What You Need to Know about Aviation SMS Implementation Plans

If you are reading this, chances are you have just begun implementing your aviation safety management systems (SMS). Or, you would like to see how your implementation plan stacks up against the suggested process for creating an implementation plan.

Either way, the important things you need to know about aviation SMS implementation plans are that they:

• Organize all elements of SMS;
• Provide you with a road map of implementation-order;
• Help you establish timelines; and
• Allow accountable executive and management teams to review progress.

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Aviation SMS implementation takes time – usually 3-5 years. There will always be setbacks and struggles, but implementation plans will inevitably expedite this process by always keeping the “bigger picture” at the forefront of your decision-making.

As alluded to above, the accountable executive has particularly high stakes in the SMS implementation. Accountable executives will regularly demand updates about the SMS implementation. They are responsible for making sure the SMS is properly implemented and functioning in all areas of your company. Furthermore, accountable executives must demonstrate that they regularly review organizational safety performance and be able to manage identified shortcomings or roadblocks in the implementation.

By providing regular updates regarding the progress of the SMS implementation, safety managers can collaborate with accountable executives to discuss challenges, such as:

• Lack of budget for required SMS data management tools;
• Increasing participation in safety meetings;
• Failing to achieve stated safety goals and objectives;
• Resistance to aviation SMS by upper-level managers or problem employees;
• Appointment of additional key safety personnel (for larger companies > 150 employees usually);
• Managing SMS documentation requirements;
• Qualified instructors for hazard identification training;
• How to demonstrate to regulators that the accountable executive can monitor SMS performance effectively;
• Data points for SMS performance monitoring;
• Training upper-level managers on SMS principles and risk management processes; and
• How to demonstrate in perpetuity the continuous improvement of the SMS.

There are many factors to consider as SMS implementation teams enter the planning phase of the SMS. The sooner these challenges are addressed, the more positive the impact on safety cultures and the success of the SMS. There are many benefits from properly implemented aviation SMS. Sadly, a large percentage of you will never realize these benefits due to:

• Lack of planning;
• Inadequate top management support;
• Toxic safety cultures;
• Competing budget priorities;
• Poorly educated management staff on principles of SMS; and
• Resistant attitudes toward true effectiveness of SMS.

Related Articles on Finding Resistance to Aviation SMS

• How to Reduce Resistance to Aviation SMS with Difficult Employees
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Many managers will resist SMS because they don't believe the hype that aviation SMS can benefit operators. They see SMS as another way for government regulators to put their foot on the back of operators' necks to oppress them. These operators may already believe:

• their operations are "safe enough;" or
• risk is already as low as reasonably practical.

In the early years of your SMS implementation, uncovering and overcoming resistance to the SMS should be a top priority. This is a common dilemma faced by safety professionals all over the world and in EVERY aviation industry segment, whether you are an:

• Airline;
• Airport;
• Flight school;
• General aviation;
• FBO; or
• Aviation maintenance organization.

You will find managers who have been successfully managing aviation operations for decades and resist this governmental intrusion. So you must be prepared to identify these resistant managers. It is not always easy.

Here is the suggested process for creating an aviation SMS implementation plan.

Get Aviation SMS Implementation Plan Checklist

The very first thing you need to do before anything is acquire an aviation implementation plan checklist. These checklists are simple but will provide you with a “bigger picture” scope throughout the entire process of implementation.

Additionally, implementation plan checklists:

• Show all implementation elements for each of the 4 pillars;
• Allow you to further customize the checklist with dates, notes, etc.;
• Help you organize your implementation progress;
• Educates accountable executive of high-level SMS requirements; and
• Allows accountable executive and management team to monitor SMS progress;.

The ICAO checklist (see link above) is always a good plan to follow, though there are other implementation checklist resources available. Surprisingly enough, the IS-BAO SMS implementation plan is among the best I've ever seen. Why is this surprising? Because their gap analysis checklist is too elementary to be useful to anyone.

Make sure your checklist is in Excel, where you can add further columns and configurations so that your implementation checklist is yours. The best practice is to store your SMS documentation in a centralized data repository to reduce risk.

SMS Implementation Data Management Strategies

More than once safety managers have taken a company's SMS documentation when they left the company, often on their personal laptops. An SMS database is the best recommendation for managing SMS data as there are many SMS documentation requirements.

The sooner your company acquires an SMS database, the less risk to your SMS. You will also be setting your company up for REALIZING the true SMS benefits, instead of pouring money down a hole with little expectation to see a return on your investment.

