What are ICAO Hazard Identification Compliance Requirements
ICAO’s hazard identification compliance requirements are twofold:
- (2.1.1) Develop formal process for hazard identification; and
- (2.1.2) Use reactive, proactive, and predictive to identify hazards.
Being compliant with these requirements involves, like anything else in SMS, doing and documenting. You need document your process and how you use various risk management techniques for hazard identification, and you need to follow through.
Let’s break down these requirements piece by piece for how to be compliant with ICAO hazard identification.
What is Hazard Identification in Aviation SMS
Hazard identification in aviation SMS programs is the primary data you will use to mitigate risks. With hazard identification, you identify the safety needs of your company and can act accordingly. It is part of the Safety Risk Management element of the 4 Pillars of aviation safety.
Hazard identification is simply an awareness and recognition of potential danger in the operational environment. Hazard can be identified by different activities, such as:
- Reactive risk management activities;
- Proactive risk management activities; and
- Predictive risk management activities.
ICAO actually mandates that your SMS attempts to identify hazards with all three types of risk management. All identified hazards should be documented in your hazard risk register and/or operational risk profile, where you can also document how you are mitigating the threat each hazard poses.
What is a Hazard in aviation SMS
Hazards are one of the core concern of safety management system. A hazard fulfills the following requirements:
- Is a condition, such as an object, situation, circumstance, that poses an unacceptable level of danger;
- Occurs once in the safety mishap lifecycle;
- Can lead directly to risk occurrence (i.e., safety mishap, accident, etc.) if not mitigated; and
- Arise from hazard mechanisms, such as initiating actions and hazardous sources.
It’s quite common for safety managers to confuse hazards with other risk management principals. A hazard is NOT:
- Benign objects (birds, mountains, people), which are hazardous sources;
- Safety mishaps, which are another way of saying risk occurrences;
- Damages, which are a product of risk occurrence; and
- Dangerous actions, which are associated with initiating mechanisms.
What can and may differ from organization to organization is how each organization defines the point where a situation becomes unacceptably dangerous.
What is a Formal Hazard Identification Process
In aviation SMS programs, ICAO mandates that your hazard identification process needs to be “formal.” A formal process means that hazard identification processes need to be:
- Described via documentation;
- Show evidence of being improved; and
- Include set steps and process for identifying via different activities.
Hazard identification processes should be based on a combination of reactive, proactive, and predictive methods of safety data collection.
The reason it’s important to understand hazard identification as a process is because identifying hazards happens as a result of several actions, each of which has several steps. These basic steps are:
- Build awareness;
- Build hazard reporting culture;
- Actively recognize hazards; and
- Reporting threats in a formal hazard reporting tool (i.e. aviation SMS software or paper hazard reporting form).
Your documented process for hazard identification should try and reflect these basic steps.
How to Identify Hazards with Reactive Risk Management
Reactive risk management has kind of a bad reputation in aviation SMS programs. It’s often perceived as the “lowest” or most basic form of risk management.
Reactive risk management is an extremely important way to identify hazards. Indeed, you may identify a majority of your hazards via reactive processes. This is because reactive risk management is an essential element of:
- Mitigating safety events after hazard has occurred;
- Identifying new hazards as they are actualized in operational environment;
- Minimizing damage from critical safety situations;
- Acting quickly and efficiently in response to undesirable incidents; and
- High quality decision making in reaction to threats, risk, etc.
Reactive risk management is how personnel see danger and react appropriately to it. This involves documenting:
- How you educate employees on hazard identification;
- How you will communicate your expectations for which issues should be reported; and
- How you will train them on your hazard reporting process.
These documentation elements will show how you promote reactive hazard identification.
How to Identify Hazards with Proactive Risk Management
Proactive risk management is something aviation safety programs strive for. Being able to identify hazards proactively is good for safety and good for compliance performance.
The primary goals of proactive hazard identification are:
- Identify root causes before they lead to hazard occurrence;
- Identify potentially dangerous situations before they actually become dangerous; and
- Understand safety “inputs” of your program – i.e., underlying causes that lead to incidents.
Being able to identify hazards proactively usually involves activities like:
- Aviation safety audits;
- Aviation safety inspections; and
- Aviation safety surveys.
The goal of such activities is to identify problems before they actually pose a real danger. Being compliant means:
- Documenting how and when you will perform such activities; and
- Actually following through on them.
How to Identify Hazards with Predictive Risk Management
Predictive risk management attempts to:
- Identify possible risks in a situation based on given circumstances;
- Identify new threats in hypothetical scenarios; and
- Anticipate needed risk controls.
Predictive hazard identification simply means performing predictive risk management operations with a goal to identify hazards. The way to actually practice this is document how your various predictive processes include hazard identification, such as how findings will be integrated into your issue management system.