Safety Managers Get into Trouble Due to Verbal Skills
Aviation safety managers are among the most articulate group of all aviation professionals. I don't have all the answers why this group is so:
- Verbally adept with writing; and
- Equally skilled at speaking.
Perhaps this is due to the similarity between truck drivers and pilots. Of course, I'm smiling as I write this, but have you ever noticed how both pilots and truck drivers have the gift of gab? Most safety managers I've dealt with were formerly pilots.
This trait of being very articulate is what causes trouble with safety managers whenever they write or restructure their SMS manuals.
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SMS Manuals De Facto Proof of Aviation SMS
Since the "aviation SMS" craze, aviation service providers have been scrambling to demonstrate compliance with the ICAO aviation safety management systems (SMS) requirements. These requirements are outlined in ICAO's guidance material: Safety Management Manual (SMM). Thousands of operators ran out and either created or purchased aviation SMS manuals.
Although these operators had SMS manuals, they were little more than paper. In the industry, we call these "paper SMS." I've heard more than one report from auditors where they have found SMS manuals at a company with another company's name written in them. Obviously, the company purchased the documentation and didn't bother even reading or modifying the documentation to adapt the SMS manual to their individual operations.
I believe operators felt safe with an SMS manual, although their operations didn't change to reflect what was written in the manual.
And this is what gets most aviation service providers in trouble with auditors. Auditors will review risk management processes described in the SMS manuals and determine whether you are following these processes. If you are one of those operators who purchased an SMS manual with the assumption that you now have an SMS, you are mistaken. You will need to review the SMS manual and ensure that your processes mirror what is written in the SMS manual.
Aviation Safety Databases Confound SMS Manual Writing Process
Aviation safety databases can be very simple affairs for only storing:
- Reported hazards;
- Investigation reports; and
- Training records.
Aviation SMS databases can also be very complex safety solutions designed to manage all SMS requirements in a single, centralized data repository. These more complex safety databases have been designed specifically for the aviation industry to manage SMS regulatory requirements. More complex SMS databases have multiple systems wrapped up in one framework. For example, you will have:
- Safety reporting System;
- Risk Management System;
- SMS Performance Monitoring System;
- Auditing System;
- SMS Training System;
- Safety Goals and Objectives Tracking System;
- Document Management System;
- Hazard Register and Safety Risk Analysis System, etc.
There are also other safety databases that have been designed for other industries, such as chemical, mining, and maritime. While these databases can be considered as a "safety database," they were not designed with the sole purpose of satisfying ICAO regulatory requirements. Consequently, these databases don't have the aviation "smell" and it becomes obvious that they were hacked together quickly to enter a new market.
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When one reviews aviation SMS documentation requirements, they will quickly see that data management requirements are incredibly broad, as they must encompass the four pillars or components of an aviation SMS.
For example, we see requirements for:
- Hazards report register;
- Hazard report (issue) management;
- Safety performance indicators;
- Records of completed or in-progress safety assessments;
- SMS internal review of audit records;
- Safety promotion records, such as safety surveys and safety newsletters;
- Personnel SMS/ safety training records;
- SMS Safety committee meeting minutes; and
- SMS implementation documentation.
As we see, safety databases for aviation SMS are very extensive and cover a wide range of subject areas. For example, it is not unusual for a full-featured aviation safety software solution to have more than 25 modules. Imagine how much documentation must accompany the most complete SMS software solutions!
How does this documentation integrate with your SMS manual?
How well do your risk management processes align with your SMS software documentation?
Safety Database Complexity with Aviation SMS Manuals
Due to the complexity of aviation SMS database solutions, safety managers have a challenge: how to have a complete aviation SMS manual that correctly covers all required elements in the SMS? This is difficult because:
- Aviation safety managers are highly detailed creatures;
- Aviation safety databases are subject to frequent changes due to technology or regulatory requirements;
- Auditors are looking for aviation SMS manuals with "substance;" and
- Aviation SMS auditors inspect to ensure operators "do what their manuals say they do."
The most common audit finding for an aviation SMS is that the safety team is not following risk management processes outlined in their SMS manual. This is a real problem. To fix it, there are some strategies that will help you avoid some grief.
Tips for Writing Aviation SMS Manuals Following Software Solutions
Safety managers are articulate. This trait may occur because they are highly educated. Or they possess the "truck driver" gene. Have you ever talked to a truck driver?
Anyhow, the best advice for safety managers and their SMS manuals are:
- Keep it simple;
- Less is often more;
- Keep the documentation very general; and
- Reference external documentation or software processes.
Keep It Simple
More than once, I have seen safety managers get into trouble because they wrote risk management processes while thinking of the more involved, high-risk issues that come from their safety reporting systems into their risk management systems. What they overlook is that these processes must be implemented for all issues that enter your aviation risk management system. Therefore, your processes should not be so complex that they burden your SMS.
Less Is Often More – Keep It, General
Auditors don't create findings if you overwork an issue according to your SMS manual. Their audit findings jump at you because you under-worked an issue because you didn't follow all the steps in your defined risk management processes. Therefore, your SMS manual will better serve you when your risk management processes work equally well with the general, low-risk issues as well as with your high-risk issues.
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Reference External Documentation in Your SMS Manual
When you are using an aviation SMS software solution, you should never copy and paste software workflow procedures from the SMS software documentation. I understand that safety managers are professionals. They have a need to provide something of "substance" to auditors and managers who use the SMS manual. Therefore, they think that the heavier the SMS manual, the better it is.
Safety professionals are better served by adding references to their aviation SMS database documentation. This will prevent any potential conflicts should the database workflows change.
An example may help: "Our company will perform investigations according to the workflow outlined in the XXX aviation SMS software solution."
This approach is cleaner and less prone to scrutiny by an auditor who is having a bad day.
Final Thoughts on SMS Manual Contents
These techniques will save you considerable grief. Each year, we see three or four safety managers receiving audit findings because they didn't follow the proffered tips above.
If your aviation SMS database solution has high-level workflow diagrams, these should be acceptable to illustrate your processes. Furthermore, when you choose an aviation SMS database provider, ask them for workflow diagrams to include in your SMS manuals. When your defined processes follow what you actually do in practice, then there is less risk for an audit finding.
If you are an SMS Pro user, you have access to a very complete SMS manual template that is aligned with the SMS database's workflows and risk management processes. This allows you to have your baby without the labor pains. Let's work together to reduce your workload and make your SMS something management can be proud of.
Full-featured aviation SMS software can be very complex. After all, it should be helping your company satisfy the ICAO SMS requirements. To see an example of how SMS database software can assist your SMS implementation, follow the link below.
Last updated June 2022.