Advisory Circular (AC) No. 107-001

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Guidance on Safety Management Systems Development

Table of Contents

10.0 COMPONENT 6 - EMERGENCY RESPONSE PLAN

10.1 General

  1. Emergency planning should aim, where possible, to prepare an organization in the event that an emergency situation occurs. This preparation should, through good planning, reduce, control or mitigate the effects of the emergency. It is a systematic and ongoing process, which should evolve as lessons are learnt and circumstances change.

  2. Emergency planning should be viewed as part of a cycle of activities beginning with the establishment of a risk profile to help determine what the priorities are before developing plans and ending with review and revision.

  3. The maintenance of plans involves more than just their preparation. Once a plan has been prepared, it must be maintained systematically to ensure it remains up-to-date and fit for purpose at any time in case an emergency occurs. In cases where the organization is the holder of multiple certificates or deals with external service providers they may choose to develop a joint emergency plan with a formal set of procedures governing them all. For example, in the event that an aircraft evacuation is required on the manoeuvring area of an airport, the police would need carefully pre-planned co-operation from various other organisations such as fire and ambulance services and the local authority, as well as involvement of others such as passenger transport organisations listed in respective plans.
10.1.1 Who do we plan for?
  1. Plans should focus on at least three key groupings of people - the vulnerable, victims (including survivors, family and friends) and responder personnel

  2. Vulnerable people may be less able to help themselves in an emergency. Those who are vulnerable will vary depending on the nature of the emergency, but plans should consider: those with mobility difficulties (e.g. those with physical disabilities or pregnant women); those with mental health difficulties; and other who are dependent, such as children.

  3. Victims of an emergency – which includes not only those directly affected such as aircrew but also those who, as family and friends, suffer bereavement or the anxiety of not knowing what has happened.

  4. Responder personnel should also be considered. Plans sometimes place unrealistic expectations on management and personnel. Organisations should ensure their plans give due consideration to the welfare of their own personnel. For instance, the emergency services have health and safety procedures, which determine shift patterns and check for levels of stress.
10.1.2 What do we plan for?
Organisations should aim to maintain plans which cover three different areas:
  1. Plans for preventing an emergency - in some circumstances there will be a short period before an emergency occurs when it might be avoided by prompt or decisive action.

  2. Plans for reducing, controlling or mitigating the effects of an emergency - the main bulk of planning should consider how to minimise the effects of an emergency, starting with the impact of the event (e.g. alerting procedures) and looking at remedial actions that can be taken to reduce effects. For example, the emergency services may be able to stem the emergency at source by fighting fires, combating the release of toxic chemicals or the extent of floods. The evacuation of people may be one direct intervention, which can mitigate the effects of some emergencies. Recovery plans should also be developed to reduce the effects of the emergency and ensure long-term recovery.

  3. Plans for taking other action in connection with an emergency - Not all actions to be taken in preparing for an emergency are directly concerned with controlling, reducing or mitigating its effects. Emergency planning should look beyond the immediate response and long-term recovery issues, to the secondary impacts. For example, the wave of reaction to an emergency can be quite overwhelming in terms of media attention and public response. Plans may need to consider how to handle this increased interest.

10.1.3 When do we activate the plan?

As obvious as it may sound, emergency plans should include procedures for determining whether an emergency has occurred, and when to activate the plan in response to an emergency. This should include identifying an appropriately trained person who will take the decision, in consultation with others, on when an emergency situation has occurred.

10.1.4 Why is it important to practice emergency response and to train staff appropriately?
  1. Organisations should test the effectiveness of their emergency plans by carrying out exercises, and should ensure that key staff involved in the planning for or response to an emergency receives appropriate training. Training plans should also consider other people who have a role in the emergency plans such as contractors and volunteer partners. The plans themselves should explicitly identify the nature and frequency of training and exercising required.

  2. The plans are normally evaluated by conducting communication (desk top) exercises that include all aspects of their emergency response plan. These exercises should involve all intervening agencies. An exercise performance report should be created and forwarded to the key agencies in a timely manner.

  3. Operational exercises such as, on board emergency, fuel spill response, fire drill, involving all intervening agencies listed in the plans for a defined scenario should be conducted on a regular schedule to test individual applications or the entire emergency plan.

