Seeking Out Mistakes in Aviation SMS Implementations

Being honest about mistakes is hard.

It’s even harder to try and seek out mistakes you are making that you do not know you are making.

In aviation safety management systems (SMS), safety managers are tasked with actively exploring, understanding, and seeking out failures in the program to improve them. Even unknown failures are holes in the safety structure of the SMS.

In many significant ways, the success of aviation SMS implementations depends on how honestly and thoroughly such failures are addressed.

The tricky thing about mistakes and failures in SMS implementations is that:

• More obvious failures are usually merely symptoms of a more deeply rooted problem;
• Searching out unseen mistakes takes valuable time and energy; and
• Frankly, the pressure to maintain safety compliance and the appearance of safety doesn’t give safety managers many incentives to seek out their mistakes.

Related Aviation SMS Implementation Articles

• Why Should We Implement Aviation SMS?
• Overview of 4 Phases of Aviation SMS Implementation With Free Resources
• SMS First Steps - How to Create an SMS Implementation Plan

Here are some of the most common and subtle mistakes aviation SMS implementations often make in their daily activities.

1 – Overestimate Implementation Phase

Overestimation is a chronic human condition. If I could vote to add a 13^th human factor, I would add overestimation. In the same way, aviation SMS implementation teams often give themselves the benefit of the doubt in terms of their development.

This is a tricky area because when organizations aren’t completely realistic about the SMS implementation maturity, they set aviation safety goals and objectives that exceed their SMS data management capabilities – much like an amateur sports player who is called up to a higher league before he/she is ready.

A good place to start in terms of setting up your implementation for honesty is to:

• Conduct a complete gap analysis at the onset of the SMS implementation;
• Conduct follow-up gap analysis regularly, such as annually until reaching phase 4;
• Create and regularly monitor and modify an implementation plan; and
• Follow up after phase 4 every two years with a gap analysis to ensure the SMS implementation is not back-sliding.

A gap analysis should be taken seriously, and though they are both time-consuming and not exactly “fun,” they are sort of like “doing taxes” for your SMS implementation: an important necessity. Fortunately, there are many resources online for conducting aviation SMS gap analysis, such as a gap analysis checklist or implementation phase test.

If you are uncertain which SMS implementation phase you are in, below are four assessments. If you believe you are in phase 3 or phase 4, choose an assessment that is one level below what you believe it to be.

• SMS Implementation Assessment - Phase 1
• SMS Implementation Assessment - Phase 2
• SMS Implementation Assessment - Phase 3
• SMS Implementation Assessment - Phase 4

2 – Lack of Prescriptive/Performing Balance

It’s no secret that many SMS implementations remain comfortably “prescriptive” to regulatory oversight compliance. But modern SMS philosophy and successful SMS implementations continue to show the benefits of a "performing SMS".

Prescriptive programs blindingly focus their safety efforts on regulatory compliance, whereas performing SMS focuses their risk management processes on organizational safety goals and objectives. Both performing and prescriptive aviation SMS implementations have advantages and disadvantages. Prescriptive programs:

• Allow the maintenance of industry-recognized and approved standards; but
• Are slow to respond to change (i.e., not very adaptable), and prescriptive standards are often out of date with evolving technologies.

On the other hand, performing programs:

• Allow for innovation that, in many instances, promotes a deeper understanding of organization-specific needs; but
• Raise many issues regarding uncertainty, the role of experts in decision-making, and the unknown performance of performance-based standards.

I continue to maintain that purely prescriptive SMS implementations remain extremely vulnerable in the long run because their inability to stay at the forefront of technology and change promotes unpreparedness. What is needed is a balance between the two.

The real strength is recognizing the limitations and strengths of the prescriptive and performing areas of your SMS and figuring out how to find harmony between the two. Providers and regulators must work together to understand where, when, and how each can be best used in an SMS implementation.

3 – Approach to Justifying Acceptable Level of Safety

In general, there are three ways to approach justifying an SMS' acceptable level of safety:

1. Standards and Guidelines: shows that the SMS follows prescriptive standards, meets with safety requirements, and is compliant;
2. Goal-Based: shows that SMS safety data and evidence were collected to create, support, and meet safety goal standards; and
3. Vulnerability: shows that the SMS has thoroughly assessed front-line (bottom-up) weaknesses in the organization's systems that lead to issues.

As you might expect, in general, aviation SMS justify their "acceptable level of safety" (ALoS) by showing adherence to standards and guidelines. This fulfills proving safety only on the end of the system, but it does not prove safety for the actual safety case. True ALoS for the real safety case requires the use of all three ways for safety justification.

For one, using all three approaches gives an organization diverse evidence for justifying their safety claims. Moreover, using all three approaches gives an organization more depth for justifying safety.

Related Aviation SMS Implementation Articles

• How to Create Aviation SMS Implementation Plan - With Templates
• 4 Best Aviation SMS Gap Analysis Strategies for SMS Implementations
• Is Your Aviation SMS Implementation Performing or Prescriptive?

Final Thought: The Real Failure and Sustainability

What all the above mistakes address are the following facts:

1. System safety does not prove actual operational safety assurance; and
2. Most unknown mistakes are made at the level of actual safety;
3. Mistakes in addressing actual safety are failures in aviation SMS resilience.

The consequence of all the above points is a lack of resiliency of the SMS. In other words, SMS implementations with one-sided prescriptive/performing standards, unrealistic SMS implementation scrutiny, without diverse evidence for ALoS are not sustainable. What makes SMS tricky is the fact that mistakes may look good in the short term, and good choices may be hard in the short term.

Resiliency and sustainability in aviation SMS require a thoughtful SMS philosophy in action.

Do you know which phase you are in? Take a quick assessment and learn where you are really at.

• SMS Implementation Assessment - Phase 1
• SMS Implementation Assessment - Phase 2
• SMS Implementation Assessment - Phase 3
• SMS Implementation Assessment - Phase 4

SMS Implementation Resources

Last updated in June 2024.