Common Question before Aviation SMS Implementations

I interact with safety managers and accountable executives as we provide consulting and database services for aviation service providers implementing formal aviation safety management systems (SMS).

Occasionally, I hear these groups saying, "We only want the pilots to participate in the SMS."

Worse yet, I'll see an airline with 4,000 employees telling me that only "20-40 people in the company are active in the aviation SMS," meaning that they have a small safety team that is peddling "safety" and the other employees are not active or are completely unaware of the SMS implementation.

I get it. Many safety professionals and accountable executives are neither properly trained on the:

• True intent or scope of an SMS implementation; nor
• Benefits of a properly implemented aviation SMS.

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This week, I received a request from a manager who is not working in typical aviation operations, such as:

• Flight ops;
• Ground ops; or
• Maintenance.

This question came from supply-side operations as:

In your opinion, how would an office type of environment, with no input to aviation safety, apply SMS and what might be their measurements?

Aviation SMS Implementations Affect the Entire Company

To answer the question, I propose: an SMS implementation is a company-wide endeavor, and not merely for operational staff. Office personnel may be visiting operational areas and identifying hazards. They are then obligated to report hazards."

ICAO Document 9859 clearly states that:

While the job descriptions of all employees, regardless of level, should include safety accountabilities and responsibilities, the safety accountabilities regarding the definition of safety responsibilities and authorities of key personnel refer to the inclusion in the job description of each senior manager (departmental head or person responsible for a functional unit), of the responsibilities regarding the operation of the SMS, to the appropriate extent, in addition to the specific responsibilities for the operation of the department/functional unit.

Since we are on the section of safety accountabilities, it makes sense to also extend this discussion to those who already "get it." Let's dive a bit deeper so you can either learn the requirements or have a quick review.

Under the perspective of the management of safety as a core business function, every departmental head or person responsible for a functional unit will have a degree of involvement in the operation of the SMS and its safety performance. This involvement will certainly be deeper for those responsible for operational departments (emphasis added) or functional units directly involved in the delivery of the basic services of the organization (operations, maintenance, engineering, training, and dispatch, hereafter referred to by the generic term "line managers") than for those responsible for supporting functions (human resources, administration, legal and financial).

The safety accountabilities, responsibilities, and authorities of all departmental heads and/or persons responsible for functional units, and in particular line managers, must be described in the organization’s safety management systems manual (SMSM) (emphasis added)... Safety accountabilities, responsibilities, and authorities must be graphically depicted in a functional chart showing the interfaces and interrelationships in terms of the management of safety among the various sectors of the organization." This is referring to the organizational chart.

In the case above, I'm referencing the first version of Document 9859. Here is a direct link to version 4 of ICAO's Safety Management Manual. Please forgive me, but I continue to go back to the version I know intimately.

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Degree of Participation in Aviation SMS Implementations

As we saw above, all employees intended to participate in aviation SMS implementations. However, one logically understands that employees providing services in operations, maintenance, engineering, training, and dispatch expect to play a larger role.

So what can we expect for supporting operations, such as logistics and administration? What role should employees in these departments play and how do you train these employees? Do they take aviation SMS courses like the other employees?

Hazard Identification Important for All Employees

Office employees may be trained on hazard identification so they both know:

• What to look for; and
• How to report an identified hazard.

Office personnel can also participate in the SMS program by contributing to newsletters or safety promotion activities. I believe office staff should have a fundamental understanding of what are safety management systems in aviation. A quick three-to-five-minute video or two is enough to cover the details.

Measure Progress in Aviation SMS Implementation for Office Employees?

To perform measurements, you may be considering how many office-related accidents occurred at your company over the past year. Five years? What type of accidents are these? These will be your KPIs to keep an eye on for this group when these align with company goals and objectives. If you are like our office, we haven't had an accident in over 13 years. How do you trend that?

I get it. This can become nonsensical, but office workers have many unreported injuries related to stress and poor ergonomics. If your office workers are getting carpal tunnel or shoulder pain, these should be addressed.

These safety-related issues can be managed using the same risk-management processes and SMS software products and tools that operations use. We see this commonly in Canadian operators. As you may know, the Canadians and Australians are furthest along in their SMS initiative.

With the Canadians, we see an Admin division to capture general safety and HR issues. Their corporate business strategy is to reduce systems and if your SMS implementation can handle other types of issues, it makes sense to capitalize on the benefits and risk management workflows practiced by the SMS.

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Other Benefits from Aviation SMS

For an office type of environment, without exposure to large amounts of operational risk, I personally would focus mainly on quality or environmental aspects, such as

• Customer service;
• Amount of paper consumed;
• Electricity consumed, etc.

While the purpose of aviation SMS is for safety, it makes little sense to not use the implemented risk management processes as an opportunity to improve other areas of the business, including:

• Security;
• Quality;
• Compliance; and
• Environmental.

Final Thoughts on Office Employees' SMS Participation

Hazard identification and accident reporting are the major roles that an aviation service provider's office workers play in aviation SMS. However, you should be considering the benefits of an integrated safety and quality management system. This is where the true business benefits of aviation SMS occur and turn the required SMS into a profit driver.

Training all employees, including office workers, should not be a time-consuming task. It is easy to automate SMS training using modern technology.

Even the most basic SMS Pro solution automates SMS training for all employees using the integrated SMS training system. This really saves time and money for operators satisfying the required SMS training element. Furthermore, an automated solution is a sustainable solution and scalable solution that can be used by operators of varying sizes and complexity.

Training office workers on the required SMS training components should be very easy and cost-effective when you implement the correct technology. If there is pushback from the accountable executive or other department heads, the safety team should suggest either:

• SMS Executive Training; or
• Read the SMS requirements.

For every implemented aviation SMS, the accountable executive is responsible for ensuring the aviation SMS is properly implemented and performing in all areas of the organization. Now, if your company operates in different industries and you are required to have an SMS, such as a corporate flight department, then your company is not expected to implement an SMS in areas that are not related to flight operations. However, if you are an aviation service provider or aviation equipment manufacturer, then you will need to get your office personnel trained and performing in the aviation SMS.

Documentation is key, especially as the years pass. Automating training is the most cost-effective approach if you wish to remain in compliance. You may get by using spreadsheets in the first few years of the SMS implementation, but as time passes, you will be better served with a low-cost, commercially available SMS database.

SMS Documentation Managed Using SMS Database

The SMS documentation requirements are the most difficult element to manage in modern SMS. If it isn't documented, it didn't happen. Most SMS audit findings are directly related to

• outdated documentation;
• nonexistent documentation; or
• improperly followed documented risk management processes.

Low-cost, commercially available aviation SMS databases reduce risk and improve your ability to participate in future predictive risk management processes. According to the FAA, the objective of the SMS is to proactively manage safety. Safety is very difficult to manage and verify using spreadsheets. I recommend an SMS database to reduce the SMS' true cost of ownership.

If you are starting your SMS implementation, it makes sense to adopt an SMS database early in the SMS implementation process. The sooner the better, because as time passes, you are missing out on opportunities to collect essential data that will improve processes in the future. We've seen many Canadian and Australian companies make this mistake. They may manage their SMS for six to eight years before realizing that they need an SMS database. Six to eight years' worth of data is significant. Don't make this mistake if you can help it.

Below are some short demo videos explaining how an integrated SMS database can benefit your company's SMS implementation.

Last updated September 2023.