What Does It Mean to Restructure Aviation SMS Implementations

Occasionally aviation safety managers will want to do a turn and pivot with the direction of their aviation safety management system (SMS) implementation. What this looks like is restructuring.

When safety managers decide to restructure an aviation SMS implementation, it means changing and updating the bureaucratic structure of the SMS and possibly some of the SMS' documented risk management processes.

Usually the decision to restructure is made in an effort to:

• Improve aviation safety culture;
• Improve safety performance by streamlining processes;
• Align SMS documentation to "real-life" risk management processes; and/or
• Take the safety program to the “next level.”

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Careful Consideration Required Before Restructuring

Often, this decision to restructure the SMS is a reactive one.

Restructuring an aviation SMS implementation can become a daunting task, and no client we have worked with has willingly embarked on restructuring simply because it was going to be beneficial "sometime in the future." Of course, proper restructuring does provide long-term benefits, but restructuring happens because there is an immediate incentive to do so.

The most important thing to understand about restructuring is that it is both:

• Change management; and
• SMS Implementation.

Restructuring uses elements from both SMS activities. On the one hand, restructuring involves implementing entirely new changes in the form of an overhaul. At the same time, restructuring is best managed as a change management operation rather than a traditional SMS implementation.

Why Restructure Your Aviation SMS Implementation?

Incentives for restructuring are usually one of the following:

• Improving an initial SMS implementation that focused on mere compliance (paper SMS or check the box);
• A risk management tool overhaul, such as in adopting a new aviation SMS software;
• Safety performance has reached a plateau;
• Changes in company structure, i.e., either from becoming more complex or selling company assets;
• Reduce complexity from initial SMS data management processes;
• Compliance with regulatory guidance or regulators' expectations;
• Aviation SMS implementation becomes increasingly more difficult because of bureaucratic weaknesses; and
• Financial benefits of restructuring outweigh the costs of continuing with the current SMS architecture.

All safety managers make mistakes during implementation.

Some mistakes can cause chronic roadblocks in the SMS' risk management processes or the SMS' data management strategies.

Restructuring an aviation SMS implementation allows safety management to extract the beneficial parts of the original SMS implementation and re-implement more troublesome areas of the system with change management techniques.

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Step 1: Ask Questions, Identify Clear Goal for Restructure

Identifying a singular, overarching goal for change management is an extremely important first step in restructuring the aviation SMS. The main goal should be a single sentence that identifies a singular purpose. Now in addition to the singular goal, or restructuring “thesis,” restructuring will surely have several different minor goals which should be accounted for as well.

Goals should be identified by asking questions about the restructuring, such as:

• What reasons instigated the desire to restructure?
• What specific problems will the restructure ideally solve?
• What are specific challenges involved in this restructure?
• What tools/methods will be used to address challenges?
• Which people/departments will be most affected by the restructuring?
• Which SMS elements will the restructure affect the most?

The key point of your responses is for them to be as specific as possible. The more specific the goals, the better you can address relevant issues and perform an accurate accounting for the scope of work.

Step 2: Build Around Risk Management Tools

This is perhaps one of the most important steps in restructuring. Restructuring is the perfect opportunity to adopt an overhaul of risk management tools or more commonly, SMS data management tools. In fact, the need for an overhaul of the SMS data management tools is often the primary instigator of the restructuring.

The reason the restructure should be built around the tools is that SMS tool solutions have already built-in procedures, workflows, and processes. These tools are also at the center of active safety efforts. It only makes sense therefore to build a program’s bureaucratic structure around them.

When we are talking about risk management and data management tools, we are primarily talking about:

• Aviation safety database;
• Safety reporting system;
• Hazard documentation system, such as hazard register;
• Risk analysis tools;
• Issue management tools;
• Communication tools; and
• Presentation tools (such as safety charts).

Examples of restructuring risk management tools are:

• Adopting an aviation safety database;
• Moving from spreadsheets and manual systems to point systems and software; and
• Moving from point solutions to a fully integrated aviation SMS software solution.

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Step 3: Perform Gap Analysis and Create Plan

With your goals in mind, the next step in restructuring is to do a gap analysis of where various elements of your SMS implementation are now vs. where your goals have identified they would be after a restructuring.

The purpose of this activity is:

• Understand which SMS elements will need to be addressed by the restructure;
• The scope of the change management for restructuring; and
• Prioritization of restructuring the various elements.

After performing a gap analysis, you will need to create a change management plan, just as with any other change management operation. This plan should address:

• Time frame and deadline goals;
• Potential risks with restructuring;
• Affected people, departments, bureaucratic elements, etc.; and
• General road map for implementing changes.

Without identifying specific goals and then performing a gap analysis, it’s practically impossible to create a plan for restructuring the aviation SMS.

Step 4: Communicate the Change Management Goals

Accompanying the creation of a plan for restructuring the SMS should be detailed communication about the restructuring. This restructure can and should be communicated:

• Via email;
• In safety meetings; and
• With a newsletter.

Simply communicating the restructure to employees one time, through one mode of communication, is not good enough. The change needs to be communicated multiple times through multiple mediums. Doing this ensures that:

• Employees understand that the restructure is a high priority (i.e., it’s “serious”);
• Employees have time to acclimate themselves mentally to the proposed change;
• Employees are not taken by surprise, which will naturally heighten their resistance to the change; and
• Employees don’t miss important information regarding the proposed changes.

Let’s be honest, many employees are complacent about your SMS. They will probably merely skim any safety material they are given. Having them review the restructuring plan multiple times will help ensure that they see the most important information about changes.

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Final Thought: Perform Change Management Implementation

After completing steps 1-4, most of the leg work for restructuring has been done. At this point:

• The ultimate goals of the restructure are clear and communicated;
• The areas of the SMS that need to be restructured have been analyzed and identified;
• You have ensured that the SMS architecture and SMS tools will be intimately integrated after the restructure; and
• You have organized all the elements of the restructure into a plan, or “road map.”

What is left is to follow through.

Some changes to the SMS implementation are trivial, such as modifying the safety reporting policy. Yet others require considerable rework of the SMS manual.

Reworking the SMS manual may require coordination with regulatory agencies, so please contact your representative at your civil aviation authority if you are unsure of the appropriate steps to change the SMS manual and acquire the necessary approvals.

As mentioned, the most common restructuring we see is when an operator starts using new SMS data management tools. Their SMS manuals must align with their SMS database's risk management processes. Since this is such a very important part of the SMS implementation, SMS Pro provides an SMS manual template to assist operators in a smooth transition from spreadsheets or their legacy point solutions to using the SMS Pro database, which is a complete SMS data management platform.

Even though SMS Pro comes with an SMS manual template, the operator must review the SMS manual to ensure the documented processes align with the operator's processes. If you are considering upgrading your SMS data management processes, consider using SMS Pro. SMS auditors love how all SMS documentation is collected and organized in a complete system.

To learn how your company can benefit from using a complete SMS data management tool, please watch these short demo videos.

If you are restructuring your SMS implementation, you may find the following free change management content useful:

Last updated August 2024.