POSITION & HOLD and editorial opinion
Taking a close look at the value of safety management systems
By Nick Sabatini
Associate Administrator Safety, FAA (retired)
ATP/Helo/CFII. Citation 500 series, Bell 206
Team member engagement and administrative oversight are required in equal measure to ensure SMS effectiveness.
The shift we need to make is from a reactive "fix and fly" method to a proactive preemptive method. SMS does precisely that. It helps you identify risks, hazards and vulnerabilities that are unique to your operation and may not be found in other operations.
As with financing, marketing or other business processes, SMS requires a rational businesslike approach that uses structure, data and analysis to ensure that the organization is safe and that it survives and prospers.
This also means that we set goals, we plan, we monitor and measure performance, we identify problems and risks, we intervene to fix those problems, and we hold people and organizational units accountable.
Like other business processes, SMS must be systematic and ongoing—it's not a one-time exercise. As an ongoing process, it never reaches an end point—it becomes a permanent part of the way an organization does business.
It defines how the organization understands and deals with its environment, it defines values that are important to the organization—and it actively guides behavior. In short, SMS must become part of an organization's culture. This can be hard work.
Both SMS and culture change have to start at the top. CEOs and senior managers must show by their actions that safety is a critical organizational goal and value. That message then needs to be transmitted to everyone else who affects safety in a corporate operation, down to the crew on each flight, the mechanic who releases the flight, those who provide ground support for the flight, and the other organizational units in the company who provide the passengers or cargo.
A typical description of SMS includes 4 basic essential elements, commonly referred to as the pillars of SMS—safety policy, risk management, safety assurance and safety promotion.
Most governmental aviation regulators add that these elements require the following.
A safety policy statement should define plausible goals and indicate a rational, businesslike process in which all employees and all managers have a stake.
Policy is where objectives are set, responsibilities assigned and standards set. It is also where top managers convey their commitment to safety to the organization's members. The words in the policy statement must be reinforced by actions.
Team members need to recognize that safety is an integral part of accomplishing the mission. Risk management requires establishing a process for identifying hazards to aviation safety and for evaluating and managing associated risks.This is where the concept of an SMS differs from a traditional safety program. Risk management must be performed with active involvement of the decisionmakers. Managers must take the lead in understanding the risks their people take and implementing effective risk control measures.
Diligent, organized steps must be taken to ensure the right risk control practices are in place, that they are being observed and that they are working.
The first step in safety assurance is a day-to-day, job-by-job monitoring of operations and maintaining an active process of checking and monitoring the conditions of each mission prior to dispatch.
Internal audits are the next step. These shouldn't be thought of as a test—they are the manager's tool for taking a periodic look at what's going on and what's happened in the recent past. Managers should determine items that could cause problems and set up a program to review these areas periodically.
The third most important area of safety assurance—some would say the most important—is employee reporting. Audits focus on the areas where we expect to find concerns, but employees' reports fill in the gaps where unexpected but potentially significant safety problems may lie.
Clear policies regarding human error and its treatment are essential. They constitute a "just culture." Trust is essential in an effective employee reporting system, since active feedback and personal involvement is often the most valuable asset in avoiding future problems.
Training and communication are key. Outcomes of risk management decisions, findings of audits and employee reports should be communicated to all appropriate parties. Communication from the top down completes the circle of bottom-up communication provided by the reporting system. Organizations must also open lines of communication with other organizations.
Continuous learning will help make safety an integral part of the job and mature your safety risk management and assurance processes. Above all, an SMS has to help make better safety management decisions.
Benefits and opportunities
SMS can help any company, regardless of its size and complexity. A well structured SMS program, with data analysis and nonpunitive, voluntary reporting programs will be well placed to identify trends in unstable approaches, adherence to SOPs, gaps in those SOPs, computation of required takeoff and landing distances, weight and balance programs, the frequency and location of EGPWS alerts, and so on. Add rigorous analysis, routine feedback and corporate accountability, and risk will go down.
It is possible that FAA's agenda may affect corporate operators. Now that Congress has passed the first FAA reauthorization bill in more than 7 years, the good news is that the agency will enjoy relatively stable funding for the next 4 years. Authorization provides enough funding at least to start making progress on NextGen.
However, authorization included a requirement that FAA enable unmanned aircraft systems (UASs) to enter the civil airspace system in 2015. The regulatory side of FAA will also be trying to manage implementation of new duty and rest rules among Part 121 operators, as well as trying to manage SMS implementation at the air carrier level. Add this to the record number of Congressional mandates and NTSB recommendations, and FAA will be fortunate not to be swamped by its workload.
Although FAA has deferred active pursuit of corporate SMS in order to catch its breath, I would recommend that the corporate aviation industry use this interval to implement good programs on its own.
At some point, FAA is almost certain to revisit its own requirements for corporate SMS. Today, the opportunity exists to get out in front of any future regulatory initiative. If you take real and positive action, you'll find that regulators are happy enough to acknowledge that they no longer have a problem that requires intervention.
Nick Sabatini is an international safety consultant who provides independent safety assessment services to organizations and entities worldwide, including Part 121 air carriers, Part 135 air operators and Part 145 repair stations.
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