Understanding Safety Policy
Many of the words and phrases used in aviation SMS have very specific meanings beyond those found in the dictionary. Hazard and risk, for example, have definitions that go beyond Merriam-Webster’s definition.
Safety policy is not one of those phrases. In fact, safety policy can refer to two distinctly different aspects of your SMS, which can be highly confusing when you jump in with both feet like I did.
Without context, safety policy is an ambiguous phrase. Much like the statement, “I’m going to the bank,” could be interpreted to mean that I’m on my way to a financial institution or that I’m headed to the riverbank, the definition of safety policy changes depending on when, where, and how we use it.
The Safety Policy Document
Before I dug into this topic, the first thing I thought of when someone said “safety policy” was a piece of paper, signed by an executive, making a flowery promise that everyone at the company values safety and management is committed to ensuring safe operations.
This is probably what most people not immersed in SMS would think. These kind of policies exist in all types of businesses and are used for everything from safety and quality to dress codes.
When developing an SMS, this kind of safety policy is called for, but there are some very specific points that ICAO requires.
The safety policy shall:
a) reflect organizational commitment regarding safety;
b) include a clear statement about the provision of the necessary resources for the implementation of the safety policy;
c) include safety reporting procedures;
d) clearly indicate which types of behaviors are unacceptable related to the service provider’s aviation activities and include the circumstances under which disciplinary action would not apply;
e) be signed by the accountable executive of the organization;
f) be communicated, with visible endorsement, throughout the organization; and
g) be periodically reviewed to ensure it remains relevant and appropriate to the service provider.
A well written safety policy of this kind will not only be more effective than a flowery promise, it will help to foster your safety culture. Check out this safety policy document from the FAA's pilot study and see if you can identify each point required by ICAO.
This document is also just one part, or element, of the safety policy pillar of SMS.
The Safety Policy Pillar
ICAO 9859 defines safety policy as one of the four pillars of SMS and identifies five key elements:
- Management commitment and responsibility
- Safety accountabilities
- Appointment of key safety personnel
- Coordination of emergency response planning
- SMS documentation
The document conventionally called a safety policy falls within the “Management commitment and responsibility” element of the overarching pillar of safety policy.
Despite being numbered in ICAO 9859, all five elements are essential to your SMS and shouldn’t necessarily be implemented in that order. For example, I can’t imagine I’d get much management commitment before establishing safety accountabilities, as the accountable executive needs to be established before they can sign the safety policy document.
These safety accountabilities also include defining lines of accountability throughout the organization, including the accountabilities of all levels of management. Those with the authority to make safety decisions must also be identified at each level. All of this information must be documented and communicated throughout the organization.
The third element is the appointment of key personnel. This one is pretty straightforward. It would read more directly as appoint a safety manager. Hopefully this is one of the first steps implemented in your SMS.
Another crucial piece of the safety policy pillar is emergency response planning. It's likely that you already have emergency plans in place, but implementing an SMS provides a great opportunity to review these plans and make sure they're properly communicated to all affected organizations.
Finally, SMS calls for documentation. There are a lot of moving pieces in a functional SMS that require documentation. In this case, ICAO is referring to two key parts of that documentation: the SMS Manual (or document) and the documentation generated by your SMS.
SMS documentation is a huge topic unto itself, so keep your eyes open for an entire article on that soon as I continue to explore aviation SMS.
Why It Matters
Understanding the distinction will be important as we talk to others about our developing SMS. When you’re discussing your SMS with managers and people unfamiliar with SMS, it’s important to remember that their minds will likely go to the first definition, the document.
Experienced safety professionals on the other hand, might think of the pillar first, and context will be necessary to determine that you’re both on the same page. I imagine with experience, the context becomes easier to pick up on.
Have you had any vocabulary confusion while learning about SMS? I’d love to hear about it so that we can explore them together!
If you'd like some more help with your safety policy document, check out these free templates to get you started or review your current SMS safety policy.