We’re often asked where certain information should live in an operator’s documentation.
Typical questions include:
- Should Human Factors and Non‑Technical Skills (HFNTS) procedures be included in the exposition or operations manual, or documented elsewhere?
- Does all HFNTS material need to be in one document?
- What if our HFNTS procedures already exist in another manual or system?
The short answer: don’t get too hung up on where things sit.
The intent of the rules is effective safety outcomes.
The focus should be on having effective, usable procedures that suit the size and complexity of your operation – not on creating perfect or idealised documents – especially during the transition to the new rules.
If your procedures are being used, understood and followed, you are already well on your way.
Understanding the role of different documents
First, it helps to brush up on the different roles your documents play:
- Your exposition or operations manual explains how you meet your regulatory obligations. It demonstrates compliance.
- Supporting manuals and procedures (such as training materials, reporting forms, or risk assessments) provide the detail people use in practice.
These documents don’t need to repeat each other. In fact, they work best when they reference and link to one another.
So where should your HFNTS procedures sit?
As a general guide, your HFNTS training and assessment program could be either:
- integrated through various chapters within your existing manual or exposition
- presented as a separate section in your exposition
- a separate manual for easier control of the content.
Detailed, day‑to‑day procedures (such as lesson plans, assessment tools, or training delivery arrangements) can sit elsewhere, such as:
- training manuals or systems
- operational guidance
- supporting procedures used by staff.
Your HFNTS program can directly inform the human interface for training needs, procedures and equipment design.
If your HFNTS procedures already sit within your draft SMS or another manual, don’t panic! There is no expectation that you restructure your documentation purely to match an ideal format. You can evolve your documentation over time in ways that make sense for your operation.
A quick self-check
Regardless of where procedures are documented, ask yourself:
- Are the required HFNTS processes in place?
- Do they suit the size, complexity and nature of my operation?
- Are people using them?
If the answer is yes, you’re on the right track.
The key takeaway
Effective systems and compliant documentation go hand in hand.
The rules require you to have a documented HFNTS program, but this is only meaningful if it accurately describes what you do in practice. So start by getting your training in place – then make sure your documentation reflects it clearly and accurately.
To learn more read Advisory Circular AC 119-12 Human factors principles and non-technical skills training and assessment for air transport operations.
