In commercial aviation, a robust Safety Management System (SMS) is critical for mitigating risks and ensuring compliance with regulatory standards, such as those set by the International Civil Aviation Organization (ICAO) and national civil aviation authorities like the FAA or EASA.
SMS audits, conducted internally or by regulators, evaluate the effectiveness of an organization’s SMS, identifying strengths and areas for improvement. For aviation safety managers and accountable executives—senior leaders responsible for SMS oversight—addressing audit findings promptly and effectively is essential to maintain compliance, enhance safety performance, and demonstrate leadership.
New safety managers often find the process of handling audit findings daunting, as it involves analyzing gaps, developing corrective actions, and engaging stakeholders.
This article provides a step-by-step guide on how to address aviation SMS audit findings, complete with practical examples and actionable tips. Whether preparing for an FAA Part 5 audit or an EASA inspection, this resource will empower you to turn findings into opportunities for continuous improvement.
An SMS is a structured framework for identifying hazards, assessing risks, and implementing controls to prevent incidents in aviation operations. The four SMS pillars—safety policy, safety risk management, safety assurance, and safety promotion—rely on continuous monitoring and improvement, which audits facilitate. Audit findings highlight gaps, such as inadequate hazard reporting or incomplete training records, that could compromise safety or compliance.
For accountable executives, addressing findings demonstrates commitment to safety and regulatory obligations. For safety managers, it’s an opportunity to strengthen SMS processes and train staff on corrective actions. Mishandling findings can lead to regulatory penalties, safety risks, or reputational damage, making a systematic approach critical.
The first step in addressing SMS audit findings is to thoroughly review and understand the report. Findings typically include non-conformities (violations of regulatory requirements) or observations (areas for improvement not yet non-compliant).
Read the Report Carefully: Identify each finding, its associated SMS pillar, and the evidence provided (e.g., missing documentation or process gaps).
Clarify with Auditors: If a finding is unclear, request clarification from the audit team to ensure accurate interpretation.
Prioritize Findings: Categorize findings by severity (e.g., critical, major, minor) and urgency (e.g., immediate action vs. long-term improvement).
Engage the Accountable Executive: Brief the executive on high-priority findings to secure leadership support and resources.
During an FAA Part 5 audit, an airline receives a finding: “Incomplete hazard reporting training records for 20% of ground crew.” The safety manager reviews the report, confirms the evidence (missing training logs), and classifies it as a major non-conformity due to its impact on safety promotion. They schedule a meeting with the accountable executive to discuss resource needs for corrective action.
Actionable Tip: Create a spreadsheet to log each finding, including its description, SMS pillar, severity, and deadline for resolution. Share it with the safety team and executive for transparency.
To address findings effectively, identify the root causes rather than applying superficial fixes. This aligns with the SMS pillar of safety assurance, which emphasizes systemic improvements.
5 Whys: Ask “why” repeatedly to drill down to the underlying issue.
Fishbone Diagram: Map out contributing factors, such as people, processes, or technology.
Bow-Tie Analysis: Assess the finding’s causes and potential consequences to prioritize controls.
For the airline’s finding on incomplete training records:
5 Whys:
Why are records incomplete? Training logs weren’t updated.
Why weren’t logs updated? The training coordinator was overburdened.
Why was the coordinator overburdened? No backup staff was assigned.
Why no backup staff? Budget constraints limited hiring.
Root Cause: Insufficient resource allocation for training staff.
Outcome: The analysis reveals a need for additional personnel or a digital tracking system.
Actionable Tip: Train safety team members on root cause analysis techniques during a 1-hour workshop. Use a recent finding as a practice case to build skills.
A Corrective Action Plan outlines how each finding will be addressed, including specific actions, timelines, and responsible parties. The CAP must be realistic, measurable, and aligned with SMS goals.
Corrective Actions: Specific steps to address the root cause (e.g., hiring staff, updating procedures).
Resources: Budget, personnel, or technology needed to implement actions.
Timelines: Deadlines for each action, typically 30–90 days for major findings.
Responsible Parties: Assign roles, such as safety manager or training coordinator.
Verification Plan: Methods to confirm the finding is resolved, such as follow-up audits.
Finding: Incomplete hazard reporting training records.
Corrective Action: Implement a digital training management system to track records and hire a part-time training assistant.
Resources: $15,000 for software licensing and $20,000 for a 6-month assistant contract.
Timeline: Software implemented within 60 days; assistant hired within 30 days; all records updated within 90 days.
Responsible Party: Safety manager oversees software implementation; HR handles hiring.
Verification: Internal audit in 100 days to confirm 100% record completion.
Outcome: The accountable executive approves the budget, and the CAP is submitted to the FAA within 10 days.
Actionable Tip: Use a CAP template with columns for finding, action, resources, timeline, and verification. Share it with the accountable executive for approval before submission to regulators.
With the CAP approved, execute the corrective actions promptly. Effective implementation requires coordination, communication, and resource allocation.
Assign Tasks: Clearly communicate responsibilities to team members, ensuring they understand their roles.
Allocate Resources: Secure budgets, staff time, or technology as outlined in the CAP.
Monitor Progress: Track action completion using project management tools or regular check-ins.
Engage Employees: Train staff on new processes (e.g., using a new training system) to ensure adoption.
For the training records finding:
The safety manager selects a cloud-based training management system, implemented by IT within 45 days.
HR hires a part-time training assistant who begins updating records within 20 days.
The safety team trains 50 ground crew members on the new system in two 1-hour sessions.
Weekly progress meetings ensure the project stays on track.
Outcome: All training records are updated within 80 days, ahead of schedule.
