Phase 0 of the Safety Management Systems (SMS) Pilot Project

Transcription

1 Phase 0 of the Safety Management Systems (SMS) Pilot Project The Beginning! 1

2 AGENDA 1. Introductions 2. Overview of SMS 3. The SMS Table 4. Break 5. Use of the SMS Guidebooks 6. Summary SMS Audit/Gap Analysis Tool 5 min 45 min 30 min 15 min 10 min 10 min 7. Detailed SMS Audit/Gap Analysis 8. Pilot Project Implementation Plan 9. Open Discussion Tools 10 min 15 min 40 min 2

3 INTRODUCTIONS 3

4 Overview of Safety Management Systems (SMS) 4

5 Really? At this airline, safety is our first priority 5

6 What is the primary objective of a business organization? 6

7 Safety Management Rationale In order to achieve its production objectives, the management of any aviation organization requires the management of many business processes. Managing safety is one such business process. Safety management is a core business function just as financial management, HR management, etc. This brings about a potential dilemma for management. 7

8 The management dilemma Resources Management levels Resources Protection Production 8

9 Resources The management dilemma Resources Management levels Protection Production Catastrophe 9

10 The management dilemma Resources Management levels Resources Production Protection Bankruptcy 10

11 Safety Space Bankruptcy Protection Catastrophe Source: James Reason Production 11

12 Safety Management The response to the dilemma Safety issues are a byproduct of activities related to production/services delivery. An analysis of an organization's resources and goals allows for a balanced and realistic allocation of resources between protection and production goals, which supports the needs of the organization. The product/service provided by any aviation organization must be delivered safely (i.e. protecting users and stakeholders). 12

13 What is safety? Safety is not equivalent to risk free (U.S. Supreme Court, 1980) Carelessness and overconfidence are more dangerous than deliberately accepted risk (Wilbur Wright, 1901) Practical safety is risk management 13

14 Mitigating to Acceptable Risk Safety in a system may be defined as a quality of a system that allows the system to function under predetermined conditions with an acceptable minimum of accidental loss. System Safety Engineering & Management, 2nd Edition, John Wiley & Sons 1990 ISBN

15 Why SMS? An imperfect system System design Operational deployment Baseline performance Operational performance Practical drift 15

16 Risk Management is. New Info?.a continuous process.a closed loop process.cross discipline Evaluate Hazard Controls Modify Process Manage Risk Identify Hazards Assess Risk Tracking Analyze Hazard(s) 16

17 A Risk Assessment Matrix Example Risk probability Catastrophic A Hazardous B Risk severity Major C Minor D Negligible E Frequent 5 5A 5B 5C 5D 5E Occasional 4 4A 4B 4C 4D 4E Remote 3 3A 3B 3C 3D 3E Improbable 2 2A 2B 2C 2D 2E Extremely improbable 1 1A 1B 1C 1D 1E 17

18 Risk Acceptance Risk is inherent in aviation operations Risk results from aspects of the environment and byproducts of operational activities Operator is responsible for risk management (Title 49 FA Act) A fundamental concept of risk management is acceptance of risk Risk management is fundamental to the SMS 18

19 Four Pillars of SMS Policy: (Structure) Risk Mgmt. Safety Assurance Safety Promotion: (Culture) 19

20 SMS is the toolbox for Policies & management practices Risk Management processes Safety Assurance processes Confidential reporting processes/employee involvement 20

21 What is the Regulator s s Duty? It is NOT safety achievement or management It IS safety oversight 21

22 What is the Provider s s Duty? Safety achievement is the responsibility of the provider The FAA s s resources are best applied in assisting / enabling safety management by the business or operation 22

23 Is ATOS the same as SMS? ATOS OS: : An Oversight System used to fulfill FAA safety responsibilities SMS: : A Management System used to fulfill operator safety responsibilities 23

24 ATOS and SMS FAA (ATOS) Oversight Program Management (8 Modules) DA PA Protection Objective: Public Safety FAA s Safety Management System (SMS-O) Direct sampling (e.g. surveillance) Production Objective: Serve customer requirements S R M S A Operator s Safety Management System (SMS-P) Inputs Process Outputs are Products / Services Air Carrier s SRM/SA Objective: Manage safety actions as part of business processes 24

25 SMS for Providers is a top-down program starting with Top Management 25

26 A SMS Organization Develops a Just Culture or Safety Culture to: Capture the operational knowledge and experience of the employees Involve the employees in the safety achievement process 26

