Proposal to improve the interpretation of para. 8.1.6.1.(d) concerning verification that the risk management activity covers and is performed over the entire lifecycle.
Proposal to revise para. 8.1.7.1.(g) to delete “Monitoring is expected to cover both the ADS and the SMS, ensuring a comprehensive view of safety performance.” and insert “Monitoring practices include the monitoring of the ADS product (i.e., using SPIs) and evaluation of the Safety Management System so that it remains effective (i.e., using KPIs).”
Proposal to improve the interpretation of para. 8.1.6.1.(b) concerning verification that the risk-management activity is not limited to the ADS itself but includes risk arising from organisation/people which can affect the SMS effectiveness or the safety of the ADS.