You can build an SMS database in-house. The expense of development and the lack of subject matter expertise may preclude you from developing your own SMS database. Some low-cost commercially available SMS solutions manage ALL SMS documentation requirements and allow management to monitor SMS performance in real time.

Related Aviation SMS Database Articles

• What Is an Aviation Safety Database
• How to Choose the Best Aviation Safety Database Software
• How to Manage Aviation Safety Programs without Complex SMS Databases

Be aware of flooding your company with "point solutions" to manage SMS data. A point solution is a software that addresses a single business objective, such as:

• Safety reporting system;
• Training and qualification system;
• Auditing system;
• Document management system; or
• Safety survey tools.

It is easy to fall prey to point solutions because you may have some of these already in service. Short-sighted management teams neglect to foresee the burden of monitoring all of these systems and aggregating the results to identify trends. Furthermore, the accountable executive is tasked to regularly review organizational safety performance and whenever necessary, direct actions to fix substandard safety performance.

The point is that mining data to detect trends in six to eight systems, or from spreadsheets is adding unnecessary risk. Whenever safety managers are working on their SMS implementation, one of their first actions is to determine their SMS data management strategies, as this will have a long-lasting impact on their ability to monitor SMS performance.

Identifying safety issues and easily spotting trends becomes untenable even for smaller aviation service providers with 50 employees. If your company has more than 50 employees, this is a no-brainer. Get the SMS database. Ditch the spreadsheets. Carefully consider the overuse of point solutions.

When one understands the intent of the regulators for requiring SMS, one will recognize the need for a long-term solution. Choose wisely. For those who don't quite understand the objectives of SMS, or you need to educate your safety team or the accountable executive, the FAA summarized SMS objectives very nicely as:

The objective of Safety Management Systems (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

From the above, you can see that safety teams will need the facility to aggregate data and create trend charts. And you will be doing this for many years to come. The best solution is to get SMS database software that will automate much of this work for you and allow management to review trends at their convenience.

The reason I hammer this data management strategy so fiercely is that so many SMS become mere paper exercises without the proper tools to efficiently collect data, identify trends, and monitor the performance of the SMS. This is an important point!

Related SMS Trend Analysis Articles

• Aviation Safety Managers' Best Friend - Trending Charts
• How to Use Trending Charts in Aviation SMS
• Six Steps How to Perform Trend Analysis in Aviation SMS

Tasks for Getting Aviation SMS Started

Having an SMS dropped into your lap is a disorienting and overwhelming experience. If this situation sounds familiar before you worry about creating your implementation plan you need to perform some initial tasks for getting your SMS started.

These initial tasks are as follows:

1. Get upper management support;
2. Adopt primary SMS data management strategy, such as aviation SMS software;
3. Identify and organize key personnel (including safety org chart);
4. Establish safety duties and responsibilities of safety roles;
5. Create key hazard reporting policies;
6. Evaluate existing safety culture;
7. Review historical safety data (if applicable);
8. Perform gap analysis;
9. Create safety goals and objectives; and
10. Choose your key performance indicators (KPIs).

Why perform these tasks before creating your implementation plan? Creating an implementation plan without detailed knowledge of "what you’re dealing with" is like trying to fly an aircraft with a blindfold on.

These initial tasks:

• Establish foundation for expectations;
• Allow you to understand your SMS' unique needs; and
• Allow you to establish realistic deadlines, goals, etc.

In short, these initial tasks make your implementation plan more:

• informed,
• accurate,
• realistic, and
• specific.

The accountable executive and the safety manager will also feel much better about the decisions and expectations that are set.

You will notice that key performance indicators (KPIs) are mentioned above. In the safety world, some safety professionals call KPIs "safety performance indicators" or SPIs. Don't worry, SPIs are the same as KPIs, but with a focus on safety goals and objectives. You can use KPI or SPI with equal ease when discussing aviation SMS, but some new safety managers may have the question as to which is correct.