  4. The emergency response plan should include sections dealing with the conducting of operational exercises such as the following involving the simulated response of one or more specialized agencies:

    1. Specialty exercises;

    2. Minor exercises;

    3. Local exercises;

    4. Other types of exercises as required by regulations specific to the certificate.

  5. The activation of the plan for a real event or an exercise should be followed by a discussion/critique of the incident or exercise.
10.1.5 Plan Coordination
  1. A resource identified in an emergency plan should be available in a timely manner and should have the capability to do their intended function. Restriction on the use of the resource should be taken into account, be reviewed by legal counsel, be signed by a responsible official, define liability and detail funding and cost arrangements. The term “mutual aid agreement” as used here includes cooperative assistance agreements, or other terms commonly used for the sharing of resources.

  2. It is important for plans to be coordinated and integrated to ensure responsible managers are competent in other organisations' roles. As an example, a fuelling operator should provide a copy of their emergency response plan to the aerodrome operator and the airline for which it is operating. The emergency response plan should be updated by the fuelling operator and forwarded to the other operators when there is a change within any of the components of the emergency response plan. The fuelling operator should ensure its emergency response plan is compatible with the airport and airline emergency plan.
10.1.6 Using External Volunteers

Where appropriate, organisations should consider at an early stage in planning whether voluntary organisations might have capabilities, which could assist in responding to an emergency. The voluntary sector can provide a wide range of skills and services in responding to an emergency. These include: practical support (e.g. first aid, transportation, provisions for responders); psycho-social support (e.g. counselling, help lines); equipment (e.g. radios, medical equipment); and information services such as public training and communications). Specialized volunteer groups (e.g. Red Cross, amateur radio, religious relief organizations, charitable agencies can be very helpful in most situations.

10.1.7 Continuous Improvement

Unless specified in the CARs, the plan should be reviewed at least annually and updated as necessary. It should also be re-evaluated when any of the following occur:

  1. Regulatory changes;

  2. New hazards are identified or existing hazards change;

  3. Resources or organizational structures change;

  4. After tests, drills, or exercises;

  5. After disaster/emergency responses; and

  6. Infrastructure, economic, geopolitical changes.
10.1.8 What are incident management and business continuity?
  1. A sound response planning program goes a long way in ensuring that the effect of an event on the certificate holder's business is minimised. The plans should highlight the business continuity elements to educate employees, partners and stakeholders of the necessity for advance planning to allow the resumption of business as soon as safely practicable following an event.

  2. In aviation a single event can impact multiple operations including but not limited to, air traffic control, information technology, military, police, air crews, ground crews, hangar operations, transportation, maintenance, suppliers, engineering, personnel, public relations, medical services, environment, legal, finance, risk management, customs, immigration, food inspection health and safety, security, stakeholders, and fire fighting/rescue.

  3. When determining the inclusion of the above in an emergency plan, consideration should be given to establish a coordinated and cooperative approach to the incident management.

  4. Decisions made and actions taken in the day-to-day administration of the emergency plan crucially affect the ultimate implementation of the incident management system in times of disaster/emergency. Therefore, the plan should be developed in consultation with those persons representing key functional areas.

  5. All planning elements cross boundaries during each of the four phases of disaster/emergency management (mitigation, preparedness, response, recovery). Each element should not be considered independently, but in relation to each of the four phases. For example, an entity might have the appropriate authority to conduct disaster/emergency operational response but lack authority to take action at an event to mitigate the occurrence or assist an operator in the recovery and business resumption plan.

  6. There should be a responsive financial management and administrative framework that complies with the operator's program requirements and is uniquely linked to disaster/emergency operations. The framework should provide for maximum flexibility to expeditiously request, receive, manage, and apply funds in a non-emergency environment and in emergency situations to ensure the timely delivery of assistance. The administrative process should be documented through written procedures. The program should also be capable of capturing financial data for future cost recovery, as well as identifying and accessing alternative funding sources and managing budgeted and specially appropriated funds.

  7. Business continuity planning incorporates both the initial activities to respond to a disaster/emergency situation and the restoration of the business and its functions to pre-disaster levels.

  8. Specific areas to consider in continuity plans include:

    1. Succession to ensure that the leadership will continue to function effectively under disaster/emergency conditions.

    2. Pre-delegation of emergency authorities to ensure sufficient enabling measures are in effect to continue operations under disaster/emergency conditions.

  9. Emergency action steps that facilitate the ability of personnel to respond quickly and efficiently to disasters/emergencies. Checklists, action lists, and/or standard operating procedures (SOPs) have been written that identify disaster/emergency assignments, responsibilities, and emergency duty locations. Procedures should also exist for alerting, notifying, locating, and recalling key members of the entity.

  10. Primary emergency operations centre from which direction and control is exercised in a disaster/emergency. This type of centre is designated to ensure that the capability exists for the leadership to direct and control operations from a centralized facility in the event of a disaster/emergency.

