Manage Safety Is Managing Risk
Ultimately, managing safety is about managing risk – a core value that can easily be overshadowed in large aviation safety management systems' (SMS) implementations.
In many ways, smaller organizations have a natural benefit for managing risk simply because:
- The scale is smaller;
- There are fewer variables to account for;
- Regulatory scrutiny is not as severe; and
- There is a tighter-knit community, therefore influencing safety cultures becomes easier.
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Aviation SMS and Aviation Safety Not the Same Thing
Aviation safety management systems and “aviation safety” are often used interchangeably, but they are distinct, separate things. Aviation safety is built from actions and mindsets that promptly and proactively identify hazards and assess risks. Aviation SMS is a bureaucratic system of processes that are designed to encourage the mindset and actions of safety.
Aviation SMS is a formal process that requires active participation from management and all employees. Participation is ensured by routine oversight activities, often in the form of audits, by civil aviation authorities and standards bodies, such as IATA and IS-BAO.
When we think about aviation safety programs, we must extend our thinking beyond the traditional safety programs that most operators embraced before the November 2006 ICAO mandate calling for the implementation of formal safety management systems. The legacy safety programs were voluntary and often implemented as an obligatory move to appease employees. Management had little expectation of financial incentives from the traditional safety program, therefore, financial and human resources were seldom adequate to make much "safety difference."
Other differences between the modern aviation SMS and legacy safety programs was that management maintained strict control and offered no promises to employees to act upon any safety concerns. There was no accountability. Employees could report safety concerns, but there was expectation that change would result or that employees would be notified of any subsequent changes.
In traditional safety programs, there was no formal CEO commitment to safety, which is required in an aviation SMS implementation. Furthermore, employees were not afforded protections from management should employees self-report accidents or errors. There was more focus on blaming employees for errors and accidents instead of focusing on modifying business processes that allowed hazards to adversely affect operations. Formal aviation SMS implementations are encouraged to provide these protections which are commonly seen in non-punitive reporting policies.
Aviation SMS Is Responsibility of Entire Organization
There are many other differences between modern, formal aviation SMS and traditional safety programs. Another major difference that bears mentioning again is the scope of the aviation SMS. Safety is no longer seen as the sole responsibility of the safety department. In the past, operations personnel were seen as third party actors and had no responsibility to safety. In an aviation SMS implementation, employees are trained on the SMS and are made aware of their responsibilities to manage safety. Of course, their level of involvement remains relative to their role within the organization.
Finally, there is an expectation of demonstrating continuous improvement in an aviation SMS that was not evident in traditional safety programs. In order to demonstrate continuous improvement, aviation service providers need more advanced data management tools to collect, store, analyze and retrieve safety information.
SMS data management tools play an incredibly important role in the success of an aviation SMS and are also the most limiting when the wrong SMS data management strategy is implemented. Aviation service providers who lack the necessary tools to manage SMS documentation requirements will not be able to participate fully in future predictive risk management activities.
Many operators don't care about predictive risk management, such as very small operators and operators with toxic safety cultures. These operators will devote more resources in demonstrating continuous improvement and quickly passing SMS regulatory audits than operators who have adopted SMS databases to manage the SMS documentation requirements.
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Keeping the above differences in mind is extremely important for recognizing that aviation SMS is a tool to be wielded by humans who practice safety. Humans are complex, tools should be simple. Your SMS implementation should be as simple as possible and also contribute to the bottom line.
Complex Safety, Simple SMS
Some people have pointed out that aviation risk management – and therefore aviation safety - is not a complex process, but rather a simple cycle of:
- Identifying hazards and associated risk;
- Reporting them as safety issues;
- Analyzing safety data and collecting data in a hazard register;
- Reviewing data trends; and
- Taking appropriate measures to account for data.
While all of this sounds simple and straightforward in theory, I couldn’t disagree more with the idea that safety is “simple.” In the nitty-gritty messiness of real life, full of uncertainty, changing relationships, sudden events, and unexpected consequences, actually practicing effective safety requires many different elements that need to work in conjunction to provide favorable results. These different elements are driven by people and personal dynamics, which I think anyone would have a hard time calling “simple.”
That being said, overly complex aviation SMS implementations – that is, the bureaucratic processes and procedures for improving risk management – do not need to be and indeed should not be “complex.” If an SMS' procedures and risk management processes are overly complex or complicated it will be much harder to practice safety, simply for the reason that the SMS will become a distraction and/or the SMS' risk management processes become a liability and eventually a deterrent to practicing safety.
