First Thing to Prepare for Aviation SMS Audits
Audits can be extremely stressful. Especially if things haven't been going well in your aviation safety management system (SMS) in terms of performance or implementation progress.
At this point, there's only one thing that you need to do before anything else:
No audit is going to be perfect. There are going to be findings. Obviously, the fewer, the better. The point is not to avoid findings altogether but to see continuous improvement:
- In the severity of findings;
- By not having recurring findings; and
- In the number of findings.
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- How to Conduct Internal SMS Audits in Aviation Industry
Here are 5 ways you should be preparing for aviation SMS audits.
1 – Clean Up Your Aviation Safety Database
Sometimes quite a bit of time can pass between aviation SMS audits. Things can fall through the cracks. Perhaps a couple of reported safety issues that were never closed or managed to completion. Perhaps the aviation safety database has acquired duplicate entries, unclear entries, and other “questionable” entries.
A necessary practice to prepare for aviation SMS audits is to review your aviation safety database and clean things up, such as:
- Verify no overdue items;
- Ensure that all items are clearly documented;
- Understand the status of currently open items;
- Confirm that all entries are unique; and
- That entries contain all critical information that an auditor would need to see if they investigated reported safety issues.
This process shouldn’t take much time, especially if your organization has been diligent in following through accurately and/or regularly reviewing the database for issues. In tandem with this, the hazard register should also be updated and reviewed in the same manner.
2 – Review and Update SMS Policies and Procedures
Documentation is, as you probably well know, a big deal in audits. Policies and procedures need to be:
- Diverse; and
- It’s best if you can show that they are regularly reviewed/updated.
Aviation SMS is a bureaucratic process of risk management, and documentation needs to reflect that. Policies and procedures should:
- Define and justify the SMS;
- Explain expectations, structure, etc.;
- Written in easy-to-understand language;
- Prescribe methods of preferred action and communication; and
- Most importantly, reflect real life practices.
One of the most common findings in safety audits is that SMS documentation and actual risk management practices do not line up. This is because documentation often “overestimates” the quality/care that being taken in work.
Ensure that documentation matches real life practices, or an auditor will likely catch it. They may not catch it the first time SMS auditors visit, but this is undoubtedly the most common audit finding. If real life practices are undesirable, that documentation should still reflect the undesirable state – BUT also include a plan of action (or goal) for improving it.
Related Aviation SMS Audit Articles
- Aviation Safety Audits 101: Prep and Pass - with Examples and Checklists
- How to Think like an Aviation SMS Auditor
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3 – Recurrent Employee Training Based on Duties and Responsibilities
It’s also extremely important that duties and responsibilities are well documented, and that employees are trained on the prescribed duties and responsibilities. What does this look like?
- Employees duties in the field match what they are in documentation; and
- Employees actively understand what is expected of them, and can refer to documentation.
Ideally, initial SMS training would induct employees into their roles. These roles should be consistent with what is required by the civil aviation authority. Reviewing current duties and responsibilities and ensuring that they are up to date with compliance.
Moreover, before audits it would be good to do a follow up recurrent training or other safety promotion effort with employees about duties and responsibilities in the company. This could be:
- A company duties/responsibilities quiz;
- A newsletter outlining duties/responsibilities;
- A mandatory review of documentation; or
- More formal training, such as automated recurrent training.
Of course, sometimes the standards and SMS guidance from civil aviation authorities is abysmal or nonexistent. In these cases, you might look at:
- ICAO's SMS Guidance;
- Transport Canada's SMS Guidance;
- Australia's Civil Aviation Authority Guidance; and
- FAA's SMS Guidance.
4 – Perform Gap Analysis
A gap analysis is a highly effective tool to review before audits. If you are not sure what a gap analysis is, the gap analysis is essentially an internal audit of your aviation SMS based on industry-accepted checklist models. It basically involved two things:
- Establishing where the SMS implementation needs to be by the time of the audit;
- Performing a gap analysis to see the current state of the SMS; and
- Based on the results, create a plan to close the gaps.
This is such an effective way of preparing for audits because it:
- Helps know where you need to prepare;
- Avoid wasting time investigating healthy areas of the SMS; and
- Understand why the SMS isn’t audit ready.
A gap analysis can save a lot of time, hone efficiency, and make the aviation SMS much better prepared for an SMS audit.
Related Aviation SMS Audit Articles
- 4 Things Safety Managers Do to Perform Well on Aviation SMS Audits
- SRM-SA Aviation SMS Audit Preparation - 4 Free Checklist Templates
- 3 Traits Good Aviation Safety Auditors Share
5 – Review Past Audits and Take Action
This is a piece of advice that should get more attention to avoid audit findings. When preparing for an upcoming audit, your organization should have documentation from the last audit on hand. Ensure that all past findings have been adequately addressed and fixed (if possible).
In fact, looking at past audits can often be the best place to start preparation.
If you don’t take care to do this and you receive a recurrent finding, this will not reflect well on safety team's performance, especially to:
- Civil aviation authorities;
- Upper management; and
- Company investors.
Final Thoughts on Aviation SMS Audit Findings
Newly minted aviation safety managers may believe that audit findings are bad. This is not the case, unless the same audit findings keep surfacing in subsequent audits. An SMS audit is an opportunity to improve SMS performance - and I'm not referring to "audit performance," but sincere SMS effectiveness.
Management needs tools to provide operational oversight to assure that desirable SMS activities and processes exist in your SMS. The SMS audit is the most effective tool oversight agencies have at their disposal, whether the agency is:
- civil aviation authority;
- standards body (IATA, Flight Safety Foundation, IS-BAO, etc.);
- customers and prospective clients; and
- internal quality assurance teams at your company.
Audits are time consuming, especially when you are not prepared. Operators with "paper SMS" and "spreadsheet SMS" implementations suffer the most anxiety both before and during the audit. A robust, centrally managed aviation SMS database keeps all relevant SMS documentation in one location, making auditors happy.
If your SMS auditing experiences are painful to recount, consider getting an SMS database to manage the SMS documentation requirements. An SMS database has tools required to effectively manage all aspects of the aviation SMS.
Since 2007, SMS Pro has been providing SMS databases to help operators achieve regulatory compliance and increase efficiencies in managing SMS documentation requirements. Auditing time is greatly reduced when you have an SMS database and management has higher levels of assurance regarding the avoidance recurrent audit findings.
Below are some short demo videos explaining how you can benefit from using an SMS database. SMS auditing tools and gap analysis tools are also included.
Here are some indispensable checklists for preparing for aviation SMS audits.
Published February 2017. Last updated May 2019.