures for continued normal operation.

• Assignment of emergency roles & responsibilities.

• Selection & authorization of key personnel for actions contained in the plan.

• Co-ordination of procedures with customers or operators.

Criteria for safe continuation of operations or return to normal conditions 6.2 Emergency Action Plan web page

For Emergency Action Plans go to; https://iweb.panasonic.aero/employee-gateway/employee-centre/safety-security/emergency-procedures- then click on Safety & Security – then scroll to Emergency Action Plans and choose your facility.

https://iweb.panasonic.aero/employee-gateway/employee-centre/safety-security/emergency-procedures

https://iweb.panasonic.aero/employee-gateway/employee-centre/safety-security/emergency-procedures

global safety management manual (gsmm)

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