27 A Positive Safety Culture is An informed culture where People understand hazards and risks. Staff work continuously to identify and overcome threats A reporting culture where People are encouraged to voice safety concerns Those concerns are analyzed and appropriate action is taken The workforce knows and agrees on what is acceptable and unacceptable (shared values) Dr. James Reason 27

28 A Positive Safety Culture is A learning culture where: People are encouraged to develop and apply their skills and knowledge to enhance organizational safety Management updates staff on safety issues Safety reports are fed back to staff so everyone learns A just culture where: The workforce knows and agrees on what is acceptable and unacceptable (shared values) Errors are understood but willful violations are not tolerated 28

29 What s s in a Just Culture? The immediate response is to find what happened and why, not who to blame and punish Acceptance that more can be learned through full reporting and detailed investigation than by blame and punishment Partnership in identifying hazards and root causes 29

30 SMS SMS emphasizes Risk Management It integrates safety with Line Management 30

31 The International Picture ICAO safety management requirements Annex 11 - Air Traffic Services Annex 14 - Aerodromes Annex 6 - Operation of Aircraft Annex 6 - Maintenance of Aircraft 31

32 ICAO Annex 6 Requirements a a safety management system acceptable to the State of the Operator that, as a minimum: identifies safety hazards; ensures that remedial action necessary to maintain an acceptable level of safety is implemented; and provides for continuous monitoring and regular assessment of the safety level achieved. and, aims to make continuous improvement to the overall level of safety (proposed amendment) 32

33 Annex 6 requirements (cont.) An accepted safety management system shall clearly define lines of safety accountability throughout the operator s s organization, including a direct accountability for safety on the part of senior management. 33

34 An Industry Answer? ICAO, FAA, overseas Regulators, Air Carriers, ALPA, IATA, IBAC SMS Launching a common idea and a new approach: 34

35 FAA Support of the SMS Concept U.S. Response to the Annex 6 proposal endorsed the SMS concept Prior U.S. implementation of system safety-based oversight systems ATOS SASO FAA (AVS) will also apply safety management concepts to oversight activities 35

36 The SMS Standard First FAA SMS standard was delivered on June 22, 2006 in Advisory Circular AC SMSs are currently voluntary in the United States The standard is organized around the four pillars The standard is based on an extensive review of existing SMSs around the world The format of the SMS standard is similar to that of the ISO standards 36

37 Rulemaking Effort Part 121 Rulemaking Project Record (RPR) opened Nov Project cancelled Jan Project team commissioned to create integrated SMS Rule for all CFR parts Objective: harmonization of requirements Strategy is being formulated ARC is a possibility 37

38 Testimonials Why didn t t TC do this years ago? (705 Operator) We are now much more aware of our safety responsibilities and liabilities. (AMO) My employees are involved in developing the SMS processes. They tell me they feel safer at work. (small AMO) It is too early to realize all the benefits of SMS, but already employees and customers have an increased confidence in the company. (AMO) Already we are seeing the benefits of recording and tracking incidents and hazards (FTU) The idea of SMS is much scarier than the actuality. (702,703 Helicopter Operator). 38

39 Others Air Transat initially saved over $1 million per month Skyservice saved $5 million in first year of SMS operation 39

40 The SMS Table 40

41 The SMS Table (Side View) 2006 The MITRE Corporation. All Rights Reserved. 41

42 The SMS Table (Top View) Internal Eval The MITRE Corporation. All Rights Reserved. 42

43 External Audit Are policies, procedures, and organizations appropriate? External Audit Is there a safety culture? Is there adequate training & communication? The SMS Table (Top View) External Audit Are data sources accurate, complete and timely? Internal Eval. Operational Data Employee Reports Change Management System & Task Analysis External Audit Are risk mitigations effective? When not, is the risk re-introduced into SRM for re-analysis? External Audit Are risk mitigation strategies appropriate? External Audit Is there a Voluntary Reporting System? External Audit Are all hazards identified? External Audit Are identified hazards analyzed correctly? 2006 The MITRE Corporation. All Rights Reserved. 43

