SMS Implementation Guidance Still Needed

Over a dozen years (Nov 2006) have passed since ICAO issued its first mandate requiring member states to implement formal, structured aviation safety management systems (SMS).

By now, I would like to believe there is considerable guidance available for aviation service providers to implement their aviation SMS. However, approximately ten percent of the people I encounter in my work as a provider of aviation SMS software request guidance on setting up their aviation SMS.

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Other operators that I work with have already started their SMS implementations. Consequently, they have different but related immediate needs. The others are looking for guidance on:

• Airline & Airport KPIs 35%;
• Aviation Safety Audit Checklists 25%;
• Gap analysis and SMS implementation checklists 15%;
• Safety policy templates 10%; and
• Aviation safety database solutions 5%;

Ten percent is a sizable number of managers needing help setting up their SMS. This article will help offer some guidance and point you in the right direction whether you are:

• Just starting an SMS implementation;
• Reviewing your existing SMS implementation; or
• Taking charge of an ongoing SMS started by another safety manager.

Planning Your Aviation SMS

Planning your SMS implementation first involves getting top management support. This may be a simple statement that one can quickly read and ignore, but this statement is very important.

Without top management support, your SMS implementation will certainly fail. More than once each year, I have seen active SMS implementations wither away after new management comes in without the same values or commitment to the SMS as maintained by previous management.

Furthermore, when aviation service providers lack commitment from upper management, they will have continual challenges acquiring adequate resources to manage the SMS. This becomes especially troublesome and frustrating when newly appointed upper management has no interest in the SMS, nor do they take the SMS as seriously as they should. When does such a scenario play out?

Currently, there is an airline that was recently purchased due to its extraordinary operational capabilities and recent track record. This airline had a "best-in-class" SMS that has been written about in many safety articles and magazines. Now that the airline has been sold, SMS is not as important to the new management. The new management's core objective is to grow the airline a bit more and turn it over for a profit.

In this case, new management's goals and objectives no longer align with the safety goals and objectives. New management is focused on cutting corners and trimming "unnecessary" spending. In short, I'm concerned that this SMS will backslide from a best-in-class SMS to a "check-the-box" paper SMS. Top management support is incredibly important. Safety managers must ensure that safety goals and objectives align and complement top management's goals. What is the best solution to this puzzle?

How would you react, as a safety manager, when management no longer explicitly supports a functioning SMS? This is a tough situation to be in. In the case above, the safety manager will exit the company after devoting over a dozen years in nurturing and growing the aviation SMS.

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No Perfection in Planning Stages of SMS Implementation

During the planning phase, the safety team will be reviewing your organization's existing

• safety processes,
• procedures,
• tools, and
• activities.

Management will determine how the aviation SMS will function within your organization.

What will the SMS look like?

Which high-level safety goals and objectives does your organization wish to achieve?

Does management expect the SMS to deliver financial benefits? Or do you only want to check the box?:

Don't worry about details yet. But the safety team in charge of the SMS implementation will need to get a general understanding as to how much effort to devote to the SMS. In short, you can do it in a fast, superficial way with little regard to changing existing business processes. Alternatively, upper management may realize that an SMS is truly the way to improve business operations across the entire organization by implementing tried and tested risk management methodologies.

Many safety managers will become paralyzed by too much analysis. They expect everything to be perfect and expect management's wholehearted acceptance and participation in the SMS implementation project. Don't worry about getting this perfect the first time around. Your SMS is a fluid, living entity that will be constantly evolving as your SMS implementation matures.

Sources for Aviation SMS Implementation Guidance

During the planning phase of your SMS implementation, you are encouraged to research SMS information from differing sources. Many of our clients operate in countries where their civil aviation authorities (CAA) offer little guidance on SMS implementations. In these cases, I highly recommend reviewing information from:

• ICAO's Safety Management Manual
• FAA Safety Management System
• Australia (CASA) Safety Management Systems

I have been impressed for many years at the high quality of guidance put out by the Australians.

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Consider Additional Resources for Your SMS Implementation

As you are planning your aviation SMS, you should consider which additional resources are needed to meet your goals and objectives. You should consider these questions:

• Are you merely trying to check the box? Do the bare minimum?
• Are you implementing an aviation SMS to comply with a client's expectations or contractual requirements?
• Are you developing your SMS to comply with regulatory requirements?
• Do you have demanding auditors who know SMS requirements? or
• Are your auditors merely "passing through" and easy to please?
• Does upper management earnestly support your SMS?

Depending on answers to these questions, you will have differing budgetary requirements. Budget is important. Don't expect much budget when management support is "reluctant" and "obligatory." Depending on the size and complexity of your organization, you will need a sufficient budget for:

• Aviation SMS training courses;
• SMS database software;
• Safety managers & additional staff; and possibly
• Aviation safety consultants.

Managing Safety Data in Aviation SMS

In the early years of your SMS implementation, you may try to manage safety data using existing tools, such as:

• Word documents;
• MS Access databases; and
• MS Excel spreadsheets.

Very small aviation service providers may manage their SMS data using these simple, readily available tools. Companies with more than 30-50 employees are advised to have professionally designed safety databases that have been developed to specifically manage the aviation SMS requirements.

