Effective risk management depends on strong rules and not cutting corners
SMS promises lower loss rates, but safety culture is a prerequisite to success and key to achieving future goals.
By Don Van Dyke
ATP/Helo/CFII. F28, Bell 222
This US-registered Hawker Siddeley HS125 Srs 600A touched down left of the runway and well beyond the threshold at ZBM (Bromont QC, Canada). Many factors, including culture, contribute to human error-the leading cause of incidents and accidents according to NTSB.
Traditionally, aviation safety has been regulated prescriptively, ie, regulators define safety correctness through myriad rules and standards and then audit and inspect operators to verify compliance.
This complex approach requires specialist oversight resources and often overconstrains operators, particularly in introducing new processes and technologies.
Long-term improvements in aviation loss rates are admired by other industries. While it took 20 years (1948-68) to achieve a 10-fold reduction in fatality rate, the next 10-fold reduction took 30 years.
Safety gains in recent years are less dramatic as training and technology benefits work through the industry. Although low, the rate appears to have flattened. NTSB data reveals that, while corporate jets flown by professional crews under Part 91 have accident rates comparable to those of scheduled air carriers, the biggest killer of turbine-powered business airplanes continues to be human failure.
Keen competition for limited resources has had its effect on governments. ICAO found approximately half of the state regulatory agencies audited had insufficient flight operations inspectors to continue adequate safety oversight of civil aviation activities.
The choices remaining were either to accept residual loss rates as a cost of business or to rethink a strategy to reduce them further.
Choosing a way forward
Considering these alternatives led ICAO to mandate a supplemental approach to safety regulation in which the regulator sets objectives for the achievement and demonstration of safety, requiring operators to show (by argument and evidence) that those objectives are met.
States and operators will interact within formalized safety programs and acceptable levels of safety, according to guidance in ICAO Doc 9859 Safety Management Manual (SMM), Doc 9806 Human Factors Guidelines for Safety Audits Manual and Annex 11 to the Chicago Convention.
ICAO itself distinguishes between state safety programs (SSPs) and safety management systems (SMSs) for air operators and maintenance organizations. SMS is a systematic approach to managing safety, including the necessary organizational structure, accountabilities, policies and procedures.
Passenger fatalities per 100 million passenger miles-scheduled public transport, excluding acts of unlawful interference-1945-2006.
In shifting from prescriptive-based to performance-based regulation, operators used to government detailing how to achieve safety will have both freedom and responsibility to adopt best practices in achieving safety goals. Most countries-including the US-have yet to meet the requirement.
Canada is one of the few to have an SMS rule in place, but aspects of its implementation have been criticized as creating potential risk to civil aviation and the flying public. While FAA's intention is to make SMS mandatory for Part 121 and 135 operators, there are no plans to include Part 91 or Part 91K organizations.
For the time being, FAA regards SMS as having relatively low urgency or impact on safety, indicating that final rulemaking before 2013 is unlikely. Until required by regulation, the US cannot either approve or accept an SMS.
If it isn't required yet, why do it? Used effectively across the corporation, the concept is sensible for 3 reasons-it integrates accepted safety management methods to prevent loss, it shares risk management strategies critical to achieving business goals and it may be required for international operations.
The training industry offers operators a range of SMS-centric courses, but these tend to concentrate on developing and using upfront tools such as databases, guidelines and checklists to help with future risk decisions. However, most fail to give adequate attention to the single element critical to the success and survival of any safety management system-safety culture.
Safety and acceptable level of safety
Notions like safety, acceptable level of safety and safety culture often carry formal definitions tending to be too academic. In 1980, the US Supreme Court concluded that "safe" is not the equivalent of "risk-free."
It follows that safety is the state in which the risk of harm to persons or property is maintained at or below an acceptable level. Human error is inevitable, and absolute safety is unachievable at reasonable cost.
What society (ie, passengers and third parties) tolerates as acceptable risk is expressed in joint terms of probability of occurrence and severity of consequences. The regulator translates societal expectations into an acceptable (or tolerable) level of safety defined by 2 metrics-safety performance targets (desired and realistic outcomes) and safety performance indicators (expressions of achieved targets).
These are set as the safety goals for operators. Disagreement exists among authorities as to the requirements and objectives of SMS. European flight operations regulations, for example, do not currently require a defined acceptable level of safety nor continuous monitoring thereof.
The rules do not address future risks, thus failing to align fully with the intent of the ICAO standard.
How important is a safety culture?
Safety culture is the set of enduring values and attitudes regarding safety, shared by every member of every level of an organization. Safety culture is widely recognized as critical to the success of SMS.
In Europe, the UK Civil Aviation Authority (CAA) considers an active safety culture as vital to the continuing success of an SMS. The accountable manager sets the standard for the organization's safety culture.
Without this commitment, an SMS will be ineffective. The US Nuclear Regulatory Com_mission found that safety culture was the dominant factor in accidents and incidents that had occur_red over many years in the US nuclear industry.
And the European Strategic Safety Initiative (ESSI) records that it is well possible to have a good safety culture without a formal SMS, but that it is not possible to have an effective SMS without a good safety culture.
FAA considers SMS as providing the organizational framework to support a sound safety culture-an important aspect of safety management. SMS will not achieve its goals unless people work together in a safety culture that promotes safety.