The Surveillance and Evaluation Program (SEP) introduced the system elements and risk indicators to Certificate Holding Offices for all carriers, beginning with "new entrants," those carriers that had been conducting Part 121 service less than five years, and later covering all Part 121 carriers. Tools were developed for Principal Inspectors to assess the overall risk situation of the carrier, document and analyze their observations, and to re-focus the surveillance program toward those areas where the highest risks were perceived. The dotted line on the graphic indicates that, while the ATOS program was not fully implemented, many important system safety features of the system were provided to all Part 121 Certificate Management teams.

The original SEP program was, however, an "overlay" on the traditional surveillance program. The program was still developed in a conventional fashion and "retargeted" at a later time. This resulted in considerable workload and additional complexity for managing the program.