  11. An alternate facility from which direction and control is exercised in a disaster/emergency should the primary centre become unavailable, or should it be determined that the alternate facility is a more appropriate location from which to handle the disaster/emergency.

  12. The measures that are taken by the operator to protect vital records for example, financial, data, passenger lists, personnel records, and engineering drawings for the effective functioning of the organisation under disaster/emergency conditions and to maintain the continuity of operations.

  13. The measures that are taken to disperse resources and personnel in a manner that will provide redundancy to ensure the entity can continue to function during disaster/emergency conditions.

  14. Plans should address deployment procedures to relocate/replicate resources or facilities, increase protection of facilities, and inform and train personnel in protective measures.

10.1.9 Incident Management Facilities

Facilities identified in the plan should be capable of accommodating any combination of essential representatives who are identified in the operator's plan. Facilities should have adequate workspace, communications, and back-up utilities and should meet other basic human needs for each representative. Essential functions include gathering essential information capable of providing centralized direction and control, and warning for response and recovery actions. Facilities should be located so that they are not impacted by the same event.

10.2 How do you know if your SMS is working?

Component 6 - Emergency Response Preparedness Yes/No
The organization has an emergency preparedness procedure, appropriate to the size, nature and complexity of the organization  
The Emergency preparedness procedures have been documented, implemented and assigned to a responsible manager  
The emergency preparedness procedures have been periodically reviewed as a part of the management review and after key personnel or organizational change  
The organization has a process to distribute the ERP procedures and to communicate the content to all personnel  
The organization has conducted drills and exercises with all key personnel at intervals defined in the approved control manual  

11.0 CONCLUSION

  1. The implementation of SMS represents a fundamental shift in the way we all do business. SMS require organizations' to adopt the components and elements detailed in this document and to incorporate them into their everyday business practices. In effect, safety becomes an integral part of the everyday operations of the organization, it becomes, quite simply, the way you do business.

  2. SMS is also being integrated into the international arena with the introduction of International Civil Aviation Organization (ICAO) SMS requirements for all ICAO signatories in January 2009.

  3. For SMS to be a success, however, TC, like the industry we regulate, must undertake numerous changes internally and externally. We have established an internal discipline policy that promotes and rewards the behaviours we are striving to achieve. Likewise we have made changes to the external enforcement policy to promote this within our stakeholders

  4. Fundamental to the SMS journey is the development of a robust yet flexible regulatory framework that accommodates safety management systems. To facilitate this change TC has introduced performance based regulations and has adopted a framework for SMS that obliges the industry to acquire an improved capacity to assure for itself that it is safe and compliant, and TC has new expectations related to this capacity.

  5. Accordingly, TC has made changes to the system of oversight to accommodate this. In the future, the regulator will oversee the effectiveness of the SMS and withdraw from the day-to-day involvement in the companies it regulates. Interventions will focus on the systems in place to manage the organization's operations and the outputs of the system, rather than assuring line-by-line adherence to the regulations through forensic auditing. It is the responsibility of the organization to identify the day-to-day issues operational issues.

  6. The operator must have effective programs in place to discover, analyse and correct safety issues, with minimal intervention at the operational level from TC. This shift does not constitute self-regulation nor does it represent an abrogation of the role of the regulator for the oversight of the Civil Aviation system. It represents an opportunity for organization's to work in conjunction with TC to demonstrate compliance within a performance-based framework. Organization's will be required to involve TC when issues are identified through their SMS. This will provide TC with an awareness that the organization's SMS is working effectively.

  7. The success of the system will hinge on the development of a safety culture that promotes open reporting, through the adoption of safety reporting policies and continual improvement through, proactive safety assessments and quality assurance.

  8. The SMS philosophy requires that responsibility and accountability for safety be retained within the management structure of the organization. The accountable executive and senior management are ultimately responsible for safety, as they are for other aspects of the enterprise. The responsibility for safety, however, resides with every member of the organization; in safety management, everyone has a role to play.

12.0 CONTACT OFFICE

For more information please contact:
Technical and National Programs (AARTM)

Phone: 613-952-7974
Facsimile: 613-952-3298
E-mail: boothbj@tc.gc.ca
 

Suggestions for amendment to this document are invited and should be submitted via the Transport Canada Civil Aviation Issues Reporting System (CAIRS) at the following Internet address:

http://www.tc.gc.ca/CAIRS.htm

or by e-mail at: CAIRS_NCR@tc.gc.ca

D.B. Sherritt
Director, Standards
Civil Aviation

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