Paperwork Is More Than Tedious

Let’s be real – documentation is really just a fancy word for paperwork (digital or hard copy). It can be extremely tedious.

I’ve never met anyone who looks forward to the documentation required in an aviation safety management system (SMS). That doesn’t change the fact that at every activity of an aviation SMS –

• planning,
• implementation,
• audit reports,
• SMS training records
• reported safety issues, and
• continuous improvement –

documentation does greatly impact the efficiency of the SMS.

SMS documentation is the script of an SMS.

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What Is Documentation in an Aviation SMS Program?

We can widely regard SMS documentation as:

• Policies
• Risk Management Procedures
• Goals/Objectives
• Job Duties and Responsibilities
• Implementation Plan
• Hazard Identification Processes
• Emergency Response Planning
• Safety Communications
• Managing Reported Safety Issues
• Documenting Internal and External Audit Finding
• SMS Training Plans and Attendance Records

It covers a lot of areas, and that means a ton of paperwork. But when aviation safety managers do their due diligence and make a serious effort to create thorough documentation, they – and their organization – will thank them for it. SMS implementations have to be:

• planned;
• implemented; and
• reviewed.

The SMS implementation documentation is perhaps the first exposure to the mountains of SMS documentation required to demonstrate an SMS that is properly implemented and performing across the organization. When the accountable executive monitors SMS performance, there should also be records to account for this activity. SMS documentation never stops. Safety managers had better prepare themselves early on in the SMS implementation that they will need a way to manage all these data requirements.

Beyond demonstration of a compliant aviation SMS, valuable documentation has far-ranging implications, from

• proactivity to damage control, and
• preparation for regulatory reviews.

Below are five areas where effective SMS documentation will save a safety manager a heartache and/or a headache.

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1 – When Accidents Happen

Accidents will always happen. Sometimes they will happen very publicly. Public attention from accidents can bring a storm of negative attention to an organization. The wrath of the public generally boils down to one consideration.

Fault. Heads will always roll.

Public backlash can be severe if it deems that the accident was preventable – i.e., the organization's fault – vs. a mistake that the organization could not have prevented – i.e., silly human error.

Enter documentation.

When accidents do happen, documentation will be one of the primary barriers between the organization and everyone else: the public, FAA, etc. The ability to show hard evidence that the organization instituted policies/procedures/training that was related to the cause(s) of the accident can make all the difference between wrath and sympathy, between an organization scrambling to divert the finger pointed at them and being able to calmly point out that the accident was totally beyond their control.

And that level of documentation falls on the safety manager’s shoulders.

2 – With New Safety Managers

I spoke about this in another post – but imagine the following scenario:

A safety manager is 3 years into implementing a new SMS, and for whatever reason, he/she has to leave the organization. A new safety manager steps in. With quality documentation, the new safety manager can quickly get up to speed on:

• How far along the implementation is towards its goals and objectives
• What has/hasn’t been effective/accomplished
• What are top organizational hazards
• Historical effectiveness of risk controls
• Level of delivered SMS training
• The efficiency of the flow of safety information
• Duties and responsibility breakdown – in actual practice – in the organization

If the documentation has been sparse or cursory, a new safety manager will have an extremely difficult time continuing where the preceding safety manager left the aviation SMS. It can be a significant blow to the SMS implementation. In extreme cases, such as sparse and disorganized documentation, the new safety manager is left merely trying to pick up the pieces.

Poor documentation is on par with a poor track record for a safety manager. What nice things will an organization have to say about a safety officer who leaves the SMS in disarray when he/she leaves?

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3 – During Employee Turnover

Similar to the above point, but when it comes to employee turnover, good documentation tends to be very proactive. Starting a new job is stressful. The environment, processes, and relationships are unfamiliar. I would be willing to bet that new employees pose a much greater risk than seasoned employees.

Getting new employees up to speed and familiar with the aviation SMS plays an important role in mitigating that risk.

Once again, enter documentation. Being able to show new employees very clearly-

• What their safety responsibilities are
• Whom they report to for issues
• What happens to safety information when they report it
• What management’s safety concerns are
• How to identify hazards
• What are risk controls in their work space
• How to use risk controls
• General aviation safety policy and detailed procedures

-gives them a steady leg to stand on from the beginning of their tenure. This is especially true if the documentation has been regularly maintained to reflect real life practices.

4 – When Preparing for Audits

Safety audits can be a stressful time for an organization, and especially a safety manager. They don’t have to be a serious headache.

Detailed and organized documentation for the flow and management of reported safety issues, as well as the organization and implementation methods for the aviation SMS, is often the difference between successful and poor audit preparation.

