What Is Proactive Hazard Management
I have a friend across the globe who is having troubles getting his head around proactive hazard identification and the resulting risk management processes in his aviation safety management system (SMS). This friend naturally prompted this blog article to explain an approach to proactively manage hazards and to document hazard identification and risk analysis activities.
Proactive hazard management from a high level is looking at your operations and identifying hazards that may affect operations. The objective is to ensure adequate control measures are implemented to:
- Prevent the hazard from manifesting itself into an unfavorable event;
- Detect the hazard to alert operations; or
- Correct the damage should the hazard manifest itself.
We are going to go through some key elements of proactively identifying and managing your hazards.
Related Aviation SMS Hazard Identification Articles
- 4 Pillars | What Is Hazard Identification in Aviation SMS
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- From Reactive to Proactive Hazard Identification in Aviation SMS
Aviation Risk Management One Bite at a Time
When you think of all the hazards that may affect your operations, the thought of documenting them all becomes overwhelming. This is a big task and you should not be doing all the work yourself if you are the safety manager. Process owners and operational department heads have risk acceptance authority over their area of operations. Consequently, these managers are responsible for managing hazards in their areas of operations, which includes satisfying the SMS documentation requirements.
One of the biggest risks to aviation SMS implementations in their fifth to eighth year is that management is not reviewing their hazards on a regular basis. Perhaps I should restate this in that there may be no documented proof that management has adequately reviewed the hazards on a regular basis, whether it be quarterly or annually.
Again, documenting the proactive hazard identification and risk management activities is a huge task. I always recommend that you break the task into manageable bites and delegate sections of this task to resident subject matter experts. Otherwise, you can expect an audit finding, guaranteed. Enlist the process owners if at all possible. Otherwise, these managers may require more SMS training to educate them as to their duties and responsibilities to the aviation SMS.
Hazard Register Is Output of Proactively Identifying Hazards
SMS auditors usually discover findings with operators' SMS implementations in the later years regarding their hazard registers.
The hazard register is a
- list of all your hazards;
- who is responsible for each hazard;
- risk associated with the hazard;
- date each hazard was reviewed;
- next review date for each hazard; and
- how many events you've experienced regarding this hazard.
The last point is optional if you have an SMS database that allows you to easily classify your events or issues according to an identified hazard. A bonus is to risk rank your hazards according to the importance of the hazard, as most hazards are seasonal.
Most small operators without an aviation SMS database manage their hazard registers in a spreadsheet. This will work adequately for very small operators, but as an operator increases in size and complexity, managing hazards in a spreadsheet is not a sustainable risk management process.
Related Articles on Using Spreadsheets in Aviation SMS
- Spreadsheets vs Software for Aviation Safety Management
- 5 Things Spreadsheets Can’t Do for Your SMS
- How Spreadsheets Not EASA Compliant Aviation Safety Reporting Database
SMS Databases Facilitate Hazard Register Management
Operators with more than 40 to 50 employees are recommended to acquire an aviation SMS database to make hazard management activities more user-friendly. When hazard documentation is too cumbersome, it will not be sustainable in the long run and process owners will neglect the SMS documentation activities that are required to demonstrate SMS compliance. Smaller operators may also benefit from an SMS database if they have more complex operations or high employee turnover.
Hazard identification processes are not a trivial matter in aviation SMS implementations. The FAA places high regard on hazard identification activities.
According to the FAA,
The objective of Safety Management Systems (SMS) is to
- proactively manage safety,
- identify potential hazards, determine risk, and
- implement measures that mitigate the risk.
The FAA envisions operators being able to use all of the components of SMS to enhance a carrier’s ability to identify safety issues and spot trends before they result in a near-miss, incident, or accident. For this reason, the FAA is requiring carriers to develop and implement an SMS.
( Federal Register / Vol. 80, No. 5 / Thursday, January 8, 2015 / Rules and Regulations )
As you can see, there is an expectation of collecting years' worth of data and to analyze the data for trends. If you are still using spreadsheets, now may be a good time to consider acquiring a low-cost, commercially available SMS database. Conducting a trend analysis on a regular basis in a "spreadsheet SMS" will not be a task that safety professionals will relish on a recurring basis. A good database has built-in, user-friendly trend analysis tools that are accepted by the entire aviation industry. If for nothing else but documenting hazard identification and risk analysis activities, the SMS database will pay for itself.