Actionable Tip: Schedule biweekly progress updates with the safety team and report milestones to the accountable executive to maintain accountability.
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Regulators require evidence that findings are resolved. Verification confirms corrective actions are effective, and documentation provides a clear audit trail.
Internal Audit: Conduct a focused audit to check the finding’s resolution (e.g., review training records).
Data Analysis: Measure outcomes, such as increased training completion rates.
Employee Feedback: Survey staff to confirm new processes are working (e.g., ease of using a new system).
Updated records (e.g., training logs).
Audit reports confirming resolution.
Screenshots or reports from new systems.
Meeting minutes or CAP progress updates.
For the training records finding:
An internal audit confirms 100% of ground crew training records are updated in the new system.
Data shows a 95% training completion rate, up from 80%.
A survey of 30 employees indicates 90% find the system user-friendly.
The safety manager compiles a report with audit results, system screenshots, and survey data, submitted to the FAA.
Outcome: The FAA closes the finding during a follow-up inspection, praising the organization’s proactive approach.
Actionable Tip: Create a verification checklist for each finding, listing required evidence (e.g., audit report, data metrics). Store documentation in a digital folder for easy access during inspections.
Sharing lessons learned from audit findings reinforces a just culture and supports the SMS pillar of safety promotion. Communication ensures employees understand improvements and feel encouraged to engage in SMS.
Safety Briefings: Discuss findings and resolutions in team meetings, highlighting systemic fixes.
Newsletters: Publish a summary of the finding, CAP, and outcome in a company-wide newsletter.
Training Updates: Incorporate lessons into SMS training, showing how findings drive improvements.
Executive Endorsement: Have the accountable executive share a message reinforcing the importance of audits.
The airline:
Holds a 10-minute briefing for ground crew, explaining how the new training system addressed the audit finding.
Publishes a newsletter article, “How We Fixed Training Records,” featuring the safety manager’s insights.
Updates SMS training to include the finding as a case study, emphasizing just culture.
The accountable executive sends an email: “Our response to this audit finding shows our commitment to safety. Thank you for your support.”
Outcome: Employee trust in SMS rises, with 25% more hazard reports submitted in the next quarter.
Actionable Tip: Create a one-page “Lessons Learned” summary for each major finding, sharing it via email or posters in crew rooms to promote transparency.
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Audit findings are opportunities to strengthen SMS. Integrate lessons into ongoing processes to prevent recurrence and enhance safety performance.
Update Procedures: Revise SMS manuals or policies based on findings (e.g., add a training record checklist).
Enhance Training: Include audit scenarios in future training to build employee awareness.
Monitor Trends: Track recurring findings to identify systemic issues, such as resource shortages.
Report to Leadership: Brief the accountable executive on how findings inform strategic safety goals.
The airline:
Updates its SMS manual to require monthly training record checks.
Adds a 5-minute audit case study to annual SMS training.
Analyzes audit data, identifying a trend of documentation gaps, prompting a $10,000 investment in document management software.
The accountable executive includes audit outcomes in the annual safety report, aligning with strategic objectives.
Outcome: No similar findings occur in the next FAA audit, and documentation compliance improves by 30%.
Actionable Tip: Schedule a quarterly SMS review meeting to discuss audit findings and integration progress, involving the accountable executive to ensure alignment.
New safety managers often face hurdles in addressing audit findings. Here’s how to overcome them:
Complexity: Break findings into manageable steps, using the CAP template to stay organized.
Resource Constraints: Prioritize high-severity findings and propose cost-effective solutions, like software over hiring.
Employee Resistance: Communicate the benefits of corrective actions (e.g., easier record-keeping) to gain buy-in.
Executive Engagement: Provide concise briefings (15 minutes) to keep the accountable executive informed without overwhelming them.
Actionable Tip: Host a 30-minute “Audit 101” training session for staff, explaining the audit process and how findings improve safety, to build support.
Finding: “Inadequate hazard reporting process due to lack of employee training and outdated reporting tools” (EASA audit, medium-sized airport).
Step 1: Review: The safety manager confirms the finding affects safety risk management and safety promotion, prioritizing it as major.
Step 2: Root Cause: Fishbone analysis reveals insufficient training budget and an outdated paper-based reporting system.
Step 3: CAP: Allocate $25,000 for a mobile reporting app and $10,000 for training 150 staff; implement within 60 days; verify via internal audit.
Step 4: Implementation: IT deploys the app in 40 days; the safety team trains staff in three sessions.
Step 5: Verification: An audit confirms 90% staff adoption of the app, with 30 new hazard reports; documentation is submitted to EASA.
Step 6: Communication: A newsletter highlights the new app, and the accountable executive hosts a town hall to thank staff.
Step 7: Integration: The SMS manual is updated to include app training, and quarterly app usage reports are added to safety assurance.
Outcome: EASA closes the finding, and hazard reporting rises by 50%.
Actionable Tip: Use this example as a case study in safety team meetings to illustrate the full process and build confidence.
Addressing SMS audit findings is a critical process for aviation safety managers and accountable executives, ensuring compliance and strengthening safety performance. By
Clear communication and executive leadership amplify these efforts, fostering a just culture and engaging employees.
Start by reviewing your latest audit report and drafting a CAP for one finding, using the steps and examples above. Engage the accountable executive to secure resources and share progress with staff to build trust. With a systematic approach, you’ll not only satisfy regulators but also create a safer, more resilient aviation operation for years to come.
Call to Action: Ready to tackle SMS audit findings? Review your audit report today and develop a corrective action plan. Share this article with your team to align on strategies and boost compliance.