44 The SMS Table (Top View) External Audit Are policies, procedures, and organizations appropriate? External Audit Are data sources accurate, complete and timely? Internal Eval. External Audit Are risk mitigations effective? When not, is the risk re-introduced into SRM for re-analysis? External Audit Is there a safety culture? Is there adequate training & communication? External Audit Are risk mitigation strategies appropriate? External Audit Is there a Voluntary Reporting System? External Audit Are all hazards identified? External Audit Are identified hazards analyzed correctly? 2006 The MITRE Corporation. All Rights Reserved. 44

45 BREAK 45

46 SMS Implementation and Tools 46

47 SMS Guidebooks The purpose of the Guidebooks is to provide a framework and offer developmental guidance to aid organizations in defining their organizational safety structure. 47

48 Format of the Guidebook (OBJ) are objectives. This information describes or outlines what you will be expected to develop in this specific area of your Safety Management System documentation, in order to meet an SMS standard. (STD) are standards. This is the specific language of the standard that the organization will be held to in order to meet the statement of requirements conveyed in the policy/procedure section. (DG) is developmental guidance This provides instruction regarding how you can develop your policy, procedures, and controls to address each specific requirement of the Safety Management System. 48

49 Example Section of the Guidebook 4.4 Safety Planning (OBJ) The expectation of this section is that you describe your safety management plan to meet the objectives described by your above stated safety policy Safety Planning (STD) - FAA Advisory Circular AC Appendix 1 The organization shall establish and maintain a safety management plan to meet the safety objectives described in its safety policy. (DG) Management has historically been defined as planning, organizing, directing, and controlling. Therefore a Safety Management System will start with a plan to meet the Safety Objectives. A plan should be set by Top Management that will direct and sequence the implementation of the Safety Management System. Planning at one level becomes direction at the next level. The first thing to plan is how much and on what time table the various portions of the Safety Management System will be created, who will be responsible for the overall system and the various portions of it. 49

50 Summary Audit/Gap Analysis Tool High level assessment tool To be utilized for initial screening or audit summary Questions at the objective level Evaluates the organization s s existing systems to determine conformance to the SMS standards 50

51 Summary Audit/Gap Analysis Tool Evaluate Objectives utilizing assessment scales Measure the level of development for each objective 0 No action 1 Action initiated 2 Implemented 3 Integrated 4 Evaluated and Sustained 5 State of Art 51

52 Summary Audit/Gap Analysis Tool No action = 0 Action initiated=1 Implemented=2 Integrated=3 Evaluated and Sustained=4 State of Art=5 52

53 Audit/Gap Analysis Tools Detailed assessment of the organization s s existing systems to determine conformance to the SMS standards Used to determine what needs to be developed After implementation, to assess continued performance of the system Final gap analysis prior to implementation planning must be based on the full set of tools to ensure that all of the standard's requirements are included in the system design 53

54 Audit/Gap Analysis Tools System 8.0 of the Air Transportation Oversight System (ATOS): Includes the SMS pillars as subsystems 8.1 Policy 8.2 Safety Risk Management 8.3 Safety Risk Assessment 8.4 Safety 13 Design Assessment Tools based on major sub-clauses of the Standard 54

55 Audit/Gap Analysis Tools Organizational Management Documentation and Records Management Emergency Preparedness and Response System and Task Analysis Hazard Identification Safety Risk Analysis and Assessment Safety Risk Controls Data Acquisition Data Analysis and System Assessment Corrective and Preventive Action Communication and Awareness Personnel Qualifications and Training 55

56 Detailed Audit/Gap Analysis Tools Utilizes ATOS SAI format Has a stated functional objective - expectations and outcomes Questions in the procedures section of each element are based on specific requirements in the standard Requirements evaluated utilizing assessment scales and scales measure the level of conformance with each requirement 0 No action 1 Action initiated 2 Implemented 3 Integrated 4 Evaluated and Sustained 5 State of Art 56

