Disconnect in FAA Importance Stressed on Safety Promotion
A few elements of the Safety Promotion requirements need to be discussed before we jump in.
The Safety Risk Management and Safety Assurance pillars of SMS receive by far the most attention by aviation service providers and aviation oversight agencies. Lagging far behind them is Safety Policy.
Just consider, the Federal Aviation Administration gives Safety Promotion in its Advisory Circular and Part 5 Requirements far less coverage than the other pillars:
- Safety Policy receives 6 pages of coverage:
- Safety Risk Management receives 12 pages of coverage;
- Safety Assurance receives 15 pages of coverage; and
- Safety Promotion receives 3 pages of coverage.
In the shadow of SRM and SA, it’s easy to overlook just how important Safety Promotion is. This pillar accounts for:
In short, Safety Promotion covers all of the mission-critical mechanisms that drive safety risk management and safety assurance performance. You could even make the argument that Safety Promotion will make the most important difference between safety adequacy and inadequacy.
Poor demonstrations of Safety Promotions will completely and totally cripple a safety management system. No other pillar can boast such a claim to such a degree. So it should be stressed that while Safety Promotion receives only 8% of the coverage in FAA’s Part 5 analysis, providers cannot underestimate how important this element is.
Safety Promotion and Aviation Safety Training
Part 5.91 indicates that one of the primary roles of the Safety Promotion element of SMS is to, “provide training to each individual identified in [the Safety Policy pillar]…” The Advisory Circular then goes on to partition aviation safety training into:
- “Initial training…to understand and perform duties” (AC, 3-6.b.6; and
- “Recurrent training…to reinforce these skills.” (AC, 3-6.b.6)
It’s extremely important to point out that the FAA indicates that recurrent training builds on initial training, i.e., “reinforce [the skills learned during initial training].” The implication here is the initial training is extremely important, as its goal is to set down the foundational skill an employee needs to know in order to perform their duties.
Other important factors about safety training are:
- Different employees will require different amounts of training;
- There are many forms of safety training, such as formal training, newsletters, safety articles, etc.;
- Safety training effectiveness should be monitored; and
- Aviation safety training will only work if it’s good training.
All roles that require training need to be documented in Safety Policy, as Part 5 indicates.
What is Safety Competency in Safety Promotion
Part 5 says that the goal of safety training is to “maintain the competencies necessary to perform…duties relevant to the operation and performance of the SMS” (5.91).
Competency is a vague word, which fortunately is explained a bit further in the AC. Does competency mean “meet the requirements”? How does one test competency? As defined by the FAA, competency is made up of observable and measurable:
- Behaviors; and
- Actions employees exhibit.
The key words here are observable and measurable. The implication is that you are defining what competency means with your goals and objectives, and then tracking those competencies with:
- Key Performance Indicators;
- Leading indicators;
- End-of-training assessment testing;
- Evaluations; and
- Other forms of safety performance monitoring.
Reviewing safety training is necessary for continuous improvement, which is a part of the FAA’s Safety Assurance process.
Safety Promotion is Safety Communication
The second and final portion of the FAA’s Safety Promotion element is safety communication. The FAA requires that, “The certificate holder must develop and maintain means for communicating safety information…” (5.93). This safety communication needs to:
- Ensure that employees are aware of resources and guidelines relevant to their positions (5.93)(a);
- Convey hazard information to employees (5.93)(b);
- Convey what safety actions are being taken (5.93)(c); and
- Convey new/updated procedures to the SMS program (5.93)(b).
The keyword here is “maintain means for communicating…” What are these means, or what could they be? Simply put, your safety management system needs some kind of content-deliver system that can be monitored and documented, such as:
- Safety meetings;
- Paper content distribution, such as newsletters, fliers, etc.;
- Messaging system; and
- YouTube video channel (for distributing video description of safety information).
The most effective communication technique is to deliver relevant content to relevant employees. If you drown every employee with every piece of new information, they will become information-blind, and may potentially miss seeing important information. Keeping information relevant will help keep employees paying attention.
Final Thought: Indications of Safety Promotion Compliance
Fortunately, as the Safety Promotion pillar is such a small part of Part 5 requirements, managing compliance is fairly easy:
- You have established (documented) methods of communicating;
- You are tracking and documenting training status of each employee; and
- You are tracking connection between safety training and safety performance.
Beyond compliance, organizations that invest resources into Safety Promotion should expect to see significant, and beneficial, returns on safety performance.
For an eBook on further information about FAA Part 5 compliance, see the link below: