The safety management system is a regulation that has 12 elements, so in order to be in compliance with the safety management system the railway will develop everything in place, the proper procedures and the program, in order to meet those 12 elements. But the company can also have its own safety program that could have 20 or 25 elements. That's the difference between the two. One is what is required by regulation. The other one you can expand.
On April 30th, 2014. See this statement in context.