57 Example: Design Assessment Tool 57

58 Example: Design Assessment Tool: Detail 58

59 Standard and Audit/Gap Analysis Tools Phase Standard Audit Tool* Safety Management System 8.0 Safety Management System 4. Policy 8.1 SMS Management 4.1. General Requirements Organizational Management 4.2. Safety Policy Organizational Management 4.3. Quality Policy Organizational Management 4.4. Safety Planning Organizational Management 4.5. Organizational Structure and Responsibilities Organizational Management 4.6. Compliance with Legal and Other Requirements Organizational Management 4.7. Procedures and Controls All 4.8. Emergency preparedness and Response Emergency Response 4.9. Documentation and Records Management Document and Records Management 5. Safety Risk Management 8.2 Safety Risk Management 5.1. System and Task Analysis System and Task Analysis 5.2. Identify Hazards Hazard Identification 5.3. Analyze Safety Risk Risk Analysis and Assessment 5.4. Assess Safety Risk Risk Analysis and Assessment 5.5. Control Safety Risk Risk Control 5.6. Operational Risk Management (Proposed) Operational Risk Management (Proposed) 5.7 Management of Change (Proposed) 6. Safety Assurance and Internal Evaluation 8.3 Safety Assurance 6.1. General Requirements Data Analysis/System Assessment 6.2. System Description System and Task Analysis 6.3. Information Acquisition Data Acquisition 6.4. Analysis of Data Data Analysis/System Assessment 6.5. System Assessment Data Analysis/System Assessment 6.6. Preventive/Corrective Action Preventive/Corrective Action 6.7. Management Reviews Data Analysis/System Assessment 6.8. Continual Improvement Organizational Management 7. Safety Promotion 8.4 Safety Promotion 7.1. Safety Culture All 7.2. Communication and Awareness Communication and Awareness 7.3. Personnel Requirements (Competence) Personnel Qualification and Training 7.4. Training Personnel Qualification and Training 7.5. Safety Lessons Learned Data Analysis/System Assessment Communication and Awareness 59

60 SMS Pilot Project A set of confirmatory trials that consist of voluntary SMS development and interface with oversight systems The purpose is to gather data to be used in further development of guidance material, implementation strategies, and oversight systems 60

61 Industry & FAA SMS Implementation Should follow a phased approach The processes underlying the four pillars will be modularized Growth or increasing maturity will then be emphasized for each process and the system as a whole 61

62 SMS Implementation Process 4 Continuous Improvement 3 Proactive Processes 2 Reactive Processes 1 Planning & Organization 0 Orientation & Commitment 62

63 Purpose and Methodology of SMS Phased implementation: a logical process for building the SMS Management capability: Each step in the model will increase and strengthen management capability Process based upon ICAO recommendations and Capability Maturity Model (CMM) concepts 63

64 Who s s Involved in Implementation? The Operator The Certificate Management Organization (CMO, FSDO, CHDO) The Standardization and Assistance Team (SAT) 64

65 Level Zero: Orientation and Commitment Outreach presentations Understanding what s s ahead Establishing the relationship Securing the commitment from top management 65

66 Level 1: Planning & Organization Charting the Course The Gap Analysis: Evaluating existing processes, programs, and practices for safety management The Implementation Plan Organizing for Implementation 66

67 Level 1 - Meetings Session 1 (Today) SAT to Brief: SMS Process Map SMS Objectives Summary Audit/Gap Analysis Tool Detailed Audit/Gap Analysis Tools Jointly Perform Summary Gap Analysis Schedule Operator s s Gap Analysis Out Brief The operator may require 4 to 6 months to complete the detailed gap analysis. SAT and CMT will be available on call while the operator is performing this task. 67

68 Level 1 - Meetings Session 2 Operator to Brief: Overview of their Gap Analysis Gaps found and how they may develop processes to close the gaps. Operator to Discuss Documentation Operator to present objective evidence of conformity Operator to Identify Resource and Training Needs SAT may provide additional training if necessary as a result of this discussion. SAT to Brief on Planning Process Schedule for Operator s s SMS Implementation Plan Out Brief The operator may require 2 to 4 months to complete the detailed implementation plan development. Estimated time for this session is one day of presentation of gap analysis by the operator. Half to one day of SAT presentation and discussions of the planning processes. 68

69 Level 1 - Meetings Session 3 Operator s s Presentation of Implementation Plan Detailed presentation and discussion of their SMS implementation plan involving the operator, CMT and SAT Consensus on Plan Agreement on the implementation plan among operator, CMT and SAT Exit Level 1 Agreement among operator, CMT and SAT that the participant is ready to move the next phase of the pilot project. Estimated time for this session is one day of presentation by the operator. 69

