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.
Whats 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 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 Cant 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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