Daily SMS Activities May Preclude Routine Review
The new year has started. Business activities are beginning to return to full speed. At full speed, aviation safety managers may be putting out fires. These fires may cause safety teams to look continuously ahead when they should occasionally be looking back.
Aviation safety managers at all stages of their SMS implementations should be monitoring activities relevant to the phase of their airline or airport's SMS implementation.
Regardless of whether your review is many months away or next week, we'll consider two highly important things you should be reviewed regularly.
Aviation SMS Implementations Are Marathons, Not Sprints
For those safety managers just starting their SMS implementations, it is recommended that you don't try to implement your aviation SMS program all at once, for it is impossible to do. Therefore, you should focus on the phased approach, such as described in ICAO's SMS documentation. There are four phases:
- Planning SMS Implementation;
- Reactive Safety Management Processes;
- Proactive and Predictive Safety Management Processes; and
- Operational Safety Assurance.
In most cases, experienced safety managers will have scheduled a review of their implemented aviation safety management systems (SMS). If you have not scheduled a review, we highly recommend that you do this now.
Aviation SMS Activities to Consider Reviewing
Today, we'll focus on an ICAO compliant SMS implementation's first phase, which the FAA Part 5 relates to. Here are two extremely important activities to review to ensure your aviation SMS implementation stays on course:
- Identify accountable executive; and
- Identify safety accountabilities of managers.
Identify Accountable Executive
If you have an aviation SMS program, chances are that you already have identified an accountable executive. But...
Has the accountable executive changed?
Does the accountable executive know and understand their responsibilities? Has he reviewed his responsibilities and has this review been documented? Here is a quick review of the accountable executive's responsibilities from FAA's Part 5 Safety Management Systems. This comes from subsection 5.25 Designation and responsibilities of required safety management personnel.
(b) Responsibilities of the accountable executive. The accountable executive must accomplish the following:
(1) Ensure that the SMS is properly implemented and performing in all areas of the certificate holder’s organization.
(2) Develop and sign the safety policy of the certificate holder.
(3) Communicate the safety policy throughout the certificate holder’s organization.
(4) Regularly review the certificate holder’s safety policy to ensure it remains relevant and appropriate to the certificate holder.
(5) Regularly review the safety performance of the certificate holder’s organization and direct actions necessary to address substandard safety performance in accordance with § 5.75.
What we don't see here from FAA's Part 5 is that the account executive is also responsible for providing support for the aviation SMS program.
Accountable executives' support must be:
- Visibly obvious to all employees;
- Adequate financially; and
- Sufficiently available for safety personnel.
Visible support may take several forms:
- Messages in safety newsletters;
- Participation in safety committee meetings; and
- Being seen publicly with safety team, such as on walkabouts.
Personnel support would be ensuring that sufficient human resources are tasked with SMS implementation and maintenance of the SMS program. Furthermore, are these human resources qualified?
Identify Safety Accountabilities of Managers
One of my pet peeves about aviation SMS programs is the current attitudes of managers outside of the SMS program. In the majority of organizations I have worked with, managers in other departments view SMS as the major responsibility of the safety team and the accountable executive. They don't view SMS implementations as a shared responsibility.
I'm delighted that attitudes are slowly changing.
An accountable executive told me recently that he wants aviation SMS tools that can be used by all managers to be actively involved in their SMS program. This is a Canadian company, so if my calculations are correct, it will be another ten years for other countries to mature to this level. I'll exempt Australia from this blanket statement because I continue to be a firm believer that the Australians and Canadians are true leaders in aviation SMS implementations.
Let us continue with subsection 5.25:
(c) Designation of management personnel. The accountable executive must designate sufficient management personnel who, on behalf of the accountable executive, is responsible for the following:
(1) Coordinate implementation, maintenance, and integration of the SMS throughout the certificate holder’s organization.
(2) Facilitate hazard identification and safety risk analysis.
(3) Monitor the effectiveness of safety risk controls.
(4) Ensure safety promotion throughout the certificate holder’s organization as required in subpart E of this part.
(5) Regularly report to the accountable executive on the performance of the SMS and on any need for improvement.
The Canadian manager I referred to above knew that it would take more than the safety team to manage all the above elements detailed in subsection 5.25(c).
For example, let's consider; (2) Facilitate hazard identification and safety risk analysis.
Safety professionals typically have operational experience, but no safety manager is a subject matter expert in all operational areas. Therefore, it is imperative that other operational managers are participating in routine:
- Hazard identification;
- Hazard risk analysis and review; and
- Safety Promotion.
Safety promotion is often left to the safety team; however, it is almost always impossible to create safety promotion content that resonates with all employees because they come from a wide range of departments, such as:
- Flight ops;
- Ground handling/ramp;
- Cabin crew;
- Facilities; and
This is one reason I believe that the best safety newsletter articles are written by functional group managers and not simply authored by the safety team.
Finally, when you review the safety accountabilities of managers, I believe it is best that you document that each manager has reviewed and understands their safety duties and responsibilities. This review exercise can be seen as serving as both:
- SMS training; and
- Safety promotion activity.
Final Thoughts on Reviewing Management Responsibilities
While this discussion used FAA's Part 5 as our reviewing document, these principles apply to all aviation SMS implementations, whether you are at:
- Maintenance organizations;
- Flight schools;
- Air traffic control; or
- Manufacturing company.
Furthermore, these principles are as valid in Canada or Saudi Arabia as they are in the United States.
Good luck with your SMS implementation.
Good aviation SMS tools should be user-friendly to all user groups, from the safety team, to operational managers, and to all employees. Furthermore, they should cut your auditing time to 25% of what you normally would expect.
Do your aviation SMS software tools save you sufficient time during audits?
Can upper-level managers monitor your SMS program without special IT support? Keep management involved and they will be more likely to support your SMS program!
Paper pile image by flickr