What are Best Practices for Establishing Safety Accountabilities?
One of the first steps in implementing an aviation safety management system (SMS) is to knock out the documentation elements in the Safety Policy and Objectives component of an ICAO compliant SMS program.
Please note that I said "one of the first steps." Before tackling these documentation elements, we recommend that you first:
The reason we recommend the gap analysis and SMS implementation plan is to:
- Educate safety team as to SMS requirements and best practices; and
- Save time and energy by not having to drastically rework your SMS documentation.
The purpose of this article is to save safety managers time and money during:
- SMS implementation; and
- Regular review of the SMS documentation.
We also hope to shed some light on some best practices revolving around safety accountabilities in aviation SMS programs.
What is Safety Accountability?
First, let's define accountability, which is especially useful for those that speak English as their second language. "Accountability" is the fact or condition of being accountable. Synonyms include responsibility, liability, and answerability.
According to ICAO guidance in the Safety Management Manual (bold added):
"The service provider shall identify the accountable executive who, irrespective of other functions, shall have ultimate responsibility and accountability, on behalf of the organization, for the implementation and maintenance of the SMS. The organization shall also identify the accountabilities of all members of management, irrespective of other functions, as well as of employees, with respect to the safety performance of the SMS. Safety responsibilities, accountabilities and authorities shall be documented and communicated throughout the organization, and shall include a definition of the levels of management with authority to make decisions regarding safety risk tolerability."
I added the bold to emphasize the most important elements of this paragraph.
The accountable executive has ultimate responsibility for implementation and maintenance of SMS program.
Establishing the accountable executive is an easy requirement to satisfy. Accountable executives are usually a:
- Chief executive officer;
- Chief operation officers
- Chairman of the board of directors;
- Partner; or
The important takeaway here is that there is only one! This is where the buck stops! One cannot share the ultimate responsibility with another, else there can never be an "ultimate responsibility" assigned.
Accountable Executive's Authorities and Responsibilities
According to ICAO's guidance material referenced above, the accountable executive's authorities and responsibilities include:
- Full authority for human resources issues;
- Authority for major financial issues;
- Direct responsibility for the conduct of the organization's affairs;
- Final authority over operations under its certificate/ approval;
- Establishment and promotion of the safety policy;
- Establishment of the organization's safety objectives and safety targets;
- Acting as the organization's safety champion; and
- Having final responsibility for the resolution of all safety issues.
Managing Safety Costs Money. No Money, No Safety.
In every organization, managers control the allocation of resources, including financial, technical and personnel. Withholding resources are the first indicator that top management is not fully committed to the SMS programs. Resources are required to mitigate safety risks when hazards manifest themselves and threaten the capabilities of the airline or airport.
The bottom line is that no top management commitment means that no money comes, which leads to the failure of the safety program.
Also, identify the accountabilities of all members of management and all employees.
SMS related accountabilities, authorities and responsibilities of key safety personnel will need to be fully documented and communicated throughout the organization. One must also not overlook the safety responsibilities of line employees and contractors. This documentation usually takes the form of two sections of an ICAO compliant SMS program, namely:
Duties and responsibilities of key safety personnel are usually stored in one or more of the following:
- Safety manuals;
- Operations manuals;
- Web-based content accessible to all employees; or
- Stand-alone documents housed in SMS documentation.
In order to demonstrate compliance, airlines and airports must show the existence of clear lines of safety accountabilities throughout their operations. These accountabilities include:
- An accountable person owning ultimate accountability for the SMS program;
- Management support throughout the organization; and
- Involvement by all employees and contractors.
Furthermore, the Accountable Executive and management team must fully understand safety risks faced by their organization.
Best Practices for Managing Safety Accountabilities
Here are some indicators that your airline or airport has tackled safety accountabilities in a spectacular fashion. Best of breed SMS programs demonstrate evidence of:
- Personnel involvement in the establishment and daily operation of the SMS program;
- Safety management system principles penetrating all organizational levels and safety is part of the everyday cultural practice;
- Documented safety accountabilities for all members of the organization;
- Documented records that individuals accept their accountabilities;
- Documented key safety activities in senior management job duties and responsibilities;
- Personnel performance reviews are dependent on employees compliance with key safety activities;
- Management recognizes employee contributions to the safety program; and
- Management communicates the significance of the safety program to all employees.
Final Thoughts on Aviation SMS Safety Accountabilities
Documented elements of SMS programs are usually pretty easy to fake during the first few years of SMS audits. We often hear of smaller operators purchasing SMS manuals that have all the "pretty" and "politically correct" words. These convenient manuals may still have another company's name in them.
Templates and purchased manuals are great starting points to jumpstart your SMS implementation, but ensure that they have been modified to reflect the correct nature of your operations. Furthermore, take a few minutes each year and review these documents to ensure they remain relevant.
Final words: don't be afraid to make changes whenever necessary. Changes should be accepted by top management. Safety accountabilities of managers must reflect the size, nature, and complexity of your operations, and also consider hazards and safety risks associated with your operations.