The Brutal Truth About Your Aviation SMS Implementation

If you cannot handle emotional pain or controversy today, please don't read this. I certainly don't mean to offend, but I have to say this:

Most aviation service providers are lying regarding their aviation SMS implementations.

What? We just spent tens of thousands of dollars on aviation safety management system (SMS) implementation consultants and we don't have an SMS implementation?

Accountable executives and safety managers need to sit down and ask some very blunt and possibly painful questions:

• Is our aviation SMS sustainable?
• Are we merely checking the boxes? (pencil whipping)
• If our safety manager leaves, will our SMS survive?
• Do we really have top management support?
• Can we demonstrate the aviation SMS is properly implemented?
• Is the aviation SMS performing in all parts of the company?
• Can you regularly review SMS performance?
• How do we demonstrate continuous improvement of the SMS?

Most aviation SMS implementations fail because of

1. Lack of top management support;
2. Safety champion leaves too soon; or
3. Management decides not to train (see #1).

How do you know you have top management support, for example? Does the accountable executive attend safety meetings? Can the safety manager or director of safety have "face-time" with the accountable executive every week?

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

Truthfully Evaluate Your SMS Implementation

When was the last time you reviewed the aviation SMS implementation plan?

• Last week?
• Last year?
• Never?

Do you even know how? It is rather easy.

SMS implementation checklists serve as a great self-assessment tool.

You may respond by saying you are neither the SMS manager nor the director of safety. So why should you care about evaluating the aviation SMS implementation progress?

• Organizational and systemic safety;
• Pulling management's heads from their backsides; and
• You may be the next SMS champion and not know it.

SMS implementation plans are put out by ICAO, FAA, Transport Canada, EASA, and other civil aviation authorities (CAAs). All CAAs must follow ICAO guidelines at a minimum. Reviewing CAA SMS implementation documentation is never fun because their technical writing staff appears to have nothing better to do than write volumes of documentation that nobody finds exciting.

What you need is a simple checklist to review your SMS implementation progress. SMS implementation checklists are easy to understand and quick to scan. They get to the meat of each required SMS implementation plan activity and allow managers to quickly judge progress.

Additional Articles on Aviation SMS Implementation

• Your Top 4 Risks to Aviation Safety Management System Implementations
• 6 Questions & Downloads for Starting an Aviation SMS Implementation
• 3 Myths about Aviation SMS Implementation

Which SMS Implementation Phase Are You In?

Most Canadian and Australian operators are in either Phase 3 or Phase 4 of their SMS implementations. Most like to believe they are in Phase 4. To discover where your company is, ask your safety manager or director of safety. They will know exactly what you are referring to.

If you think you are in Phase 2, or if you are not sure which phase you are in, take a quick survey that determines whether you have passed each particular milestone:

SMS Implementation Assessments

1. Phase 1 SMS Implementation Assessment
2. Phase 2 SMS Implementation Assessment
3. Phase 3 SMS Implementation Assessment
4. Phase 4 SMS Implementation Assessment

Have you learned the answer yet? Which phase are you in?

Most of you will be surprised that their aviation SMS is either:

• Not sustainable for the long run;
• Has backslid significantly due to safety culture challenges; or
• Was merely a pencil exercise (managers pencil-whipped an SMS together).

If you discover that you have a paper SMS (was merely a pencil exercise), don't be quick to judge too harshly. The paper SMS could have been the best strategic business solution at the time. Depending on your region of the world, SMS oversight may be:

1. lacking altogether;
2. not consistent in SMS auditing practices; or
3. consistent and constantly improving.

No SMS Oversight

The business decision for operators in Region #1 is that "if" the auditors come, we'll put on our best face and make promises to do better. And everybody is happy. You may even get by for many years with this tactic, even in regions of the world where SMS oversight is in the third region, "consistent and constantly improving." Operators in Region #1 may have an SMS manual and a safety reporting system that sits "idle." No SMS activity and there really is no business need to spend time and money on a "program" without SMS oversight.

Inconsistent SMS Oversight

If you are in region #2 and you have discovered you have a "paper SMS," this still makes sense from a business perspective. When SMS auditing practices by oversight agencies are inconsistent, there is an excellent chance that major audit findings pass undetected for many years. This becomes a gamble. And while the stakes are ultimately high for the operator for non-compliance, the chances for certificate revocation become exceedingly slim by another significant margin. A paper SMS will probably survive a minimum of ten years in a region where SMS oversight is inconsistent.

Most simple operations in Region #2 can get by with a simple SMS manual and an Excel spreadsheet. This does not hold true in the European Union where databases are required to store safety report data.

Related Articles on Spreadsheets in Aviation SMS

• Spreadsheets vs Software for Aviation Safety Management
• 5 Things Spreadsheets Can't Do for Your SMS
• See How Spreadsheet Not EASA Compliant Aviation Hazard Reporting Database

Consistent and Constantly Improving SMS Oversight

Finally, if you are operating in region #3 where SMS oversight has finally matured, and you are still operating a good job. If you have followed this argument thus far, we were discussing business reasons for having a paper SMS where there is good SMS oversight.

