SMS' Risk Management Seldom Reaches Full Potential
Risk management processes in aviation safety management systems (SMS) offer service providers structure for:
- Hazard identification;
- Hazard reporting;
- Risk quantification;
- Evaluation of risk controls;
- Safety performance monitoring; and
- Investigations of both reported safety issues and foreseeable hazards.
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For most aviation service providers, risk management involves the participation and cooperation of many stakeholder groups, including:
- Manufacturers; and, of course,
Without the involvement of all stakeholders, risk management activities at your organization will never realize their full potential. And we all remember the reason we have risk management procedures, correct?
- We want to be safe.
- We want to prevent or avoid "The Accident" that we all know is coming, but we don't know when, or to whom. But we do know why?
Do you know why "The Accident" is coming?
The short answer why "The Accident" is coming is because operators do not yet know how to monitor the effectiveness of risk controls. I have seen hazard registers in many aviation SMS that are created once, and may be reviewed annually or every two to three years. Some hazard registers only are reviewed in anticipation of a scheduled SMS audit.
The hazard register is a list of all
- organizational safety hazards,
- hazards' conditions where they may manifest and create harm (risk consequences); and
- hazards' control measures to detect, prevent or correct hazard manifestation.
Purpose of SMS' Risk Management Procedures
Most of us understand the purpose of having formal risk management processes. SMS allows for the timely and repeatable elimination or reduction of risks to all affected stakeholders to an acceptable level. However, too many managers, simply complying with regulatory or contractual obligations is their only motivation for formalizing their risk management procedures or participating in the mandatory SMS. These operators may have processes, but they are not being practiced.
Processes for the management of hazards and their associated risk are implemented to increase the organizational value or to meet service obligations. Regardless of the reasons behind implementing risk management processes, there are several critical elements that must be observed.
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The failure of any of the following elements will result in the failure of your SMS' risk management processes:
- Safety policy affording employee protections from self-reporting;
- Safety reporting process and subsequent investigation;
- Accountability and responsibility;
- Hazard identification training; and
- Safety promotion.
Every safety manager recognizes that hazard identification and risk management are the core component of every aviation SMS. The FAA succinctly describes the purpose of SMS is to:
- proactively manage safety,
- identify potential hazards,
- determine risk, and
- implement measures that mitigate the risk.
"The FAA envisions operators being able to use all of the components of SMS to enhance a carrier’s ability to identify safety issues and spot trends before they result in a near-miss, incident, or accident. For this reason, the FAA is requiring carriers to develop and implement an SMS."
Source: Federal Register / Vol. 80, No. 5 / Thursday, January 8, 2015 / Rules and Regulations
We can logically see the reasoning behind SMS implementations. If you work in the aviation industry, we daily see preventable accidents and incidents. Why do these accidents and minor incidents continue to occur?
We can see why we need SMS. Operators have proven to be either unwilling or unable to reduce risk on their own volition. In the interest of "system safety," regulations have been created that mandate SMS implementations.
Risk Management Processes Not Enough for Aviation SMS Success
Risk management processes give us the tools and technologies to reduce risk to as low as reasonably practical (ALARP). But having tools and technologies is not enough! Top management should be supporting these risk management procedures openly and frequently using these SMS-related vehicles:
- Safety policies;
- Safety newsletters;
- Safety budgets (supplying adequate resources);
- Safety surveys;
- Lessons learned libraries;
- Safety training article libraries; and
- Safety meeting participation.
From this list, we see that most activities fall under the SMS' Safety Promotion component. Safety promotion is one of those very important SMS elements that receive little attention.
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Why do you think safety promotion gets the least amount of attention in SMS? Is it because safety promotion in traditional safety programs seemed forced or contrived? Do safety promotion activities seem like a disingenuous attempt by management to influence employees?
You may have the best risk management processes on the planet. However, when employees don't trust management, or when employees don't know how to identify hazards and report safety concerns, your "best-in-class" risk management processes are simply worthless. Sure, they may please an auditor, but an SMS requires active participation from all of the stakeholders we listed at the beginning of this article.
Safety promotion has been considered the "forgotten" component, or the pillar that receives the least amount of attention in an implemented SMS. How management treats "safety promotion" in modern SMS reminds me of the traditional safety programs. We hardly see a company that regularly promotes SMS in an effective manner. Sure, the organization may have good intentions at the beginning of the SMS implementation, but the safety culture is slow to develop and slow to see visible results. Consequently, safety promotion campaigns are short-lived in most aviation SMS.
Tell me that you disagree. Can you tell me that most companies have a vibrant, healthy safety culture that was spawned by consistent safety promotion efforts? Yes, there are a few companies that have the perseverance to faithfully promote the SMS year after year, but these are the minorities...the three to five percent group.
Employees need to understand what are hazards, risks and how risk controls function in their area of operations. Unless employees know how to identify a hazard and how to report safety concerns, the SMS implementation is doomed to remain a "paper SMS" that only serves to "check the SMS box."
Time Plays a Role in SMS' Risk Management
Aviation service providers may believe they have an effective SMS, illustrated by:
- Documentation; and
- Safety training; and
- Well-defined and detailed risk management procedures.
More than once, we have seen operators possessing both the abilities and the required risk management processes to manage reported safety concerns, however, they lacked timeliness. Their documented risk management processes were so detailed and painstaking that they took forever to close reported safety issues, thereby crippling the timely execution of treating their hazards, once they were identified.
Timeliness is incredibly important for:
- Hazard reporting;
- Performing investigations;
- Safety risk analysis of reported hazard;
- Review of the system which manages the reported hazard; and
- Management of corrective/preventive actions.