In difficult SMS implementation where environments have a poor safety reporting culture, quality documentation becomes demonstrative of the energy and methods that a safety manager is employing in an SMS.

It also makes the auditor's job way easier too when he/she is reviewing your organization’s risk management practices. Organizations with good SMS implementation documentation and well-documented risk management processes will consistently perform better in audits and receive more specific feedback on how they can improve.

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5 – During Implementation

This is the most obvious one on this list. Efficient aviation SMS implementation hinges heavily on preparation. Without-

• Well planned policies
• Thoughtful procedures
• Imaginative accountability
• Prepared and accepting management personnel

-an SMS is prone to hit setbacks and fall behind. Consistently hitting SMS goals depends on detailing realistic objectives in a proper time frame, and finding inventive, but practical methods of reaching those goals.

I tend to find that SMS implementation activities are where documentation really shines and sets itself up as a crucial aspect of building and demonstrating evidence of performing aviation SMS.

Documentation Creates a Process to Rely On

One reason I’m a major fan of documentation is that it’s very controlled. Human factors – including your own and those of management – are much more of a wild card, i.e., less controlled and more unpredictable. Life happens, things come up, people get distracted and make mistakes. If you rely on people too much, accidents will happen. Well-defined and enforceable processes are required.

Documentation is finite. History demonstrates successful SMS relies on the system – the procedures and processes – rather than the people. The procedure is a framework you can rely on, and count on the fact that if you invest time and energy into doing it well, you will save time, energy, frustration, and will come out well-prepared.

Safety Policy Is Core Element of Every SMS Implementation

Aviation SMS is implemented in a top-down approach, meaning that the SMS begins with the accountable executive. Safety managers don't own the SMS. The accountable executive is responsible for ensuring the SMS is performing in all parts of the organization and that a "proper" SMS implementation endures.

There are multiple techniques that accountable executives employ to demonstrate that they "own" and are committed to the SMS. The accountable executive is expected to do more than sign the checks to pay for the "safety program" that nobody seems to care about, except for the safety champion and accountable manager (they are often not the same person). Accountable executives demonstrate commitment by:

• Endorsing the safety policy (often written by the safety manager);
• Attending safety meetings;
• Meeting regularly with safety managers (and it's no secret);
• Publishing messages in safety newsletters;
• Walking around the area of operations with the safety manager by his side (obviously visible support); and
• Awarding employees for exemplary contributions to the SMS.

Yet it all starts with the safety policy. When you create a safety policy, it must be written with an understanding of:

• who is the audience?
• what language (level of prose) do they understand?
• what will they find genuine?

We see many safety policies. We have to, as it is our job. A best practice for your safety policy is to keep it accessible to all employees and not stored on a network drive where only the safety manager knows where to find it. Putting your safety policy online using your SMS database is a best practice.

Unfortunately, most of the safety policies I've seen are written for a college-level audience. Yes, they may be beautifully drafted and say all the right things, but they lack authenticity.

Just because you found a great template does not mean it is suitable for your audience (your employees). Try "dumbing it down" so all employees can understand the safety policy. This is a great first step in building your safety culture.

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Safety Policy Hindering Safety Cultures

Too often (60-75% of the time), I see safety policies written for SMS regulatory authorities. This practice "checks the box," but adds no real value to the SMS. It becomes just another useless document that nobody even bothers reading.

As industry professionals, safety managers need to do a better job preparing safety policies for accountable executives. Why do I call out the safety managers as the culprits? Because in most cases, the accountable executive has neither the time nor inclination to draft a safety policy. Sadly, this demonstrates their lack of understanding and commitment to the SMS. Therefore, it is up to the safety managers to tackle this problem of writing safety policies that are directed to the proper audience.

Safety managers, here is a suggestion. I know this will have the accountable executive's signature on it. I also know that you need to present to your account executive a high-quality, professional document. But please, please make the safety policy readable for the employees. If you feel a bit "guilty" about using unsophisticated prose that should be coming from the accountable executive, give the reasoning to the accountable executive when you provide the document to him/her to sign.

The real truth here is that most SMS safety policies need to be rewritten. If you have a good example of a safety policy, you'd like to share that is better than these canned templates below, please share it for others to see how it is done.

As I said, in most cases, the safety manager writes the safety policy for the accountable executive. A sophisticated, high-powered safety policy makes the safety manager appear more competent to other managers and to the accountable executive. This is an example of when documentation saves the safety manager at the expense of safety culture.

When was the last time you reviewed your aviation safety policy? Here is a good resource.

Last updated May 2024.