An SMS' risk management processes should be as simple, quick, and easy to use as possible.
SMS Simplicity Fosters Involvement
Simplifying an SMS' risk management processes and procedures encourages front-line employees to become actively involved and hopefully take ownership of the SMS. The reasons for this should be rather clear:
- When hazards are identified and safety reporting processes are extremely easy and FAST, employees are likely to report safety issues;
- When safety reporting is complicated and time-consuming, employees are likely to avoid reporting issues;
- When safety professionals can easily manage reported safety issues, they will be more motivated to encourage high safety reporting activities;
- When safety professionals can quickly manage reported safety issues, they have more time available for other SMS activities, such as safety promotion and strengthening the safety culture.
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Simple SMS Processes Add Financial Value
An aviation SMS will never become "performant" and deliver financial value if employees are not reporting safety issues. Management will not have enough hazard and risk data to make informed safety decisions and improve operational processes. Even worse, if employees are in the habit of not reporting safety concerns, they may also be in the habit of having a slack, ambivalent mindset for
- hazard identification;
- awareness of risks;
- monitoring risk controls; and
- knowledge of existing problems.
That’s my philosophical way of saying: out of sight, out of mind.
I have seen on many occasions how cultivating a safety reporting culture in an aviation SMS has a kind of snowball effect on employees. Safety reporting metrics steadily increase over time until plateauing at healthy levels. This steady rise in safety reports indicates that making reporting processes easier will not just initially encourage employees to report more safety concerns, but will continually encourage them to report as time passes.
User-friendly safety reporting processes are not a panacea to poor safety reporting cultures. Safety reporting processes must be supplemented with:
- Credible safety policy;
- Employee protections against self reporting mistakes and accidents;
- Easy to follow risk management work flows that do not slow risk management to a crawl; and
- Continual streams of safety promotion activities to keep safety at the forefront of employees' consciousness.
Keep Risk Management Processes Simple
Just as complicated safety reporting processes will hurt involvement from front-line employees, overly complicated risk management processes can render an SMS disorganized and ineffective, and drive a safety manager up the wall. I recently received an email from a safety manager who was experiencing this exact problem in his organization, and he was at his wits' end.
When we are talking about risk management processes in aviation safety management systems, we are really talking about two things:
- The bureaucratic procedures management undertakes to manage reported safety issues and audit findings; and
- Management of change.
Bureaucratic procedures already often require rote actions that many managers don’t look forward to undertaking. Throw in some confusion and a few extra unnecessary steps, and as said it will drive a manager crazy. Frustrated aviation safety managers cannot be effective ones.
The same goes for operational department heads who are managing the preventive actions and corrective actions resulting from reported safety concerns. We have seen overly complicated risk management processes that may look great on paper when treating a major accident or incident, but these same risk management processes cripple an SMS when dealing with the majority of safety issues, which will be minor incidents and close calls.
I would be willing to bet that some of you were surprised to see management of change on this list. The reason is this, and make no mistake, management of change is a bureaucratic change to the processes, procedures, or rules of an organization. Regulating management of change to small steps is extremely important for an organization:
- To manage and track implementation of the change;
- To limit resistance to change from the employees who are affected.
In so many ways, aviation safety professionals are only doing themselves a favor by reducing as much workload as possible by keeping things easy and more manageable.
Related Aviation Risk Management Articles
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Final Thought: What to Do If You Are Stuck in a Complicated SMS
This is a tricky matter and will be different for each organization based on SMS maturity and which symptoms are particularly acute in the aviation SMS implementation. But basically, I see two options (if you have any other ideas I would appreciate hearing about them!):
- Small changes to safety reporting process and risk management procedures;
This is the patient approach, with minimal upfront changes, and the “easier” of the transitions.
- An overhaul of entire SMS risk management processes/procedures.
This would look something like adopting new aviation SMS software to save time and improve efficiencies. While new SMS software would probably be the most efficient route, it also requires a lot of implementation and training. But the argument is that if your SMS is broken, you have to fix it as soon as possible to start benefiting from the improved operational processes that an SMS will bring.
Both approaches above have their pros, cons, and limitations. Trying to make changes to risk management procedures/processes may be impossible if stuck with cumbersome safety software. Of course, trying to adopt a new software or system requires money and resources that management may not have or be willing to cough up.
If stuck in such in a seemingly hopeless bind, safety management teams will have to find innovative and creative ways of simplifying their SMS implementation. A good place to start is by asking employees what changes would help them the most, and working within whatever capacity possible to make it happen, even if only partially.
How do you identify failures in your SMS implementation? This following resource may help.