When hazard and risks are not managed in a timely fashion, employees and contractors will assume management possesses apathetic attitudes to your SMS' risk management activities. Appearances are incredibly important. Appearances or perceptions of management's commitment to the SMS strongly affects safety culture.
Related Articles on Management Commitment to Aviation SMS
- How to Earn Top Management Support for Aviation SMS
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How do employees view your SMS? Do they see management actively participating? This brings us back to the days before mandatory SMS, where many operators had traditional safety programs. You may remember the old safety programs:
- There may have been a dual-purpose suggestion/safety reports box;
- Safety concerns stayed in the safety department without upper management participation;
- Safety department received no additional resources to improve safety;
- Upper management seldom participated in safety initiatives;
- Employees had little protection from management when self-reporting errors or mistakes;
- Hazards and damage were reactively managed and then forgotten;
- Employees had little indication of the safety program's influence or impact to operations; and
- No documented risk management processes existed to consistently and repeatedly treat safety concerns.
Well-defined, effective risk management processes identify and treat hazards in a timely fashion--while they are top of mind. Otherwise, new or recurring hazards are continually vying for preciously limited resources and the process fails. Also, safety cultures are affected because employees may see a "slow response" as a "no response."
Accountability and Responsibilities Must Be Communicated
Wherever appropriate, accountabilities and responsibilities for the identification, reporting and management of hazards must be communicated and documented. Best practices will have employees and managers review their accountabilities and responsibilities on an annual basis. This activity will be documented and serve as another "safety promotion" activity.
For most aviation SMS, these accountabilities and responsibilities include:
- Hazard identification;
- Hazard reporting;
- Incident, accident and hazard investigations;
- Management and performance of corrective/preventive actions; and
- A scheduled review of closed safety reports.
For best results, accountabilities and responsibilities should be posted where all employees can review not only their accountabilities and responsibilities but also the accountabilities and responsibilities of other employees and stakeholders, such as:
- Their supervisors;
- Customers and facility visitors;
- Safety committees;
- Safety managers; and
- Top management.
Related Articles on Accountability and Responsibility in Aviation SMS
- Distinguishing between Responsibility, Authority, and Accountability in Aviation SMS
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Without Training, SMS Risk Management Efforts Fails
The first steps for implementing an aviation SMS and its risk management processes are:
- Acquiring top management support;
- Determining SMS requirements (gap analysis) and planning next steps;
- Creating the vision of what you expect to achieve (safety goals and objectives); and
- Designing risk management policies, procedures and documentation (an ongoing task).
Once you have accomplished these tasks, you will have to determine the best way to train the organization to identify and treat hazards in a timely fashion. For most organizations, we see that "train the trainer" concept is most widely accepted. "Train the trainer" is cost-effective and ensures that the safety team is more knowledgeable regarding the entire hazard management system.
All educators understand the concept that "you really don't understand a subject well unless you can teach it."
Risk management training should be developed for different user groups, dependent upon the role they play in the hazard management system. These groups may include:
- Regular employees and contractors;
- Department heads responsible for treating the hazards;
- Safety committees; and
- Upper-level executives.
Safety Promotion Offers Continuous Reinforcement
Safety training proves effective for short-term gains in the aviation SMS; however, safety managers must continue to stoke the fire to ensure the developing risk management mindset and extant safety culture does not die on the vine.
Too often, we see aviation service providers spend considerable time and money developing their hazard management procedures...
- They have top management support.
- They hire contractors or special safety consultants to jump-start their SMS.
- And then it slowly dies.
- And sometimes it quickly dies!
Aviation SMS will slowly die when:
- Top management withdraws visible support;
- Top management withdraws financial support; and
- When safety teams neglect safety promotion activities.
Most often, top management is not actively monitoring SMS performance. Nor is top management looking to identify a sick safety program unless a serious accident occurs.
Top management is busy focusing their energies on increasing the financial value of their company or satisfying a board's interests.
Related Aviation SMS Safety Promotion Articles
- Why Transparency Promotes Safety Culture in Aviation SMS
- Aviation SMS Surveys - an Often Neglected Safety Promotion Tool
- 3 Inexpensive Ways to Promote Safety at Flight Schools & Other Aviation SMS
Due to humans' tendency to forget, it is important that safety managers keep hazard identification and safety reporting at the top of everyone's minds. This can be accomplished using:
- Safety newsletters;
- Safety surveys;
- Safety meetings; and
- Safety posters.
It is easier to keep everyone interested in the aviation SMS than it is to try to revive interest after everyone has tuned out of "the program."
Final Thoughts on Aviation Risk Management in Aviation SMS
As we have seen, managing hazards and safety concerns is not simply about waiting for accidents to happen and then react. There are several critical elements to effective risk management programs.
We can easily see that when one element is neglected, your risk management system will easily fail, which leaves you with an impotent SMS.
A common failure of aviation SMS can be averted early on in the SMS implementation process. We frequently see aviation service providers outgrow their SMS data management facilities. At the beginning of SMS implementation, safety managers are busy getting top management support and learning SMS requirements. There is little consideration as to what the SMS documentation requirements are.
Consequently, we see SMS data managed completely in paper and spreadsheets. Occasionally, we see a point solution or software developed for another operational process converted to manage SMS data.
Timely completion of SMS risk management activities is often attributed to SMS tools. When an operator has the right tool for the job, the task becomes much easier to manage. Imagine that you have a hammer and you need to dig a hole. Sure, you could dig the hole with a hammer, but a shovel or a backhoe would be better suited to accomplish the task. You can think of a spreadsheet SMS as the hammer. There are better ways to manage SMS data and make the safety team more effective.
If your SMS tools are lacking, we can help. To determine whether we may be a good fit for you, please watch these short demo videos:
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Last updated April 2021.
Deicing image by Helen Cook on flickr