It’s important to make the distinction between the
Being ICAO compliant with continuous improvement is a systematic review to continuous improvement verification. Actually, practicing continuous improvement will happen in day-to-day operations.
To summarize this distinction:
You will use internal SMS audits to confirm that your organization is sufficiently practicing continuous improvement.
To be able to tell stakeholders and auditors that your aviation SMS is practicing continuous improvement, you need to periodically perform an internal SMS audit.
These SMS audits should be conducted:
The act of performing an internal SMS audit demonstrates that you are dedicated to continuous improvement. That is, the act of verifying continuous improvement is a continuous improvement activity in and of itself.
Fulfilling this aspect of continuous improvement compliance involves being able to show a strong history of consistent internal SMS audit documentation.
One aspect of conducting periodic internal audits is having an auditing plan. This plan should include:
Your auditing plan does not have to be complex, but it should outline your audits in a way that an external auditor can review your plan and immediately understand the scope of your internal SMS audits.
Audit plans may be displayed on a calendar view, or simply listed in a table in your aviation SMS database. If you don't use an SMS database, an MS Excel spreadsheet will suffice. We have never seen a defined format for an audit plan in over a dozen years. However, we frequently are requested to provide guidance on audit plan preparation.
It’s absolutely critical that your SMS internal audits include a random sampling of historical issues managed. This sampling should review:
What you should be looking for is that the current risk assessment matches the most recent one. What you don’t want to see is a current risk assessment that is more than your most recent assessment, as this would indicate either:
Sampling issues that have undergone your organization's defined risk management processes are used to verify that:
Based on over a dozen years of experience, the most common audit finding we've seen is that aviation companies are not following their SMS manual's defined risk management procedures. If a process is described in your SMS manual, you had better follow what is written or change the procedure to more correctly align with your business processes.
Key performance indicators (KPIs) highlight the core performance of your safety objectives. Auditing your KPIs involves verifying that:
When KPIs are not current or are not being monitored thoroughly, it shows a lack of commitment towards continuous improvement and will reflect poorly on external audits. Automated KPI monitoring and notifications are a good way to ensure good audit performance. To automate KPI monitoring, you will need an aviation SMS database that is integrated with your aviation SMS':
KPIs are also known as SPIs (Safety Performance Indicators). We prefer the term KPIs because we work in both the quality and safety space. KPIs are a big topic in SMS and require considerable attention from the safety team.
Your SMS audits should include your contractors. This may mean having a separate auditing form dedicated to assessing the interactions contractors and suppliers have with your SMS. Things you might look for are:
The kinds of things you will audit in terms of vendors depend heavily on how many suppliers and/or contractors you have and how involved in your operations they are. But the point is, you need to audit and ensure that your contractors are not hindering the improvement of your SMS through their interactions in your operations.
Finally, the last way to demonstrate that you are compliant with continuous improvement is to ensure that your account executive is aware of important audit findings. Your accountable executive is ultimately responsible for the SMS. Continuous improvement activities must remain within the purview of the accountable executive; therefore, he/she needs to be aware of:
You need to have a demonstrable process documented, such as having all internal audits and corrective action plans signed off that they were reviewed by the accountable manager. To be safe, you may document the process steps for accountable executive audit review in your Safety Policy.
Operators who are in the early stages of their SMS implementations do not need to be overly concerned by the "continuous improvement" requirement. Keep in mind, that your SMS progress will be evaluated based on:
If you have been practicing the concepts of SMS for more than three years, you can expect some serious scrutiny through continual verification and follow-up audits by inspectors, whether they are:
For a few years, you may "sneak by" auditors in demonstrating verifiable continuous improvement in your SMS; however, be prepared for the final reckoning when auditors believe you have a mature SMS. In short, you will need proof, i.e., documentation that your SMS is effective, and your SMS is improving. This documentation will be difficult to produce if all you have are paper forms, MS Word documents, and spreadsheets to show to the auditors.
Proactive safety managers prepare for the eventuality of demonstrating continuous improvement by ensuring the SMS is well documented and that the documentation is easily retrievable. Nothing frustrates an auditor more than being told to wait while the safety team "searches" for phantom documentation.
SMS documentation is best stored in a centralized SMS database. This is a best practice. If you are familiar with the European Union's SMS requirements, you will know that a database is required to store hazard reporting data. This is another indicator that an SMS database should be a requirement in your organization to document all your SMS activities.
Are you prepared to demonstrate continuous improvement of your SMS? If not, we can help.
Last updated October 2024.