If you are a small company and not a complex operator, it is surprising how many times, and for how many years an operator can keep going until the CAA has finally had enough. How many operators do you know that keep "sliding by" for years and occasionally, maybe occasionally, pay a fine?

SMS has these conceptions of "just culture" and "safety culture," and the CAA may try to hand-hold the operator until it realizes that the operator had neither desire nor inclination to change their culture and sincerely implement an SMS. It is hard to hand out "tough love" to operators in their early years of SMS implementation, especially when you are trying to be the "big brother" and "mentor" to operators who are struggling with "just culture" or no safety culture.

When

If you want to start operations in a region with mature SMS oversight, then you will be required to have a demonstrable SMS before the certificate is granted. All the pieces need to be there, whether you are using them or not. Some operators complain to me that it is like the "chicken and egg paradox" when it comes to demonstrating SMS performance monitoring when you still don't have operations.

If you are in Region #3, eventually you will be implementing a bonafide, demonstrable SMS. You may still be using paper and spreadsheets, but you are learning that your SMS isn't sustainable using these tools. You will realize that SMS documentation requirements are too diverse and too many to try to manage in a cobbled-together solution. This is the reality if you are in Region #3. There is no escaping this reality.

Accountable Executive Needs to Monitor SMS Performance

When you move from the paper SMS to a true, no-faking-it-anymore SMS, your account executive will be able to smile and be assured the SMS is properly implemented. In a perfect world, accountable executives have an unfettered ability to monitor aviation SMS performance. We are not talking about spreadsheets.

One of the major objectives of aviation SMS is to help aviation service providers identify safety issues and spot trends before these safety concerns turn into a near miss or "Accident." SMS intends to have all operators monitor SMS performance to detect these trends. The sooner operators can identify these trends, the sooner that detective and preventive actions can be implemented. SMS makes perfect sense. It is an effective system, but you have to work it out to realize the full benefits.

If you have more than 50 employees, your account executive needs to understand that they will not be able to easily "spot trends" in a timely fashion for extended periods (decades) using spreadsheets. In this case, the SMS is not sustainable and the SMS is not in Phase 4. Accountable executives in this boat may as well bite the bullet and either:

• develop an SMS database in-house; or
• adopt a low-cost, commercially available SMS database built specifically to address all SMS requirements.

You don't want a bunch of "point solutions" to manage your SMS. When you have eight different systems to manage SMS documentation requirements, this is not a pretty picture. If you don't believe me, take a quick look at the SMS documentation requirements. The cost of managing eight different systems is not worth the risk. The more moving parts, the greater the risk. The same applies to every aspect of engineering that I can think of.

The best practice is to have all SMS documentation requirements managed in a centralized SMS database. That centralized database will facilitate more effective trend monitoring and allow operators to identify trends and apply remedial actions in a more timely fashion.

Related SMS Trend Analysis Articles

• Aviation Safety Managers' Best Friend - Trending Charts
• How to Use Trending Charts in Aviation SMS
• Six Steps How to Perform Trend Analysis in Aviation SMS

Next Steps – Our SMS Implementation Is a Farce!

Did you discover your company's proclaimed SMS implementation phase is a sham?

If so, be careful. Egos are involved. Nobody appreciates the truth when you tell them that their "processes are crap." You should be honest and say something when things are not looking "proper." That is part of having a good safety culture.

If your accountable executive is preaching all those beautiful, nice-sounding "safety culture" words, and you realize your SMS is NOT properly implemented, you should call him on it. He may not know what is truly required of an SMS. If you want to show him, have him perform the assessments above. For your convenience, I'll add them again.

SMS Implementation Assessments

1. Phase 1 SMS Implementation Assessment
2. Phase 2 SMS Implementation Assessment
3. Phase 3 SMS Implementation Assessment
4. Phase 4 SMS Implementation Assessment

Safety cultures are not changed quickly. Bad-mouthing the safety program and gossiping about upper management's lack of oversight will not change anything.

To make meaningful, lasting change, you have to start from the top. One must possess tact, charisma, inexhaustible energy, and the ability to suffer setbacks.

Remember, SMS implementations are not overnight projects. SMS is more than a manual and a spreadsheet or two that only gets pulled out before the audit. Don't become discouraged if you don't see rapid progress. Some airlines and airports require four to five years for a successful SMS implementation.

You can also start by evaluating your SMS implementation using the SMS implementation Plan checklist below.

Most aviation SMS lack the proper tools to

• sustain their SMS; or
• spot trends; or
• monitor SMS performance.

User-friendly, Web-based software offers assurance your SMS remains sustainable and does not backslide. Watch these short videos to learn how your SMS program can benefit from good aviation SMS tools.

Last updated in November 2023.