Why Aviation SMS Audits Are Important
The objective of Aviation Safety Management Systems (SMS) is to:
- Proactively manage safety to reduce risk;
- Identify potential safety hazards;
- Determine operational risk, and
- Implement control measures mitigating identified risk.
The Accountable Executive is responsible to ensure the aviation SMS is functioning properly across the entire organization. In addition to ensuring the SMS is properly implemented, accountable executives must regularly review organizational safety performance. Whenever shortcomings are identified, the accountable executive is in charge of directing necessary actions to address substandard SMS elements.
To help determine whether an aviation SMS is compliant and implemented properly, internal and external auditors review common SMS elements. In most cases, these checklists evaluate items found in aviation SMS gap analysis models. These models are created by regulatory agencies and standards-setting bodies, such as
- Transport Canada and
Auditors use predefined, industry-accepted auditing checklists to objectively evaluate SMS implementation.
Related Aviation SMS Auditing Articles
- Audit Checklist: 10 Things to Prepare for Aviation SMS Audits
- How to Create an Aviation SMS Audit Plan
- Real Difference between an Aviation Safety Audit vs. Inspection
Aviation SMS Auditors Viewed with Suspicion
Aviation SMS auditors are usually not welcomed with open arms as they visit operators to
- pour through their SMS documentation;
- conduct interviews; and
- verify that all employees know their role in the aviation SMS.
SMS auditors and inspectors tend to be high-stress sources for safety managers and accountable executives. An auditor wielding a pen and checklist can be quite nerve wracking.
It’s easy to view auditors as "outsiders" who are trying to uncover damning information to prove your aviation SMS implementation is doing “something wrong.” It’s equally easy to forget that audit preparation is one of the most valuable time periods for strengthening your SMS implementation.
Learning to think like an auditor will not only help you perform better on aviation SMS audits, but it will:
- Improve productivity during audit preparation;
- Reduce the amount of time required by the SMS auditors that could disrupt operations;
- Hone ability to spot compliance red flags; and
- Improve global risk management processes (not just during audit preparation).
Good aviation auditors provide a benchmark for how to “think like an auditor.” These types of auditors show up at your door ready to illuminate and cooperate in order to improve your safety management system. This is the same attitude safety managers need to have when working with their SMS implementations as well.
Interpret Compliance Requirement of Oversight Agencies
Aviation SMS compliance requirements are not set in stone. They are also certainly susceptible to various interpretations based on one's professional background and education. In fact, you should interpret how compliance requirements relate to your operations.
The best SMS implementations focus on tailoring the aviation SMS to meet unique operational requirements. An aviation SMS implementation is not a "one-size-fits-all" scenario, but varies slightly according to the operator's
- Industry type (airline, airport, maintenance, FBO, flight school, manufacturer, etc.); and
- Oversight (regulatory, standards bodies and contractual obligations from clients).
Not everyone interprets the same regulatory guidance and requirements in the same way. This point highlights the importance of safety managers and accountable executives to not only understanding SMS implementation requirements, but also the logic behind the SMS requirements.
Therefore, do not rely on auditors for "perfect" guidance:
- SMS auditor’s job is not to guide you; but
- To assess whether your SMS implementation meets defined standards.
Related Aviation SMS Auditing Articles
- How Integrating QMS and SMS Will Improve Aviation Safety Audit Performance
- 5 Ways to Avoid Common Aviation SMS Audit Findings
- Aviation Safety Audits 101: Prep and Pass - with Examples and Checklists
Operators Have Flexibility in SMS Implementations
Having the ability to customize an SMS implementation to align with operational differences is obviously great news for the widely heterogeneous group of aviation service providers. This affords operators two distinct advantages over a strict prescriptive SMS implementation:
- Flexibility in conducting operations to retain a competitive business advantage; and
- Ability for operators to create SMS risk management processes that best fit your company, and make compliance requirements work for you.
Whenever auditors evaluate your SMS implementation, they are interpreting requirements to see how your SMS implementation addresses widely accepted SMS requirements. If you, as a safety manager, have not already done this, you will have a much harder time justifying within the bound of compliance why you made certain decisions in your SMS implementation.
If you HAVE interpreted SMS regulatory compliance correctly, you will eliminate much of the auditors' work, as they will see that you have done your homework and understand what you are doing.
Look for Documentation of “Why” in Risk Analysis Activities
One of the things we hear about most is that companies are hit with findings:
- NOT because their risk analysis outcomes were necessarily “wrong”; but
- BECAUSE they couldn’t show why or how they came to certain conclusions.
When an auditor asks you why you classified a safety issue with a particular classification, such as a hazard or root cause, and you “can’t remember” why you made that decision, it’s the same as saying I don’t know. Even if you had perfectly good reasons at the time of classification, it is all for nothing if you can’t provide necessary documentation that to an auditor.