SPIs are subsets of KPIs. Your organization's KPIs may include financial and operational concerns. Management teams are used to hearing about KPIs. Is there a time and place to say SPI instead of KPI? I'm guessing that you should only use SPI as a matter of personal preference or when you need to explicitly differentiate between the two. KPI = SPI

Related Articles on Key Performance Indicators (KPIs) in Aviation SMS

• What Is a Key Performance Indicator (KPI) in Aviation SMS?
• How to Set and Monitor Key Performance Indicators (KPIs) in Existing SMS
• How to Automate Key Performance Indicator KPI Monitoring

Gap Analysis and Evaluation of 4 Pillars

While a gap analysis was pointed out in the last section as being an essential initial SMS task for getting started, it deserves some more special attention. A gap analysis should evaluate your existing SMS in the following areas:

• Safety policy and objectives
  • Management commitment and responsibility
  • Safety accountabilities of managers
  • Appointment of key safety personnel
  • SMS implementation plan
  • Coordination of emergency response planning
  • Documentation
• Safety risk management
  • Hazard identification process
  • Risk assessment and mitigation process
• Safety assurance
  • Safety performance monitoring and measurement
  • The management of change
  • Continuous improvement of the SMS
• Safety promotion
  • Training and education
  • Safety communication

By "evaluate", we are talking about two things:

1. Where the SMS currently is; and
2. Where it needs to be (hence the “gap).

A gap analysis is an integral part of understanding your program's safety needs.

Related Articles on Aviation SMS Gap Analysis

• What Is a Gap Analysis in Aviation SMS?
• SMS First Steps - Gap Analysis
• 4 Best Aviation SMS Gap Analysis Strategies for SMS Implementations

Establish Greatest Needs of Company’s SMS

Understanding your company’s safety needs is much simpler than it might initially seem. Safety needs constitute the following 4 elements:

1. Level of compliance with oversight company;
2. Existing safety culture and Norms;
3. Amount of support from upper management; and
4. Resources available to influence compliance, safety culture, and upper management.

A “safety need” is simply something in your company that either detracts from or is apathetic to exposure mitigation. For example, all of the following can be safety needs:

• Having non-compliance for a particular element of safety;
• Lack of safety reporting culture;
• Indifference to safety decisions;
• CEO who does not take ultimate responsibility for SMS;
• Poor means of collecting/analyzing data.

The list goes on, but you should be able to see that each of these elements is something undesirable for improving/maintaining safe operations.

List Notes and Strategy on Each Element of Checklist

Remember your implementation plan checklist? Now that you have a good understanding of your SMS and organization, you can start to make some notes on each element of the checklist. Create another column for “Notes” in your checklist.

For each item in your checklist, these notes will:

• Help you evaluate the current status of that element;
• Make applicable notes that will help/impede your ability to implement it;
• Help you establish a strategy for implementing that item; and
• Lists how much needs to be done for that element to be implemented.

Next, create one more column on your checklist for “Strategy”. Review your Notes column, and for each element, list how (i.e., bullet point steps) you are going to implement the safety element.

For example, for the checklist item “Deliver training to reactive risk management,” you might list a strategy as the following steps in your “Strategy” column:

• Research reactive risk management training company;
• Provide reactive risk management training course to all employees;
• Store all signed-off training on an online document;
• Research web-based reactive risk management assessments that will store test data; and
• Have all employees take tests and review data.

Completing all of these bullet point tasks will allow you to effectively cross out this implementation checklist item.

More Articles on Aviation SMS Implementation

• Why Should We Implement Aviation SMS?
• Your Top 4 Risks to Aviation Safety Management System Implementations
• How to Implement SMS in Small Organizations

Establish Implementation Deadlines Based on Needs

Finally, based on your notes and your strategy, you should have a rough idea of how long it is going to take you to accomplish each element. Create one more column in your checklist for the deadline. For each activity, write the deadline in this column and then review your entire checklist.

Deadlines for each activity are often within the following:

• Phase 1: one to six months from start;
• Phase 2: about one year after completion of Phase 1;
• Phase 3: about two years after completion of Phase 2; and
• Phase 4: about two years after completion of Phase 3.

Note that especially in the case of phases 3 and 4, timelines will be heavily affected by the size and complexity of the organization. Typically, aviation SMS implementation takes 3-6 years. Larger companies may take even more time.

If you are a new airline, you will have to have a fully functioning SMS before commencing operations in many parts of the world where SMS is required.

Good luck with your SMS implementation.

How you manage SMS data storage and retrieval will affect the effectiveness and success of the SMS. We provide a web-based SMS database that addresses ALL SMS compliance requirements.

Review these short demo videos to see how we can help you manage your SMS. Your company will appear more professional in managing aviation SMS when you have the proper tools. Furthermore, this software assures accountable executives that the SMS is implemented properly and they can monitor SMS performance with utmost assurance.

Reduce your time spent with auditors! Make a good impression.

Last updated in August 2023.