Why Review Safety Risk Management Procedures?
Aviation safety managers come and go. At the most volatile organizations, we see safety managers change every six months to a year.
The reasons safety managers leave their positions include:
- Demotions (usually from poor safety audit results);
- Voluntary resignation (overworked, lack of management support); and
- Permanently changing jobs and leaving the company.
In most cases, your safety programs' risk management procedures are:
- Inherited from unknown predecessors; or
- Developed during a hurried aviation SMS implementation phase.
Related aviation SMS implementation articles...
- Overview of 4 Phases of Aviation SMS Implementation
- How to Implement SMS in Small Organizations
- How to Implement a Sustainable SMS Program (with Free Resources)
In the second instance, there is a high chance that your risk management processes were copied almost verbatim from another source. Furthermore, there is another high probability that these procedures came from an aviation service provider that differed in
- resource availability, or even
- industry segment.
For these reasons, it is imperative that new safety managers review their aviation SMS' risk management processes. It may be that your predecessors could not even spell SMS and simply copied and pasted from another SMS manual, or worse yet, simply purchased an SMS manual. Many times I've heard stories from auditors finding the names of other companies in an operator's SMS manual.
In this article, we will describe how to review your aviation SMS risk management processes and also provide a sample workflow to compare your processes.
How to Review Safety Risk Management Procedures
So you have decided that your aviation SMS requires review. As a hard-driven, professional safety manager, you will either need to:
- Create new risk management processes; or
- Review what is already in place.
One way to do this is to review existing literature on aviation risk management procedures. Some useful resources may include:
- FAA's Risk Management Handbook (pdf);
- FAA System Safety Process Steps (pdf);
- Transport Canada Risk Management Process; and
- Australia Safety Risk Management (pdf).
There are certainly more resources out there, but these are easy to understand. I particularly like what Australia has been doing with their aviation SMS resources over the past dozen years.
Each of the above resources has their advantages and disadvantages. For a review, I prefer I simple flowchart based on the complexity of the organization. For example, smaller organizations generally do not have safety committees. Furthermore, not all issues require in-depth investigations.
How Often Should Risk Management Processes Be Reviewed?
If you are lucky and have a stable management structure, you may be the safety manager for five to ten years. There may also be a high probability that you implemented the original aviation SMS. Regardless, you should review your risk management procedures annually.
Use one of the above resources to get ideas or use one of our simplified workflows. Our recommendation is to keep your risk management procedures as simple as possible.
I have seen some incredibly complex risk management workflows that make my eyes spin. Some overzealous safety manager is trying to impress management or to demonstrate their value by coming up with workflows that would excite a nuclear physicist, but cause others to roll up their eyes and ignore.
Complex processes may be required, but when employees are not following prescribed procedures, unnecessary and uncontrolled risk is injected into operations.
Exceptions to Standard Risk Management Procedures
There will always be exceptions in your risk management activities where one particular case doesn't fit nicely into a designed workflow. Your workflow should be flexible to accommodate a variety of reported accidents, incidents or irregularities. You may wish to incorporate triggers, such as:
- The extent of injuries;
- Estimated $ amount of damage;
- Potential harm to company reputation; or
- Environmental damage.
Related Aviation Risk Management Articles...
- 3 Main Components of Aviation Risk Management
- Difference between Reactive, Predictive and Proactive Risk Management in Aviation SMS
- 8 Stages of Safety Events in Aviation Risk Management Programs
Don't Be a Victim to This Common Problem
Complex risk management procedures will almost always get you in trouble with auditors.
For example, you may believe that your risk management procedures cover the worst-case scenarios. Your procedures are bullet-proof and are highly detailed.
Aviation SMS auditors come to visit your operations and you proudly show them your masterpiece. It is beautiful. Very colorful with arrows going from hazard reporting to risk assessment to safety committee review, etc. The astute auditor will then start reviewing your treatment of reported safety issues and/or audit findings.
What trips up safety managers the most is that they don't abide by the processes that they have created. They create these very elaborate safety risk management processes and yet don't follow all the steps for every accident, incident or irregularity.
For example, your risk management workflow may include investigations requiring:
- Photos of damage or injury;
- The sequence of events;
- Root cause analysis;
- Human factors analysis; and
- Lessons learned.
If your treatment of routine incidents and irregularities deviates from your risk management workflow, then you will legitimately have an audit finding.
You may feel disgruntled at how nit-picky SMS auditors are when they dissect your SMS processes. There is a reason.
Why Do We Have Procedures?
When employees are hired, they are trained to perform their assigned duties according to proven processes that have worked in the past. When these procedures are documented, they can be shared with new employees to ensure that the company continues to provide the service in the most efficient manner possible.
When employees don't follow procedures, they are operating outside the bounds of the designed system. Management may not have accounted for operational deviance, therefore, implemented risk controls may not detect or prevent the manifestation of an operational hazard. In short, management has no control, no assurance that the mission will be fulfilled unless employees are performing the task that has been demonstrated successful in the past.
Procedures keep the organization walking along a controlled pathway. When employees step from the path, management has no control. Procedures provide assurance that the mission will succeed as long as procedures are followed.
Related Articles on Aviation Procedures
- How Routine Procedures Assist in Aviation Risk Management
- Are Your Aviation Safety Program’s Procedures Effective?
- How to Document Your System Processes in Aviation SMS
Final Thoughts on Aviation SMS Risk Management Procedures
Risk management workflows should never be considered "perfect" and do it once and forget it. There may always be room for improvement.
If your procedures never change, this is an indication that you do not have a mature SMS. SMS processes are an interaction between the design and implementation of procedures followed by monitoring and detecting anomalous behaviors. The design phase is called safety risk management (SRM) and the monitoring phase is known as safety assurance (SA).
SMS is a process that works, but you have to work the process in order to benefit.
On the same token, when processes are not broken, don't fix them!
As an aviation safety professional, you will have to learn the best practices of aviation safety risk management. Technologies change, and processes are considered a "technology." Poke around once in a while and see what others are doing. Look at how other industries are managing their risk. We can always learn something new.
Risk management processes are more easily followed when you use aviation SMS software. With commercially available and low cost SMS software, your safety team can be assured of standardized workflows and automatic notifications.
Below are a couple simplified risk management workflows adapted from South Africa's Civil Aviation Authority Safety Risk Management Procedure. I saw this a few years ago and I liked the simplicity.
Published in August 2015. Last updated January 2019.