Understanding the 12 Elements of the ICAO SMS Framework – MSAT Oversight

Introduction

While regulated entities (operators, CAMOs, AMOs, aerodromes, ANSPs, design and production organisations) are responsible for developing, implementing, and maintaining these elements, CAs carry the parallel responsibility to ensure each element is present, appropriate to the organisation’s scope, demonstrably operating, and producing effective safety outcomes.

Through MSAT, CAs move beyond compliance monitoring into performance-based oversight, ensuring each element is not only documented but demonstrably embedded into day-to-day operations.

MSAT Framework

The MSAT framework provides CAs with a structured maturity scale—from “Present” through to “Effective”—ensuring assessments are consistent, transparent, and evidence-based.

• Present: Policies or processes exist.
• Suitable: Appropriately tailored to organisational complexity and risk profile.
• Operating: Implemented and in routine use.
• Effective: Demonstrably achieving intended safety outcomes.

For each of the 12 ICAO SMS elements, MSAT requires CAs to identify evidence across all four maturity levels, ensuring oversight is not just about compliance but about measuring systemic resilience.

SME-Level Challenges for CAs

• Ensuring scalability—adapting SMS oversight for both small operators and complex multi-certificate organisations without lowering expectations.
• Maintaining objectivity in high-trust relationships with long-standing certificate holders.
• Driving industry-wide safety culture without prescribing overly rigid one-size-fits-all solutions.
• Integrating MSAT findings into risk-based oversight planning to target resources where they can make the greatest safety impact.

Four Components – Twelve Elements Through the MSAT Lens

Safety Policy and Objectives

CAs must evaluate if the organisation’s safety policy is more than a declaration—it must be measurable, understood, and aligned with resources and governance.

1. Management Commitment and Responsibility
   MSAT Role: Verify senior leadership visibly supports safety objectives through policy endorsement, active involvement, and resource allocation. Confirm the Accountable Executive can demonstrate practical knowledge of SMS outputs and associated obligations.
2. Safety Accountabilities
   MSAT Role: Assess whether roles and responsibilities are clearly documented and whether lines of reporting allow safety concerns to bypass operational or commercial pressure. Review effectiveness during interviews and in real-time operational scenarios.
3. Appointment of Key Safety Personnel
   MSAT Role: Confirm that the Safety Manager (and supporting team) has independence, competence, and authority to act on safety issues without undue interference. Validate competence via training records, experience, and evidence of decision-making impact.
4. Coordination of Emergency Response Planning (ERP)
   MSAT Role: Ensure ERP is harmonised with external stakeholders, tested through realistic exercises, and updated based on lessons learned. MSAT scoring considers both the documentation and the proven interoperability in multi-agency environments.
5. SMS Documentation
   MSAT Role: Review whether manuals and procedures accurately reflect actual practice. Verify change control processes ensure that documented SMS arrangements remain current and auditable.

Safety Risk Management

Here the CA’s role is to validate that hazard and risk processes are proactive, data-driven, and integrated into operational decision-making.

1. Hazard Identification
   MSAT Role: Evaluate the organisation’s hazard reporting channels, the level of employee engagement, and whether hazard data is analysed and acted upon. Effectiveness is judged by the quality of hazard logs and feedback loops to staff.
2. Risk Assessment and Mitigation
   MSAT Role: Ensure risk matrices are fit for purpose and consistently applied. Confirm that mitigation strategies are not only documented but monitored for actual risk reduction, with re-assessment post-implementation.

Safety Assurance

The CA must verify that the organisation has mechanisms to ensure safety performance is maintained and continuously improved.

1. Safety Performance Monitoring and Measurement
   MSAT Role: Validate that SPIs (Safety Performance Indicators) are relevant, measurable, and linked to strategic safety objectives. Assess whether performance monitoring results in timely corrective actions.
2. The Management of Change
   MSAT Role: Check that change management includes formal risk assessments, stakeholder consultation, and post-implementation review. MSAT evaluates both the process and case evidence.
3. Continuous Improvement of the SMS
   MSAT Role: Look for systematic processes that incorporate internal audit results, occurrence trends, and safety surveys into measurable enhancements. Assess whether improvements are documented and communicated organisation-wide.

Safety Promotion

This component underpins the sustainability of the SMS by embedding safety thinking at every level.

1. Training and Education
   MSAT Role: Confirm that training is role-specific, recurrent, and assessed for effectiveness. Verify linkage between training outcomes and operational performance improvements.
2. Safety Communication
   MSAT Role: Evaluate the channels, frequency, and content of safety communications. Verify that messaging is bidirectional—allowing for both top-down and bottom-up safety dialogue.

Next Steps

Please see Sofema Aviation Services (SAS) and Sofema Online (SOL) for Classroom, Webinar and Online Training. For additional information, please email [email protected].

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AMOS, Emergency Response Planning (ERP), Objectives, SME-Level Challenges, MSAT Framework, 12 Elements, MSAT, Policies, ANSPs, Risk Assessment, CAMOs, SMS Documentation, Safety Policy, SAS blogs, Hazard Identification, Safety Risk Management, Safety