While an operator could create their own SMS database, the accrued expenses and, risk over time will outweigh the cost savings from building your own SMS database. Very large operators can modify their existing quality management systems (QMS) to support additional SMS requirements. If you currently use a QMS and wish to include facilities to manage SMS documentation requirements, the primary areas to focus on include:

• Confidential safety reporting system;
• Hazard register;
• Risk control monitoring;
• SMS training documentation; and
• Safety promotion.

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Fastest Way to a Compliant SMS Implementation

Small operators with high employee turnover are also recommended to use a centrally located SMS database. While small operators can manage SMS data using spreadsheets, high employee turnover is a discerning trigger to prompt an operator to use commercially available systems for continuity purposes.

The advantages of the commercial SMS database outweigh the small expense. Companies with fewer than 20 employees can expect to pay as little as $300 monthly for complete SMS database management services. Commercial SMS database services provide operators with:

• Faster, less risky SMS implementation times;
• Tried and tested, industry-accepted risk management workflows;
• Web and database servers, including bandwidth;
• Data backups;
• Technical support;
• Routine bug fixes and software enhancements;
• Subject matter expertise; and
• Tools to manage all SMS documentation requirements.

For every aviation service provider wishing to jump-start their SMS implementation, an SMS database is the quickest path to achieve an audit-worthy, ICAO-compliant SMS. This makes sense for most operators as their expertise revolves around providing their core services, whether they are charter services, total aircraft maintenance, or air traffic services.

Not All SMS Have Same Data Management Requirements

Depending on the maturity of your SMS implementation, you will have different requirements. As a matter of fact, not only does SMS maturity play a role, a bigger determinant will be the organization's goals and objectives. Before spending too much time determining the best strategy to implement the SMS, the safety team and the accountable executive must have a "heart-to-heart" meeting to ensure expectations are aligned.

Very often, a newly appointed safety manager assumes the position of the safety manager with high expectations. The safety manager is motivated to learn and to do the best job possible with the SMS implementation. Based on the safety managers' research and education, the safety manager may have the expectation that management wants a full-blown, soup-to-nuts SMS.

Sad to say, many safety managers become disillusioned when they realize that upper management has a different vision for the SMS. The scenario becomes even more difficult when upper management sends mixed signals, where part of the management team wants a bonafide SMS, while other managers see SMS as another required regulatory hurdle to leap and forget. In these cases, the SMS implementation will not be smooth but will suffer many setbacks as the safety team combats resistance to the SMS.

Related Aviation SMS Implementation Articles

• FAA Part 5 - Understanding Scope of Aviation SMS Implementation
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• How to Complete Phase 4 of Aviation SMS Implementation [With Free Checklist]

Due to the myriad scenarios that could possibly affect aviation service providers during the early years of their SMS implementations, we recommend that you acquire tools that offer more features as your SMS matures. Too much, too soon may overwhelm some employee groups. This becomes evident most quickly with operational department heads.

Department heads are already working very hard and have little spare time to implement processes required by the SMS. When they realize their duties and responsibilities are suddenly increased due to the SMS, they may silently rebel. Therefore, it may be best to educate first, and then slowly bring the department heads into line.

In the early stages, keep it simple. For example, your data management requirements won't be as demanding until you finish up phase two of the SMS implementation plan. Up to phase two, you will need a software module that addresses:

• Hazard reporting;
• Corrective and preventive action tracking;
• Basic risk analysis charting tools;
• Gap analysis tools;
• SMS implementation management tools; and
• Version-controlled documentation capabilities.

By phase three of the SMS implementation, your data management requirements will grow, so be prepared for these. Very often we see mid-sized operators spend four to six years trying to use the same data management strategies that were successful with auditors in the early years. As SMS auditors become more demanding, they want to see evidence of continuous improvement and regular SMS performance monitoring activities.

From an SMS auditor's perspective, if it isn't documented, it didn't happen. This is the driving force behind a robust SMS data management strategy. This is also a compelling argument to adopt a low-cost, commercially available SMS database that is used by hundreds of other aviation service providers.

An operator's expertise is not SMS database management, nor will it ever be. This reality is easy to convey. Imagine that an operator has only a few chances to play with different SMS data management scenarios. Now consider the commercial SMS database provider. They work with hundreds of different operators; therefore, they are exposed to more opportunities to develop a more robust SMS data management platform.

Another simple comparison would be that commercial airlines don't manufacture their own aircraft. They leave this task to the experts. The same should apply to SMS database management to achieve the best results.

Final Thoughts on Setting Up Your Aviation SMS

Setting up your aviation SMS is not rocket science. A lot of the heavy lifting can be done if you have the proper tools. Without a doubt, you will not get these tools unless you gain top management support.

Best advice?

• First step, and most importantly, get top management support.
• Then become familiar with the requirements.
• Be open to new ideas.
• Don't develop your own database unless you are a large company.
• Finally, get safety management tools to save you time and energy.

You can save time on an SMS implementation if you have the proper tools. What do these tools look like? Since 2007, SMS Pro has been working with operators on their SMS databases. Here are some short videos explaining what a commercial SMS database can do for you.

Want to see SMS Pro live? Sign up for a live demo.

Last updated September 2023.