70 Level 1 Completion Criteria Identify and assign safety responsibilities to managers. 1.1 Management commitment and responsibility (4.2B, 4.5A, 4.5B) 1.2 Safety responsibilities of managers (4.5D, 4.1) Identify the person responsible for implementing the SMS. 1.3 Appointment of key safety personnel (4.5C) Describe the system. 1.4 SMS implementation plan (4.4, 4.1) Conduct a gap analysis of existing resources compared to SMS requirements. 1.4 SMS implementation plan (4.4) Develop an SMS implementation plan. 1.4 SMS implementation plan (4.4) Develop documentation relevant to safety policy and objectives. 1.6 Documentation (4.9) Develop and establish means for safety communication. 4.2 Safety communication (7.2) Communicate the SMS implementation to all employees. 4.2 Safety communication (7.2) Develop an initial training plan for all employees. 4.1 Training and education (7.4) 70

71 Level 1 Assessment Criteria The assessment will be accomplished using the Audit/Gap Analysis Tools below: Organizational Management Document and Records Management Communication and Awareness Personnel Qualification and Training All questions on these tools should achieve a score of at least 1, as defined on the next slide. All individual questions receiving less than a score of 1 will be reviewed by the Participant, the CMO and the SAT for creation of a mutually agreeable solution. 71

72 Level 1 Assessment Scale SAI Assessment Scale Score Assessment Word Picture 0 No Action No action has been taken on this requirement of the standard. 1 Action Initiated Identifiable actions have been taken to satisfy this requirement of the standard. All responsibilities, processes and procedures are documented. However, the implementation of those defined actions is not complete. Example: Section 2, Question 1. Does the operator have a control or controls in place to ensure that all SMS processes are documented, monitored, measured, and analyzed? To achieve a score of 1, the Participant must have policies and procedures defined and written on how the process will be monitored, measured and analyzed, but does not have to have taken any actions to actually do the monitoring, measuring or analysis. 72

73 Level 1 - Documents Management Commitment Letter Management responsibilities defined Safety Policy and Objectives Safety responsibilities for managers defined Results of Gap Analysis for the department/area under the Pilot Program SMS Implementation Plan for the entire organization All Employee Letter or equivalent advising employees of the SMS implementation SMS Training Plan for all employees 73

74 Level 1 - Expectations Development Partner Sessions 1 Complete summary gap analysis Session 2 Completed detailed gap analysis utilizing the detailed audit/gap analysis tools for Level 1 Brief gap analysis results Brief gaps and how they will be addressed Provide evidence of conformity Session 3 Present implementation plan Complete the required documents Meet the requirements of the exit criteria for this phase Provide process inputs to the SAT 74

75 Level 1 - Expectations Oversight Organization Review and utilize (if desired) audit/gap analysis tools Attend audit/gap analysis meetings with the operator Participate in meetings with the SAT and operator Review the operators implementation plan and other documents Discuss the requirements of the exit criteria for this phase with the operator and SAT Provide input to the SAT regarding the SMS implementation, documents and audit tools 75

76 Level 1 - Expectations SAT All Levels Provide assistance, as requested, to the Development Partner and its Oversight Organization throughout the Pilot Project period. Participate in meetings with the CMT and operator, if requested Review the operators implementation plan and other documents Discuss the requirements of the exit criteria for this phase with the operator and CMT Receive Pilot Project inputs from the Development Partner and Oversight Organization Report on summarized data gathered from the Pilot Project 76

77 Level 2: Reactive Processes Basic Risk Management Setting up the information infrastructure and processes Going after known problems: Reactive Hazard Identification Designing and implementing risk controls Documentation Training General initial training Specialist training 77

78 Level 2 Completion Criteria Implement safety risk management (SRM) for reactive processes. 2.1 Hazard identification process (5.2) 2.2 Risk assessment and mitigation processes (5.3, 5.4, 5.5) 2.3 Internal safety investigations (6.3.5) Perform training relevant to SMS implementation plan and SRM components. 4.1 Training and education (7.4) Develop documentation relevant to SMS implementation plan and SRM components (reactive processes). 1.4 SMS implementation plan (4.4) 1.6 Documentation (4.9) Initiate a non-punitive voluntary employee reporting system. (6.3.6, 4.2B5) 78

79 Level 2 - Documents Processes and procedures for operating the SMS to the level of assessment and actions reactively Voluntary employee reporting program 79

80 Level 2 Audit/Gap Analysis Tools Document and Records Management Emergency Response Hazard Identification Risk Analysis and Assessment Risk Control Data Acquisition Data Analysis/System Assessment Preventive/Corrective Action Communication and Awareness Personnel Qualification and Training 80

