| Safety Management
System Introduction |
(Last Revision: Nov. 16, 2010)
Risks
It took just over a century of flight for
the arrival to the industry of a comprehensive, systematic,
formal approach to safety. The nuclear power industry, space,
pharmaceuticals, chemicals; they have all embraced SMS for years
due to the obvious inherent risks involved in their operations
that are transmitted to their customers and/or surrounding environment.
Rarely mentioned in aviation advertising are the inherent risks
of flight that cry for mitigation but they are there for you
and me to worry about every time we board an aircraft. Long
overdue, we finally have a risk-based business decision process
that takes management bias out of the equation.
What’s It All About?
ICAO (International Civil Aviation Organization)
through its member states has adopted Annex 6 which requires
each member state to require the implementation of SMS by its
aviation service providers. Very simply, this means States shall
establish a safety program, in order to achieve an acceptable
level of safety in the operation of aircraft. States shall require
as part of their safety program, that an operator implements
a safety management system acceptable to the State of the Operator
that, as a minimum:
-
identifies safety hazards;
-
ensures that remedial action necessary
to maintain an acceptable level of safety is implemented;
-
provides for continuous monitoring and
regular assessment of the safety level achieved; and
-
aims to make continuous improvement to
the overall level of safety.
A A safety management system shall clearly
define lines of safety accountability throughout the operator’s
organization, including a direct accountability for safety on
the part of senior management.
You Can Run but You Can’t Hide
For the first time in aviation history
aviation managerial accountability has arrived. With an adequate
SMS (Safety Management System) fully implemented into an aviation
service provider’s organization as soon to be mandated by the
FAA (Federal Aviation Administration), safety issues will no
longer languish for action due to cost issues or managerial
bias. From any source, when a safety issue arises and enters
the SMS, formal processes take over to manage that issue from
recording it, to risk assessment, to mitigation of risk to an
acceptable level, through follow up ensuring that mitigation
strategies continue to work. No longer will operations with
unacceptable risk be conducted. No longer will known high-risk
hazards be allowed to exist for very long. And that is the crux
of the matter for management accountability. Someone’s name
will be associated with the acceptance of any risk level that
has been formally assigned to any known hazard. And, for that
reason alone, as if there weren’t many good ones, managers must
be careful that the tools they use do the right job in a timely
manner with the hazards that are now tied to them. Managers
must think twice about the quality of their organization’s talents
in SRM (Safety Risk Management), one of the four pillars of
SMS.
SMS in a Nutshell
Dr. Don Arendt, SMS program manager for the
FAA has a simple SMS definition. "It is not a safety program,
it is about decision making and posits safety as part of the
decision-making management process just like any other part
of running a business," the FAA man said. "It has a set of practices
- a policy - that gives it a structure. It is nothing more than
looking at your operation and your environment and finding out
what hazards are there and deciding what you are going to do
about them. The other side of it we call safety assurance, and
we take steps to gain confidence that our processes are working
using evaluating tools like auditing. I investigate where I've
made shortfalls and have a management-review process to make
sure the controls are working."

FOUR PILLARS
OF SAFETY MANAGEMENT SYSTEMS:
-
Safety Policy – Clearly defined policies,
procedures, and organizational structure
-
Safety Risk Management – Formal system
of hazard identification, risk assessment, resource allocation,
and system monitoring v Safety Assurance – Continuous quality
improvement of processes and products
-
Safety Promotion – Continuous communication
of safety values and practices that support a sound safety
culture
NTSB Board Member Robert Sumwalt succinctly
puts SMS in a nutshell with this description of the components
of SMS. He believes "you can make these things as complex as
you want to" but all SMSs are composed of four components.
-
Written policies, procedures, and guidelines
are the standards by which you will conduct your operations.
"You write down what you want to do - how you want to operate
- and then you operate that way," Sumwalt said, a statement
which more than anything else concisely describes what an
SMS should be all about.
-
Data collection and analysis. You need
as many sources of data as possible. An analogy would be
the engine instruments in your airplane, each of which gives
you a piece of information about a parameter within the
powerplants. By analyzing these data, you can determine
what your engines are doing and, to some extent, their condition.
-
Risk management. With data in hand, you
can define your risks and set policy and procedures to mitigate
them. For example, you might set company minimums for nonprecision
approaches that exceed the published examples or set a rule
not to operate into fields with runways less than, say,
5,000 feet.
-
Establishment of a safety culture where
people do the right thing even when they aren't being watched.
Reporting of mistakes, incidents and perceived risks into
the data collection mechanism is an essential part of the
safety culture, and open disclosure without fear of retribution
must be encouraged and protected. The safety culture has
to begin with upper management and be promoted and supported
down through the company.
The FAA's Arendt believes that the SMS concept
is "overrated in terms of complexity." It can be either a complicated
process or simple and straightforward, he said, "and the latter
is what we are trying to make it. Document your process accurately,
but don't over-document it. It is all about decision making.
Collect the information you need to make good decisions and
use it. Have repeatable processes." These goals are not simple
to accomplish for established companies with long-held management
concepts and biases. This is a relatively new way of doing business,
of conducting management of a business and the climate in which
it flourishes is open, honest and transparent with risk-based
decision-making. To borrow a concept from Southwest Airlines;
in a climate where all employees feel empowered to “do the right
thing,” safety can flourish.
CHARCHARACTERISTICS OF A SYSTEMS APPROACH
TO SAFETY MANAGEMENT:
-
Assign responsibility and authority to
individuals tasked with the accomplishment of safety action
v Provide clear instructions to members of the organization
-
Establish interfaces between individuals
and organizations to facilitate safety action v Establish
measurements of processes and products of the system
-
Establish organizational controls to ensure
system output accomplishes the intended objective
Advice for Safety Managers
Keep SMS implementation as simple as you can,
cover the basics before you embark on ambitious goals. Crawl
before you walk; walk before you run and get a good head start
before you takeoff for the clouds. Start simple and small with
manageable implementation phases one at a time, at your own
pace, within your budget, with the people you have. Make your
tools work for you; not the other way around. Take it one step
at a time and you’ll get there. The concept of the Internal
Evaluation Program is based on the premise of verifying compliance
with safety regulations in accordance with FAA HBAT 99-19 and
Advisory Circular 120-59.
For more information on how your company can
quickly gain these advantages, please
email one of our Senior Consultants to find out more
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