Aviation SMS Implementation Challenges for Small Service Providers

Disadvantaged Part-Time Safety Managers

Incredible challenges assail aviation safety managers at smaller operations who are implementing aviation safety management systems (SMS). In short, their organizational size and make-up present a very real hazard that must be recognized and mitigated.

Recognizing the hazard, as well as awareness of possible remedies will be a first step toward overcoming these SMS implementation challenges. What is the biggest hurdle for these small service providers who are required to implement an aviation SMS? How do other small service providers manage this hazard?

Lack of Long-Term SMS Implementation Focus for Smaller Operators

Smaller operators typically do not possess adequate financial or human resources to employ full-time safety managers. Due to these budgetary and organizational limitations, safety duties are commonly assigned as additional duties to mid-level managers, such as the Chief Pilot or Director of Maintenance. For those of us with military backgrounds, we are very familiar with these "extra duties" that were not part of our documented job descriptions.

In some cases, we see office personnel, such as administrative assistants without operational experience, assigned as the organizational safety manager. What does this scenario look like in practice? What role does the safety manager play in risk mitigation when the safety manager lacks real-world, operational experience?

SMS implementations are significantly less effective and only moderately successful whenever SMS duties are assigned as "extra duties" to very busy managers. Safety management commonly becomes a lower priority because managers are often overworked and can only fit so much work into a given day. Operations that directly contribute to the bottom line take precedence, except of course, when somebody is bleeding. This is a simple fact of life. Safety is never the first priority, no matter how many times we have heard this outworn cliche.

An SMS implementation may take three to five years to fully implement. Safety cultures, which are so very important to a successful SMS, may require ten to fifteen years to change. The point is that an SMS implementation is a long-term project.

Accountable executives at smaller organizations must remain hyper-vigilant. After all, the accountable executive is responsible for ensuring the SMS is properly implemented and performed in all areas of the organization. When you have a part-time safety manager doing SMS "as a hobby," the accountable executive must be prepared to regularly review organizational safety performance to ensure the SMS is performing as designed.

How can the accountable executive be assured that the SMS is performing as designed in scenarios where there is only a part-time safety manager? What happens when the part-time safety manager leaves the company?

This article discusses techniques safety managers at a smaller organization can employ to adequately comply with ICAO SMS requirements and also maintain their sanity.

Implementing Aviation SMS Programs Is Not a Trivial Task

Effectively managing aviation SMS implementations is nearly possible without an adequate budget. The increased budget will be spent on either:

A dedicated safety manager (perhaps part-time); or
Aviation SMS software tools to make the part-time safety manager more effective.

Looking at SMS documentation requirements, managers will see them broken out into four components, or pillars, as they are commonly referred to:

SMS Documentation Requirements Overwhelm Unorganized Managers

Seems simple enough, right? Four pillars don't seem like an overwhelming group of requirements. But when you consider there are twelve elements or parts to these four components, then the task seems considerably formidable to a full-time operations manager playing at being a part-time safety manager.

For a quick review, here are the twelve elements of the four pillars or components of a fully implemented aviation SMS:

Safety Policy

Management commitment and responsibility;
Safety Accountabilities;
Appointment of key safety personnel;
Coordination of emergency response planning; and
SMS documentation.

Safety Risk Management

Hazard identification; and
Risk assessment and mitigation.

Safety Assurance

Safety performance monitoring and measurement;
Management of change; and
Continuous improvement of the SMS.

Safety Promotion

Training and education; and
Safety communication.

If It's Not Documented, It Never Happened

In the safety policy component, we see that several of those required elements are "do it once and then review" types of tasks. These tasks will include:

Safety policy statement;
Support safety policies, such as non-punitive reporting policy;
Duties and responsibilities of key safety personnel;
Emergency response plans; and
Safety goals and objectives.

SMS documentation is an ongoing task. It can quickly become a problem when SMS review activities are not properly documented, as possessing this documentation is imperative for the accountable executive to maintain assurance the SMS is compliant. Furthermore, an audit finding becomes a very real threat when small operators do not have the processes or technology to ensure that required SMS documentation is not reviewed regularly. Remember, that if it isn't documented, it didn't happen.

Documenting Risk Management Activities among Major Challenges

A more troubling consideration for both accountable executives and part-time safety managers should be highlighted as we look at Safety Assurance elements. "Safety performance monitoring and measurement" can take many hours each month, even when the part-time safety manager has adequate SMS software tools. For example, the FAA expects operators to use all of the components of SMS to enhance a carrier’s ability to:

identify safety issues; and
spot trends before they result in a near-miss, incident, or accident.

The second point requires a second glance, as a trend analysis requires years' worth of SMS data to be collected, organized, and analyzed. Staying on top of required SMS documentation requirements can exasperate any operations manager who already has their plate full from their normal, assigned, day-to-day managerial duties.

Small Operators with Non-Performing Safety Cultures

Is it any wonder that small operators possess a weak safety culture? Where does the part-time safety manager find time to document all the SMS risk management activities and also develop and broadcast safety promotion materials? This is undoubtedly the main reason that safety promotion activities take the biggest hit in SMS implementations for smaller operators.

Each aviation service provider must have a genuine commitment from upper management to allocate both personnel and financial resources to the critical functions of the SMS implementation. Safety promotion is just one example that comes up when we talk about the "SMS system." All four pillars are important for the system to work.

I have to stress this again: all four pillars are important for the system to work.

