Why Review Safety Policy & Objectives in Aviation SMS Programs?
Aviation safety managers are hard driven professionals. They are results driven.
In most aviation SMS programs, the bulk of the daily work revolves around the second and third ICAO pillars:
Let's face it, the other two pillars are not that sexy. Most aviation SMS programs focus on the first ICAO pillar heavily during their initial SMS implementation.
The bulk of SMS audit findings come from the first SMS pillar, "Safety Policy & Objectives."
In this article, we'll discuss the elements of the first ICAO component.
What Are the Five Elements of Safety Policy & Objectives?
Safety policy and objectives defines roles, responsibilities, and relationships outlined in your airline or airport's policies and procedures. To accomplish the goal of regulatory compliance, it is important your SMS program explicitly documents:
- Procedures; and
- Organizational structures of key safety personnel.
As you can imagine, these requirements are managed in the first ICAO component. The five elements of Safety Policy and Objectives are:
- Management Commitment and Responsibility;
- Safety Accountabilities;
- Appointment of Key Safety Personnel;
- Coordination of Emergency Response Planning; and
- SMS Documentation.
Management Commitment and Responsibility
Management commitment and responsibility is typically satisfied by:
- A safety policy; and often
- A CEO Commitment to Safety statement.
Most aviation safety professionals agree that an adequate safety policy must:
- Demonstrate top management's commitment to safety;
- Promise human and financial resource commitments toward SMS implementation;
- Announce SMS participation is a requirement by all employees;
- Encourage hazard reporting by introduction of non-retaliatory policies (in most cases);
- Outline when non-punitive reporting is not applicable; and
- Be reviewed on a regular basis.
Here are a few aviation safety policy templates if you need one.
Most airlines and airports identify the accountable executive that has ultimate responsibility and accountability for the SMS program. In some countries, the accountable executive can risk financial penalties or jail time when an SMS program is neglected.
For managing the safety accountabilities element, we recommend a section in your SMS program titled: "Duties & Requirements of Key Safety Personnel." This section identifies and documents the safety accountabilities AND safety expectations of:
- All senior management positions;
- All staff management positions;
- All employees; and
- All stakeholders (customers and contractors).
It is not enough to document the safety responsibilities and accountabilities of all personnel. This documentation will need to be communicated to all stakeholders.
Here is a pro tip: When documenting your duties and responsibilities, include a paragraph or a few lines for managers with authority to determine tolerable levels of risk at your airline or airport. This information can also be tied in nicely with your organizational chart. If you need help with creating an org chart, here is a good resource.
Appointment of Key Safety Personnel
This is perhaps the easiest element to manage. As one can imagine, aviation safety management systems need an "aviation safety manager" to run things.
Every successful SMS implementation requires a qualified person to take charge of the safety program. See this link for a list of desired qualities and a sample job description.
Safety managers report directly to the accountable executive. If they don't have a background in aviation safety management, they will need to receive the required training. Here is a link to aviation SMS training providers.
More complex organizations will require a "safety committee." Many times, we see a safety committees comprising of the
- Chief pilot;
- Director of maintenance;
- Accountable executive; and
- Safety manager.
Not all organizations have safety committees, so don't feel pressured into setting one up if your organization is very small. In these cases, the safety manager and accountable executive are in close communication and act as the de-facto "safety committee."
In the case of your airline or airport having a safety committee, it is recommended that the "Accountable Executive" acts as the chairman. Going one step further, it is a best practice that accountable executives chair all safety meetings. This demonstrates top management commitment and sends a very strong message and example to the other managers.
Coordination of Emergency Response Planning
As a part of Safety Policy and Objectives, airlines and airports need to ensure that an emergency response plan (ERP) has been:
- Regularly reviewed;
- Practiced (including documentation); and
- Made accessible by all key ERP personnel.
Depending on the scenario, your ERP must document roles and responsibilities of contractors and in-house personnel during an event. One potential finding is that your ERP scenarios are either:
- Not reviewed regularly (and documented); or
- Not tested with key personnel (and documented).
SMS documentation describes:
- Safety policy and objectives;
- SMS requirements;
- SMS processes and procedures;
- Accountabilities, responsibilities and authorities for processes and procedures; and
- SMS outputs.
SMS documentation does not yet have a "universally accepted best practice," however, the trend is to put all of the SMS documentation into an SMS manual.
In the past, there have been two or three approaches to SMS documentation:
- Create an independent SMS manual;
- Incorporate SMS documentation into existing organizational documentation; or
- House SMS documentation in logical structures with aviation safety management software.
I prefer the third approach as all employees can easily access required documents. Furthermore, one is more apt to read documentation when it is focused on immediate need.
SMS manuals have several disadvantages and are often suspect, especially when smaller operators purchase SMS manuals believing "one size fits all." We often hear of auditors review SMS manuals and seeing that another company's name is repeated several times within.
Well written SMS manuals serve a purpose, but we recommend that your airline or airport creates your own SMS manual, as you know your operation the best. Alternatively, find a reputable aviation SMS consulting company to help you write your SMS manual.
The most common audit finding that we hear about is that the "operator is not following the procedures outlined in their own SMS manual."
Final Thoughts on Safety Policy & Objectives
The SMS manual is perhaps the first item safety managers tackle when beginning their SMS implementation.
The SMS manual is your SMS blueprint and is a breathing, living document. Don't be afraid to change it. I seldom see or hear of safety managers reviewing their SMS manuals after their initial SMS implementation.
Yes, I see that many safety managers quickly thumb through it and mark a "Date Reviewed" on the document, but I wonder how seriously they review it?
Do you review your SMS manual or SMS documentation?
Having tools to guide your SMS implementation save companies time and money. An undeniable bonus for such tools would be to have a Web-based accident-incident-hazard reporting system to jump start your SMS program.
If you are interested in ICAO SMS implementation according to the four phases, you may be interested in how SMS software can be utilized during this process.