2 3  3.2_SMSM_201904  Originally published April 2019  Uncontrolled copy when downloaded The Safety Analysis and Risk Mitigation Process  Section 3  • All charting specification changes prior to submission to the Inter-Agency Air Cartographic Committee for final signature (e.g., symbology, color changes in routes, route identifiers) • Airspace changes, including routes, airways, sectors, and the addition or deletion of a position or sector • Changes to policies, procedures, or NAS equipment for which training exists • Removal of or modifications/waivers to existing national and/or local training requirements that could affect the NAS or NAS operations, except for the purposes of individual performance management • Establishment of or modifications to the Technical Training orders, architecture, and curricula • Changes to the conditions of the assumptions during the SRM process (potential implications to initial risk must be reassessed) 3.2.2  When a Safety Analysis May Not Be Required  3.2.2.1  Overview  Modifications made to systems to meet initial operational specifications (e.g., Problem Trouble  Reports) may not require additional assessments if the system specifications have undergone a  documented safety assessment. The modification and testing processes must also be  compliant with the SMS.  FAA and/or ATO documents (e.g., policies, directives, manuals, Standard Operating  Procedures, Letters of Agreement, Letters of Procedure) for developing and implementing many  routine and repeatable NAS changes could be considered compliant with the SMS, meaning  that SRM was performed, documented, and approved. For example, routine procedures such  as flight inspections are conducted in accordance with FAA Order 8200.1,  United States  Standard Flight Inspection Manual . If there are no changes to those procedures, then a safety  analysis is not required. However, if there is a change to the frequency of flight inspections, a  safety analysis is required.  A safety analysis using the SRM process does not need to be performed for NAS changes that  are compliant with policies/processes that have undergone SRM and have been documented  and approved by the appropriate management official. If these policies or procedures are  changed, or if any NAS change deviates from these policies or procedures, a safety analysis  must be performed using SRM to manage the safety risk. Note that editorial and administrative  changes (i.e., any changes that do not affect the substantive elements of a procedure or  system) do not require SRM.  Not all NAS changes require a safety analysis using the SRM process; there are exceptions. The change proponent must use the criteria in this section and  Section 3.2.1 to make this  determination. 