This is no better witnessed than with the lack of safety promotion activities during the early phases of SMS implementation. An accountable executive cannot expect a performant SMS when employees:

Don't know about the aviation SMS;
Don't care about the SMS;
See management not taking SMS seriously (prioritizing safety initiatives);
Lack tools to easily participate in the SMS.

When employees don't participate in the SMS, there are few reported safety issues to treat in the SMS's risk management processes. How can the SMS deliver the promised benefits of "continuous improvement of business processes" when there is a huge lack of "safety inputs" into the system? In this case, management will quickly become disillusioned with the lack of "visible progress" in improving operations. Subsequent risk management activities will simply fade away and the failed SMS becomes a self-fulfilling prophecy.

SMS Implementation Seen as a Profit Driver

Yet I get it. An SMS implementation costs time and money.

Implementing an aviation SMS is a risk and upper management may not be ready to accept this risk. How can we expect the accountable executives of smaller organizations to commit resources when they are uncertain as to:

What actual, measurable benefits will outweigh the cost?
How much money and resources will the SMS implementation require each year?
What will the SMS implementation look like in three years, five years, or ten years?
What happens if I do the bare minimum and implement a paper SMS?

In order for upper-level management to commit these resources, they must be convinced that well-executed SMS implementations can serve as a profit driver AND that auditors will sooner or later call them on their SMS implementations' deficiencies. Whenever there is inconsistent regulatory oversight, we know that account executives will do little more than pay lip service to their SMS.

Reducing Risk to SMS Implementation in Small Organizations

How do accountable executives reduce risk to their SMS implementations?

How should part-time safety managers improve their chances of success, given that their primary duties focus on operations?

At a bare minimum, part-time safety managers require aviation SMS software tools designed to manage ICAO-compliant SMS implementations. Existing data management tools that have to be retrofitted for SMS purposes seldom meet SMS requirements and in the long run, simply cost more time and money to implement. We have repeatedly seen operators attempt this approach, but within three to seven years, they realize the task is too great and resort to professionally designed aviation SMS software tools.

Not every small operator should go out and purchase SMS software. In many cases, they will be throwing away their money. Most importantly, they should evaluate the organization's business goals and objectives and then determine the best data management approach. There is no sense in spending time and money on SMS database software when your business goals don't align with the SMS's goals.

Smaller operators with high turnover should consider acquiring SMS software to manage their SMS documentation requirements. This is a no-brainer. High employee turnover is a real risk to SMS implementations and when the safety manager leaves, there must be allowances for this transition. When the SMS' data management processes are not documented or ill-defined, then the risk increases exponentially.

The best way for smaller operators to reduce risk to their SMS implementations is to capitalize on the work of hundreds of operators before them. Their efforts are captured in the more popular SMS database software's risk management processes. A huge uncertainty for small service providers is: will my risk management processes pass muster with the regulatory authorities?

Subscribing to low-cost, commercially available SMS software is the fastest way to reduce this risk. Commercial aviation SMS software has tried and tested risk management processes. Furthermore, this approach will make the part-time safety manager's SMS documentation tasks more palatable. The best part about commercial SMS software, it is very inexpensive for smaller operators.

SMS Software Tools Serve as Force Multipliers

With the proper tools and training, a part-time safety manager can be more effective and reduce the organizational risk of being non-compliant. Otherwise, the task is too great to perform satisfactorily, and your SMS is no better than a "paper SMS" or a poorly-designed "spreadsheet SMS."

Without the proper tools, part-time safety managers will either:

Become burned out; or
Leave the position; or
Leave the company.

SMS software tools can help such situations by:

Enabling positive and measurable results;
Saving time and energy; and
Delivering more safety-related services to the company.

The last point is especially true for elements in the safety promotion component, namely:

Training and education; and
Safety communication.

Upper-Level Management Must Interface with Aviation SMS

The part-time safety manager must not be left alone to solve the "SMS problem." Too often, I hear of new safety managers being "promoted" to manage the SMS, but they don't have a clue as to what an SMS is. Not wanting to disappoint, the safety manager does the best job they can. They don't want to needlessly burden the accountable executive with the details. After all, safety managers are competent professionals who can "figure things out."

To sincerely demonstrate "top management support," upper-level management must both support and interact with the SMS and the assigned safety manager and not just provide the budget. The entire operation must see management not just giving lip service to the SMS implementation, but also sincerely and continuously being involved with it. Considering the many demands of upper management, this requirement has been a critical challenge for most organizations and not just the smaller operators. Safety culture starts at the top!

Final Thoughts for Safety Managers at Smaller Operations

From experience, we see that committed operators fully embrace SMS implementations for the first several years. The first and second part-time safety managers will be trained fully with the support of upper management. However, upper management enthusiasm seems to fade after the third or fourth "part-time" safety manager passes through their company.

I think this is happening because the third or fourth safety manager is assuming he has top management support and may be shy about asking for more tools and training. The final word is that safety managers at smaller companies have a tough task and we need to find ways to improve their often poor safety cultures.

Good quality SMS software tools are affordably priced for smaller companies. Part-time safety managers can get more done and offer more services with good tools. Yet they will need top management support. In order to get top management support, safety managers must learn to speak "management talk" and show them the real benefits of sincere SMS implementation and not simply a "paper SMS" shell that 70% of the smaller companies have today.

Does this article resonate with you? Are you in a small company with no SMS budget? Are you a part-time safety manager who is trying to organize the SMS? We can help.

Since 2007, SMS Pro has been providing SMS database services to small aviation service providers around the world. Learn how you can benefit from industry-tested risk management workflows. SMS documentation becomes manageable using SMS Pro.

Last updated November 2023.

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