81 Level 3: Proactive Processes Looking Ahead System and task analysis of the operational (production) systems Proactive Hazard identification Updating: the risk controls Updating the documentation Additional specialist training 81

82 Level 3 Completion Criteria Implement safety risk management for proactive and predictive processes. 2.1 Hazard identification process (5.2) 2.2 Risk assessment and mitigation processes (5.3, 5.4, 5.5) 2.3 Internal safety investigations (6.3.5) Perform training relevant to proactive and predictive processes. 4.1 Training and education (7.4) Develop documentation relevant to proactive and predictive processes. 1.4 SMS implementation plan (4.4) 1.6 Documentation (4.9) Perform a system and task analysis for one department (5.1) Incorporate hazards from system and task analysis into SRM ( ) Develop policies and procedures for safety assurance (6.2) Information acquisition (6.3) Analysis of data (6.4) System assessment (6.5) Preventive and corrective actions (6.6) Management reviews (6.7) 82

83 Level 3 - Documents All processes and procedures for operating the SMS. Safety assurance policy and procedures must be documented. 83

84 Level 3 Audit/Gap Analysis Tools Document and Records Management System and Task Analysis Hazard Identification Risk Analysis and Assessment Risk Control Data Acquisition Data Analysis/System Assessment Preventive/Corrective Action Communication and Awareness Personnel Qualification and Training 84

85 Level 4: Continuous Improvement Continued Assurance Mature safety assurance process Analysis of data System performance assessment Corrective/Preventive action: Maintaining the controls Identifying new and emerging hazards Management Reviews: Formal involvement Documentation & Training as required 85

86 Level 4: Continuous Improvement This is the final stage of maturity of the SMS Continuous improvement is based on: Continuous risk management,, and Continuous safety assurance 86

87 Level 4 Completion Criteria Implement an operational safety assurance program (6.x) 3.1 Safety performance monitoring and measurement ( ) 3.2 The management of change (5B4, 5E) 3.3 Continuous improvement of the safety system (6.8, 4.2B2) Develop acceptable level(s) of safety (4.7) Develop safety indicators and targets (4.7) Perform training relevant to operational safety assurance. 4.1 Training and education (7.4) Develop documentation relevant to operational safety assurance. 1.6 Documentation (4.9) 87

88 Level 4 - Documents All SMS program documents that have been previously developed should be reviewed to ensure that any changes, amendments or maturity in the processes or procedures have been appropriately documented. 88

89 Level 4 Audit/Gap Analysis Tools Organizational Management Document and Records Management Data Acquisition Data Analysis/System Assessment Personnel Qualification and Training 89

90 Interfaces and Integration Regulatory Oversight ATOS Safety Assurance CASS IEP Employee Reporting ASRS ASAP Compliance and Enforcement: Interfaces VDRP EDT 90

91 Voluntary Implementation of SMS Advisory Circular has been Drafted Process Based on AC Interim Solution while rulemaking is ongoing Award System Bronze: Maturity Level 2: Risk Management Program Silver: Maturity level 3: SMS (provisional) Gold: Maturity Level 4: SMS 91

92 Draft AC 120-XX Contents Description of Levels Implementation Process Gap Analysis Tool Functional Objectives Maturity Rating Cross Reference to Detail Design Assessment Tools Cross Reference to ICAO Framework 92

93 SMS Pilot Projects Phase 2: 4 Continuous Improvement Experience 3 Proactive Processes 2 Reactive Processes 0 1 Orientation & Commitment Planning & Organization Phase 1: Readiness 93

94 Summary Phased implementation of SMS Four levels plus a zero level Approximate three-year estimated time to complete Integration of existing programs encouraged SMS Pilot Projects underway to refine: Oversight practices and interfaces Implementation strategies SMS gap analysis and system assessment tools provided Additional guidance and advisory material being developed 94

95 Are we done yet? Aviation systems are open systems that operate in a dynamic rapidly changing environment Safety management is, therefore, never done Continuous improvement is based on continuous risk management and assurance 95

96 CONTACT INFORMATION Dr. Donald N. Arendt, Manager AFS-940 Suite Aviation Drive Dulles, VA (703) Keith D. DeBerry FAA, AFS-940 Suite Aviation Drive Dulles, VA (571) Bill Jarrott Lead System Engineer The MITRE Corporation 7515 Colshire Drive McLean, VA (703)

97 OPEN DISCUSSION 97