What Change Management is in Safety Management Systems
Change management in safety management systems is an extremely important topic. Not just for safety performance, but also for showing auditors.
You can bet that poorly managed or documented change will result in an audit finding. The reason is that change management:
- Demonstrates your understanding of the steps in the Safety Risk Management process;
- Shows the quality of your risk analysis activities;
- Validates your ability to document activities; and
- Bridges the gap between Safety Risk Management and Safety Assurance.
You might sometimes see management of change (MOC) listed under the Safety Assurance or Safety Risk Management pillars, which can be true depending on the activity. In fact, we even have it listed in places as being a part of SA.
Regardless, the fact is that change management has increasingly been used and inspected by oversight agencies as a process that very closely resembles the SRM process.
- Describe the change;
- Identify hazards;
- Identify risks;
- Assess risks for acceptable level of safety (ALoS); and
- Develop new risk controls to process change.
That being said, change management definitely has SA qualities, which is because it works best when used to bridge the gap between SRM and SA.
What the SRM Process is in SMS Programs
The Safety Risk Management Process in aviation SMS programs has four distinct goals:
- Identify hazards (old and new);
- Identify risks that are associated with hazards;
- Manage risk controls; and
- Establish and maintain an acceptable level of safety (ALoS).
The basic process of SRM is to:
- Understand a system by describing/outlining it;
- Identify old and new hazards;
- Identify risks associated with those hazards;
- Assess risks (with a risk matrix); and
- Develop needed risk controls.
This constant process keeps “SMS programs on their toes” so to speak. It allows SMS programs to adapt to changing conditions by:
- Creating new risk controls;
- Updating existing controls to meet changing needs; and
- Retiring controls that are no long relevant.
The end result should be a very high level of documentation that demonstrations your operational risk profile. This overused phrase simply means the “personality” of your SMS program.
What the SA Process is in SMS Programs
The Safety Assurance Process is performing arm of SRM. Safety Assurance puts the documentation, controls, and activities of SRM into action. Some common SRM activities are:
- Reviewing, measuring, and monitoring safety data;
- Reporting safety issues;
- Managing safety issues;
- Ongoing monitoring of effectiveness of available management resources (i.e. risk controls) during issue management; and
- Ensuring that program is improving (continuous improvement).
The SA and SRM processes work together in a symbiotic relationship. If the data, issue reporting, and issue management processes are not performing, then the SRM process will be used to make safety changes. These safety changes in turn should help the SA process. This process endures ad infinitum.
Management of Change Connects SA and SRM Processes
Management of change is an essential link between the SA and SRM processes, as it helps both processes (communicate). As discussed, the process of change management follows a similar path to SRM. However, the outcomes and results of change management:
- Drive both the SRM and SA processes simultaneously.
To make this clear, change management:
- Follows similar process to SRM;
- Prompts SA and SRM activities at the same time.
For example, during change management one of the first activities is to identify hazards (SRM activity). However, in the event that new hazards are found the outcomes are that:
- These new hazards are usually managed as safety issues (SA activity); and
- These new hazards are accounted for in the hazard register (SRM activity).
Both of these activities happen at the same time. These exact same outcome activities occur with:
- New risk controls; and
- Additional updates to SMS bureaucracy.
Changes will be documented and accounted for in the process of safety risk management, and processed with SA activities.
Final Thought: Understand Goals of MOC as Bridge for SA and SRM Processes
It’s critical to understand that MOC is an SRM activity that bridges the gap between SA and SRM because:
- Organize separation of concerns, such as accounting for the change (SRM) and processing the change (SA);
- Have better organization of change management; and
- Be better able to defend and express change management operations to an auditor.
The third bullet point is especially important. Regardless of the quality of your change management, if an auditor detects any discrepancies, or if you can’t quite “remember” why a choice was made, or if you can’t clearly explain your MOC process and how the parts relate to SA and SRM, you can count on a finding.
So be very clear during MOC:
- What you are doing;
- Why you are doing it; and
- How each activity fits into the SA and SRM processes.
If you do this and document well, count on strong audit performance and high quality change management operations.
For more information about performing management of change, you will find these templates helpful: