Hazard Identification Training and Safety Reporting in Aviation SMS
Hazard identification training and safety reporting can be seen as the beginning of the aviation risk management cycle in aviation safety management systems (SMS).
Is this the first step in the aviation risk management life-cycle? We shouldn't say this because employees and stakeholders reporting safety issues must be trained on what type of safety reports management wishes to process.
Consequently, safety training and safety promotion activities may be considered the first steps in aviation risk management activities. But is this accurate?
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Safety Promotion Not Beginning of Risk Management Life-Cycle
I could further argue that management's decision to improve operations or implement an aviation SMS to comply with SMS regulatory requirements is the beginning of the aviation risk management life-cycle. An aviation SMS is by its very name a "system." This system has four components or pillars that support the system. These four pillars are known to every aviation safety professional.
There is no way that one can justify having an effective SMS without any of the four pillars. They are all important and there is a logical purpose for each pillar:
- Safety Policy;
- Safety Risk Management (SRM);
- Safety Assurance (SA); and
- Safety Promotion.
For example, you take away the "Safety Policy." Then the purpose and management commitment for supporting the SMS crumbles into nothing. Well, I shouldn't say "nothing," because we would return back to the times of the traditional safety program. We can all agree that if the traditional safety program adequately addressed operational risk, then there would be no need for formal, structured aviation SMS.
Traditional safety programs had no management commitment. There was no expectation from management to supply adequate resources to manage safety to reduce risk to as low as reasonably practical (ALARP). I could easily argue that Safety Policy is the most important pillar and is the start of the aviation risk management life-cycle. Without Safety Policy, there is no "starting point" for the SMS. Safety policy defines:
- Accountable executive's commitment and responsibility to providing resources;
- Safety accountabilities and responsibilities to the SMS by all employees and stakeholders; and
- Who is in charge of implementing and maintaining the SMS.
I argue that Safety Policy is the beginning of the modern aviation risk management life-cycle. I could go one step further and claim that safety policy is the most important pillar, but I'm not quite ready to make this argument.
SMS is a system.
All pillars are important, just as with an aircraft. You cannot argue that the engine is more important than the wings, just as one cannot argue that the tail is any less important than the aircraft's nose cone.
Why Do We Need Safety Reporting Systems?
If we could rely upon operators to be responsible and implement safety programs, there would be no need for aviation SMS, right? This is obviously not a realistic expectation. The operator is in "production mode" and is in business to earn profits or satisfy a specific mission directed by its shareholders.
Aviation service providers are seldom compelled to voluntarily act responsibly to reduce risk to ALARP unless there is another motive that is financially based. Risk management activities cost time, money, and scarce resources that must be pulled away from production resources. Furthermore, operators may not know "how" to reduce risk to ALARP.
Based on over a dozen years of empirical evidence, most smaller operators do not have defined risk management processes before implementing an aviation SMS. As they start their SMS implementations, they realize they are required to have documented processes. Until then, they really have no need to document their processes. If something breaks, they fix it. They may not ask why it broke. They may think, "every year, we spend $250,000 in repair costs. This is just the cost of doing business."
To extend this argument, we also know that operators have not developed efficient, repeatable risk management processes even with the adoption of required SMS. This becomes evident as we see recurring incidents in the industry. How many times have you heard safety managers say: "this keeps happening over and over?"
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Alternatively, operators may be too busy "performing their mission" to focus on developing their repeatable risk management processes. So what have we historically seen? Operators focus on their mission. Profits are spent on increasing production capacities and not on improving production quality, which equates to safety. We can surmise that for SMS implementations, operators had neither the
- willingness; or
Even after a dozen years of SMS implementations, the rash of preventable occurrences continues to plague the aviation industry. Over the past two weeks, I have heard of several distinct reports involving aircraft wing damage during ground movements on the ramp. These are not serious incidents when one considers the risk to human life, but these are very expensive "minor incidents." Does an airline consider a damaged winglet a "minor incident?"
My sincere belief is that SMS is still a "check the box" compliance game for most organizations. It will take perhaps two generations for the "aviation system" to change from the obligatory,
"I have my SMS now what?" attitude, to
"We have an SMS and it improves processes and saves money."
For those multiple winglet damage incidents to happen in such a short time, it tells me the system is still broken. Employees and managers are either not:
- identifying the hazards correctly, or
- reporting the identified hazards; or
- properly implementing risk controls to mitigate the "why this event keeps recurring."
There are three pieces to this puzzle, and each is equally important:
- Hazard identification;
- Hazard reporting; and
- Risk analysis and risk mitigation.
Without one of these risk management activities, the system will be just like an incomplete, 3-pillar SMS. In short, the risk management process will not be effective. So now, we can see the importance of both hazard identification training and safety reporting systems. Once employees or managers identify a hazard, the hazard needs to be brought to management's attention in order to analyze, assess and mitigate risk to ALARP.
Hazard Identification Training & Safety Reporting Forms Define Priorities
Hazard identification training and safety reporting forms provide structure to the hazard reporting process. Both hazard identification training and safety reporting forms are commonly suited to a particular purpose or type of aviation service provider.
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Different operators have different needs because aviation service providers provide specialty services in their region or industry segment. Moreover, management also has operational goals and objectives that take precedence over safety goals and objectives. For example, management may need a paper SMS to operate within a particular theater of operations for a few years. Management may not need a long-term, costly SMS when their business objective is to "make money and get out." We see this behavior very commonly with private operators providing aviation services in another country or for a particular client, such as the oil and gas industry.
Other instances require a "paper SMS." Many smaller operators cannot afford more safety. Their production rates won't support the added cost of implementing an SMS in earnest, so the alternative is to implement a "paper SMS," which will survive for two to five years depending on:
- level of regulatory oversight;
- industry segment (airline, aviation maintenance, flight school, etc.); and
- ability to put on a good show for auditors.
The last point is worth expanding upon.
Operators know when auditors are scheduled to inspect operations. If you were ever in the military, you are familiar with the routine inspections. We all know the inspection is coming, so we scrub the floors, clean the weapons, and make sure all the documentation is in order. But as soon as the inspectors leave, it's back to the same old grab-assing, "do as you may" behavior. This was crazy behavior and I never understood it. Yet this is what operators do when an auditor is expected to come. Therefore, the comment on the ability of the operator to put on a good show for auditors reminds me of my military days. And I know it continues in private industry as well.
Aviation SMS goals and objectives must align with organizational goals and objectives. Otherwise, the safety team will continue to become disappointed and eventually become disillusioned to the point of becoming ineffective.
Hazard identification training will reflect management's commitment level to SMS performance. When hazard identification training is very brief and is intended only to satisfy a requirement, employees recognize the level of management's commitment to the SMS.
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How seriously do employees take hazard identification training? Are they
- joking around;
- rushing out of the classroom to take calls; or
The quality of the hazard identification training sets the tone for management's priorities to the level of participation expected by employees in the aviation SMS.
The hazard identification training aligns with organizational goals and objectives. During this training, employees will learn what are:
- risks; and
- risk controls.
Each operation will have its unique hazards, risks, and control measures. Employees need to know how to monitor risk controls and how risk controls are expected to work. This training is necessary so employees know what to do when a risk control is not mitigating risk according to the system design. And what should they do?
When risk controls are ineffective, the substandard behavior will be reported through the safety reporting system. In most cases, employees will be provided paper-based or Web-based reporting forms to submit safety concerns.
Safety reporting forms are designed to:
- educate employees as to what hazards are important to management;
- focus employees' attention to particular operational areas; and
- communicate to management when risk controls are not working properly.
Both hazard identification training and the safety reporting forms indicate management's priorities. Taken one at a time, one may draw incorrect conclusions about management's commitment to SMS performance.
For example, the operator acquires a robust, Web-based SMS database for hazard reporting and risk management processes. The operator has obviously demonstrated commitment to the SMS. But when the operator neglects to provide adequate training on how to effectively use the SMS database, there is obvious discordance between management's real goals and objectives and the organization's safety goals.
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It may be that management didn't have time to develop their own safety reporting system and the related risk management processes. Therefore, management threw money at the problem and acquired the SMS database as a matter of expediency. A few hundred dollars per month is very inexpensive to get a safety reporting system complete with industry-accepted risk management processes.
This is actually a common occurrence in Africa and Southeast Asia. We are approached about six times each year by aviation service providers who need an SMS but really have no desire to implement an SMS. They buy a subscription to SMS Pro and then they let it sit, barely used. Obviously, their intention was to demonstrate to their regulator, and sometimes a client, that they have the "ability to practice SMS' required risk management processes."
By purchasing the SMS database tools, they did indeed acquire the ability and the accompanying risk management processes, but they simply lacked the motivation or willingness to go further. By going further, the operator would need to start promoting the SMS, training employees, and improving their safety culture.
Alternatively, we could analyze an operator who devotes considerable resources to providing high-quality hazard identification training but has inadequate tools to report safety issues. We see this usually with operators using paper-based forms, or email and spreadsheet SMS. The operator may spend tens of thousands of dollars on hiring an SMS consultant and pulling employees from their production jobs to sit in hazard identification and SMS training. Yet the operator is reluctant to spend a few hundred dollars per month on a modern, user-friendly safety reporting system that comes with:
- predefined reporting forms;
- automated email notifications; and
- immediate feedback to employees reporting safety issues.
In both cases, we have identified the importance that both hazard identification training and safety reporting tools possess in the SMS.
Safety Reporting Forms in Safety Management Systems
Aviation safety reporting forms commonly tailored for safety management systems, regardless of whether they are
- Scheduled or on-demand operators;
- Flight schools;
- Aviation maintenance organizations;
- Military or police operations; and
- Fixed based operators.
Unique industry segments may require different types of information to manage the reported hazard. For example, an aviation maintenance organization may want to collect information about aircraft parts, ATA codes or aircraft types, while a flight school may be more interested in information regarding students.
There are some best practices about safety reporting forms that safety managers need to understand. Reporting forms should be developed with the end-user in mind. There is a common tendency to develop safety reporting forms for the benefit of management, with little regard for employees. This becomes evident when there are more than 20 data points on a reporting form. Another indication of "not caring" about the end-users experience is to see reporting forms that are too busy. These reporting forms not only have too many data points for users to enter, but the layout is not logical or the form fields are crammed together, making the form difficult to easily read.
Safety reporting processes should be fast, painless, and rewarding. When safety managers make their employees suffer each time that they report safety concerns, you can guess what will happen. Nobody will report. Safety culture suffers.
Did you catch this? Your safety reporting system may be damaging your safety culture. If you want to be neutral about this, an equally disconcerting thought is that the safety reporting process leaves employees indifferent toward the aviation SMS.
Do I have proof of this?
If you are in the United States and are either a part 121 or part 135, you may have heard of the FAA's sponsored WBAT reporting software that the FAA provided to operators for free. They now charge money for this (too much for what you get).
Have you heard of this WBAT software? If not, ask someone who works for an airline or a part 135. Ask them whether WBAT left them feeling positive about their company's safety culture. I already know the answer. Nobody likes WBAT and yet the FAA, with its deep pockets, cannot fix it. WBAT is aviation safety software that hinders the development of healthy safety cultures instead of supporting a healthy safety culture.
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Safety Reporting Forms Not Just for Reporting Hazards
Hazard reporting forms may not be the best term to use for safety reporting forms. For many years, I have become so accustomed to hearing about hazard reporting that I gave little thought to how powerfully limiting those words mean. The title makes one believe that an aviation SMS is only interested in potential or identified "hazards."
Consequently, "hazard reporting form" seems like a misnomer. But then, should we call them "safety reporting forms?"
There is actually more to this story. While reporting forms are useful for reporting hazards, they are also designed for any safety-related "issue" including:
- Accidents (an unintended event that causes damage to persons or property);
- Incidents (an unintended event with the potential of causing damage to persons or property); and
- Other irregularities (including hazards).
Safety reporting forms are used for actual and potential events, or occurrences. Some safety documentation uses the term "safety occurrence" or "incident," but we feel these are also limiting terms, an "occurrence" and "incident" imply that something has occurred. The best term we have seen for hazard reporting is "issue reporting," as an issue can be both actual or potential.
Using a generic term like "issue reporting" also does not limit the scope to simply safety or security.
The term "issue reporting" can be extended to other risk management systems that have been adopted by the aviation industry.
