Cayman Islands State Safety Programme

Introduction to the Safety Programme

CAYMAN ISLANDS STATE SAFETY PROGRAMME BRIEF

AJLR/10/01/2016

This brief serves to introduce the Cayman Islands State Safety Plan which is attached to this document. Together with the Cayman Islands Safety Policy and the State Safety Plan (SSP) document this brief is available in hard-copy, electronic version and on the CAACI web site.

The document is offered for consultation and any comments, suggestions or recommendations would be gratefully received by 31st March 2016.

ICAO Annex 19, Safety Management Systems, first published in July 2013 and effective from 14th November 2013 requires that each State develops an SSP designed to manage safety within the State in order to achieve an acceptable level of safety performance (ALoSP) in civil aviation.

The SSP established by the State is to be commensurate with the size and the complexity of its aviation activities.

Contracting states are required to implement a fully effective SSP by 31st December 2019.

In normal ICAO usage, the word “State” refers to the Contracting State which in this instance would be the United Kingdom. However, bearing in mind that an SSP is to be commensurate with the size and the complexity of its aviation activities it is clear that the UK’s State Safety Programme would not only be significantly different from that of its Overseas Territories but it might also be inappropriate. Consequently, it has been decided that each OT will be responsible for producing its own, bespoke, SSP which will be attached to the UK document to demonstrate how the UK and the OTs meet their safety obligations. The process of developing individual SSPs within the OTs to meet the 2019 deadline is being coordinated by Air Safety Support International (ASSI).

ICAO Annex 19 (page 1-3) defines an SSP as:
“an integrated set of regulations and activities aimed at improving safety”

The content of an SSP is described in detail in the supporting ICAO Doc 9859. Chapter 4 of Doc 9859 identifies the four component parts of an SSP with each part comprising a number of elements as follows:

4.1 State Safety Policy and Objectives
4.1.1 State safety legislative framework
4.1.2 State safety responsibilities and accountabilities
4.1.3 Accident and incident investigation
4.1.4 Enforcement policy

4.2 State Safety Risk Management
4.2.1 Safety Requirements for the service providers’ SMS
4.2.2 Agreement on the service providers’ safety performance

4.3 State Safety Assurance
4.3.1 Safety Oversight
4.3.2 Safety data collection analysis and exchange
4.3.3 Safety-data-driven targeting of oversight of areas of greater concern or need

4.4 State Safety Promotion
4.4.1 Internal training, communication and dissemination of safety information
4.4.2 External training, communication and dissemination of safety information

The above is but an overview of the content and ICAO requires considerable detail to satisfy each individual element.

In order to satisfy each element, briefly identified above, several requirements must be met. These are also outlined in Chapter 4 of Doc 9859 and were used in July 2014 as the basis for a gap analysis to identify the current status of the Cayman Islands safety management infrastructure. The current version of the initial gap analysis (updated in December 2015) is contained at Appendix C to the Cayman Islands’ SSP document. The purpose of the gap analysis was simply:

  • to establish where the Cayman Islands met the ICAO criteria in relation to an SSP and;
  • to identify the areas that remained to be addressed.

Thereafter, it has been necessary to establish a work programme which will enable the Cayman Islands to be fully compliant by the deadline and to allocate the necessary trained resources to achieve this target.

ICAO has recommended a four-phase implementation programme which is based on the logical development of the framework required to support the increasing detail and complexity of the SSP.

It should be noted that the content of the four phases of implementation are not necessarily synonymous with the four components described in paragraph 4.

Whilst it may be necessary or appropriate for the CAACI to modify the phases of implementation and even the timetable, it would probably be beneficial to follow recommendation as closely as possible because:

  1. ICAO will have given considerable thought to the logical progression towards implementation.
  2. It is likely that ASSI and the other OTs will be following a similar timetable and Cayman may be able to benefit from the shared experience.

Following the completion of the gap analysis it was established that some elements were in place, some were partially in place whilst many had yet to be addressed. In the gap analysis summary the elements in place were identified in green, those partially in place in orange and those yet to be addressed, in red.

The reference numbers are from ICAO Document 9859 Edition 3 and the numbers in brackets, immediately preceding the text represent ICAO’s recommended implementation phase.

Currently, it is anticipated that Phase 1 will be complete by 31st March 2016 and work has already commenced on Phase 2 with an expected completion date for all constituent elements by 31st March 2017.

Although the natural progression for the implementation of ICAO SARPS is via the Regulator it will be appreciated that the responsibility for meeting Annex 19 compliance is a joint one.

The completion of Phase 2 and subsequent phases to meet the requirement for a fully effective SSP by 31st December 2019 will require the support of and input from not only the CAACI but also its industry partners across the globe. Consequently, specific requests for information will be generated in the near future and an early response to those requests would be appreciated to allow the programme to stay on schedule.