The implication here is that many findings are products of lack of documentation rather than poor decision making. As inspectors have said, they mostly want to see that:
- You know what you are doing; and
- What you are doing is working.
Having strong documentation for why you make choices while conducting your risk management processes:
- Makes it much harder for auditor to attack your conclusion;
- Significantly reduces “forgetting” why certain decisions were made;
- Allows larger teams to participate in SMS audits due to self-supporting SMS documentation;
- Provides new safety managers with required documentation for activities performed before the new safety manager was hired; and
- Further demonstrates that you are meticulous in risk management activities.
Thinking like an auditor means being meticulous in documentation, such as documenting each step of decision making (i.e. history of how conclusions were arrived at) and justifying those steps with reason.
Related Aviation SMS Documentation Articles
- 5 Times Documentation Saves Safety Managers in Aviation SMS
- Why Documentation in Aviation SMS Is Important - Beyond Compliance
- Best Practices for Documenting Your Aviation SMS
Eye for Well-Organized SMS Manual or Aviation Safety Database
Organization looks good. Organization in aviation SMS manuals, spreadsheets and aviation SMS databases means:
- Consistent language and syntax (such as abbreviations and codes);
- Having no anomalies, such as SMS elements that are not in the right section;
- Looks neat;
- Includes clear navigational elements; and
- Logical sub-sections.
You know something is well organized when a stranger can follow and/or find things with little difficulty. Organization indicates that you have a proper high level understanding of the role of each SMS element. As with the other “think like an auditor" examples, it’s one more demonstration that you know what you are doing.
A good test is to invite a stranger to see how well they can navigate your SMS documentation.
Look for These 3 “Symptoms” of Compliance
Good auditors have a radar for symptoms of compliance, as well as symptoms of non-compliance. Experience inspectors have seen enough substandard SMS implementations and are familiar with the tell-tale signs that "things don't appear proper."
On the opposite spectrum, safety inspectors are more prepared to identify specific elements that demonstrate SMS compliance. We might call these “underlying markers” of compliance. In other words, when these elements are present, or certain risk management activities can be easily demonstrated in an aviation SMS, then usually the SMS implementation has a high degree of compliance:
- Consistent behavior in activities means similar pattern in how things are documented, assessed, classified, and accounted for;
- Fact-based decision making supported by the organization's SMS data means that service providers can justify certain decisions with specific safety charts, data, tables, etc.; and
- Can show relationship between documented safety risk management (SRM) and safety assurance (SA) processes and historical risk management activities while treating reported safety issues and audit findings.
Safety managers will be best-in-class audit performers when they take the time to ensure that their risk management activities are
- backed by safety data, and
- follow documented risk management processes.
Related Aviation SMS Auditing Articles
- 4 Tips for Passing Aviation SMS Audits -with Free Resources
- How Often Should You Conduct Aviation SMS Audit
- 4 Things Safety Managers Do to Perform Well on Aviation SMS Audits
Thinking like an Auditor Means Conscious Decision Making
All of the above points have one thing in common: they demonstrate conscious decision making on the part of safety managers, including:
- Ensuring that each decision matches documented risk management processes;
- Decisions are documented and justified using fact-based decision-making processes; and
- That the process aligns with SMS compliance guidance.
Make sure decisions are made passively or routinely.
Passing Aviation SMS Audits Improves with SMS Database
Auditors are human beings. Human beings are naturally "lazy" and will avoid unnecessary work whenever possible. When safety managers prepare all required SMS documentation before the arrival of the SMS auditor, the SMS auditor will be impressed. Furthermore, they will be less likely to dig deeply to uncover another possible shortcoming. This is also a natural tendency. When an auditor comes to an organized organization, they won't have to:
- Wait for requested SMS documentation when asked;
- Revisit the operator for those "extra" follow-up visits;
- Worry whether they missed "anything important."
In short, good SMS documentation really saves an operator considerable grief when faced with a team of SMS auditors. The best SMS data management strategy to perform well on SMS audits is the SMS database. Spreadsheets are not designed to store years' worth of dissimilar data elements. A low-cost, commercially available SMS database is the best SMS data management strategy to store and retrieve SMS documentation.
Not all aviation service providers need an SMS database. A good rule of thumb is that if your company has more than 40 employees, you should invest in an SMS database. It will be cheaper than trying to manage the SMS documentation requirements in a spreadsheet. Also, companies with fewer than 40 employees are recommended to acquire an SMS database if they have high employee turnover.
To learn how your company can improve SMS audit performance, check out these demo videos to SMS Pro, which has been one of the leading players in aviation SMS databases since 2007.
Published June 2017. Last updated December 2019.