Safety Reporting Forms Not Just for Safety
Safety reporting forms for hazards (accidents, incidents, irregularities) need not be limited to only aviation safety-related issues. Modern aviation SMS encourages employees, customers, and other stakeholders to report issues related to:
- Quality (customer service);
- Compliance (regulatory and contractual); and
Pure, homogeneous management systems are designed to manage one of these types of issues.
The most efficient aviation service providers have recognized considerable benefits by extending one management system to accommodate issues that would normally exceed their original scope. For example, within the past few years, we see aviation service providers use flexible SMS database software to manage their quality management systems (QMS).
Other operators also include other departments' issue reporting management in their aviation SMS, such as:
- Security department;
- HSE, OHSA and OSHA;
- Customer care; and
Aviation SMS' risk management processes are sound. Astute managers realize that other parts of their businesses can benefit from similar risk management and decision-making processes as they exercise in the aviation SMS.
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Integrated Management Systems Require Generic Reporting Forms
Safety managers can positively influence other operational department heads when you share "your secret risk management sauce" that you use with the aviation SMS. We see the younger generation of safety professionals adopting SMS processes in other areas of the company. This has several benefits, including:
- reduced training costs;
- reduced software systems cost;
- improved risk management processes across the entire organization, versus just operations;
- increased visibility of the aviation SMS; and
- more effective team building as users share tools.
There are special considerations when the safety team shares their SMS database with other functional units. For example, how is data segregated? A typical use case is when the HR department wants to use the SMS database and the risk management processes that come with the SMS database. HR data is considered sensitive information. You do not want all employees or managers accessing employee HR records.
The logical and secure isolation of one department's data can be accomplished with modern, commercially available SMS databases that have been designed specifically for this use case.
Another example we commonly see is an airport's security department needing similar risk management tools as those enjoyed by the safety department. These airports create a "division" in their SMS databases to provide a secure work area within the SMS database. This has the advantage of:
- providing security department with their own "security reporting system;"
- allowing security department access to specialized auditing tools;
- aggregating managerial reports across all other company divisions based on security permissions; and
- assuring the security department that unauthorized access is managed by the software;
For operators who want other departments to share their SMS database, you will require at least one safety reporting form that captures information suitable for the department(s) sharing the SMS database.
Most aviation SMS databases have reporting forms for:
- Flight safety;
- Aviation maintenance;
- Cabin safety;
- Airport safety;
- Fatigue risk management;
- Air traffic control;
- Security; and
- General safety.
A very simple approach to include issues from the HR or Commercial departments would be to have a "General Safety" or "General Issue" reporting form. This reporting form could be used for
- Fitting of wrong parts;
- Loose objects left in aircraft;
- Gear pins not removed before departure;
- Installation of wrong parts;
- Food cart deficiencies;
- Intoxicated pax;
- Lost baggage;
- Passenger complaints;
- Ticketing problems; and
- Boarding problems.
These above issues may not prove to be immediate safety concerns (some of these are). There may not be a suitable reporting form in your aviation SMS database to deal with these "generic quality issues;" therefore, they can be easily submitted using your SMS' generic safety reporting form.
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Final Words on Hazard Identification Training & Safety Reporting Forms
SMS require systematic review. Reporting forms should be critically reviewed at least every two years. Annual reviews would be best. It is rare that major changes are needed to safety reporting forms.
If you decide to modify safety reporting forms, make sure you follow best practices, such as:
- Don't make the forms too complicated;
- Create forms for end-users, not for management;
- Use adequate white-space to reduce clutter; and
- Don't have too many "required" fields;
- Include forms adaptable to both safety and quality; and
- Only ask questions that absolutely add value to the reporting process.
Safety managers are very busy and one of their biggest challenges is to increase safety reporting numbers. Well-designed, easy-to-use safety reporting forms, supplemented with high-quality hazard identification training, will increase the chances that employees will report issues more than once. Otherwise, you are wasting everyone's time. You may as well have a paper SMS.
Aviation SMS databases offer tremendous power to an SMS. Modern, commercially available SMS databases include multiple, integrated systems, such as:
- Safety Reporting System;
- Risk Management System;
- Online SMS Training System;
- Auditing System.
SMS software influences safety culture. If you have the wrong SMS software, you may suffer years of an unhealthy safety culture before determining the root cause.
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Last updated October 2022.