What Is an Operational Risk Profile
As we stated above, documenting the proactive hazard identification and risk management activities is a huge task. For complex operations, it is best to break this task into major operational activities. For example, if you are an airline, your major activities include:
- Flight operations;
- Ground operations;
- Administration (including as safety and quality).
Airport operations' major activities revolver around:
- Maintenance or Engineering.
These lists are not all-inclusive, but you definitely do not want to go too far into the weeds. Each type of operation has hazards and risks related to the type of operational activities. Grouping all hazards together according to the operation type allows you to focus on the elements. We have to eat this elephant "one-bite-at-a-time." Otherwise, you will become confused and overwhelmed.
Related Aviation SMS Hazard Identification Articles
- FAA Part 5 Compliance | Safety Risk Management Hazard Identification Requirement
- How to Be Compliant with ICAO Hazard Identification
- SMS Chart: Where to Focus Hazard Identification Training & Risk Mitigation
Non-Complex Operations Have One Operational Risk Profile
Smaller, non-complex operations have only one operational risk profile. You will manage all your hazards in one bucket. You do not want to over-complicate matters.
One common strategy to segregate operations is by divisions in your company. Each division will have its own operational risk profile. Your aviation SMS database may allow you to create divisions to logically segregate:
- People (user-access); and
- Data (reported issues).
In this case, you can have an operational risk profile for each division. After all, the hazards in the "maintenance division" are different from the hazards in "flight ops."
Some hazards may exist in both divisions. If so, there should be a person responsible in that division to manage that hazard. If there is not a dedicated person in the division to oversee the risk mitigation strategies of the hazard, their will be a manager from headquarters or someone who has their feet in both divisions.
Breaking Down Operational Risk Profiles
We took our first bite. If you are a complex operation, we have a dedicated operational risk profile (ORP) for your division. Let's start adding some structure to our ORP.
When organizing hazards in an ORP, I prefer to use an easy to follow, logical schema, as follows:
- Hazard Category;
- Hazard Sub-Category;
- Hazard; and
- Control Measures (risk controls).
For each hazard, you will be identifying risks or credible risk scenarios. For each of these risk scenarios, you will be documenting control measures to mitigate the risk. Again, control measures will be either:
- Corrective; or
- Any combination of the above.
Your SMS may use the term risk control instead of control measure. These terms are synonymous.
If you are a risk management rock star, you may also want to document the type of control measure according to the hierarchy of control. To review, your control measure will be one of the following types:
- Administrative (policies); or
- Personal Protective Equipment (PPE).
The risk control hierarchy at the upper level (Elimination) is the most effective, with PPE being the least preferred.
Additional Articles on Aviation SMS Risk Controls
- Difference between Hazards, Risks & Control Measures in Aviation SMS
- How to Implement Effective Control Measures
- How to Monitor the Effectiveness of Control Measures
Risk Management Software Saves You Time
In the early days, I have seen many hazard registers in spreadsheets. These are hard to update and too unwieldy to manage in the long term. You will be storing safety reporting data for at least five years. Spreadsheets are not the correct technology for collecting, storing and analyzing many years' worth of safety data.
To add a specific shortcoming of spreadsheets, the hazard register needs to be integrated with the risk management system that documents risk management activities of:
- reported safety issues; and
- audit findings.
As safety managers process safety issues in the risk management processes, one activity is to classify safety issues according to related operational hazards. This affords the most efficient trend analysis results. Aviation risk management software will save you countless hours managing the hazard register and do a more effective task. Furthermore, management can receive automated email alerts when the SMS database detects developing trends that interest management.
Best practices will have your hazard register integrated with your classification schemes for classifying your reported issues, whether they be:
- Compliance; or
If your company has more than 60 employees, aviation risk management software is a must. Otherwise, your SMS implementation will fail in the long term. Software to proactively identify and track hazards cannot be under-rated. This will save your bacon when the SMS auditors come calling when you are in Phase 3 or Phase 4 of your SMS implementation.
Documentation Highly Important in Managing Hazards Proactively
If it is not documented, then there is no proof you are proactively managing your hazards. This final take-away here is for safety managers.
You cannot manage the hazard register by yourself. If you try, you are either:
- Doomed to fail; or
- Very luck your SMS auditor is incompetent.
At the beginning of this process, explain to the accountable executive of the importance of the proactive hazard identification and risk analysis process. Furthermore, stress that all operational department heads take part in the process and manage the areas under their control.
If you distribute the documentation workload required in the hazard identification and risk analysis processes, you are having a team eat the elephant instead of having to rely upon the imperfect judgment of the safety manager, who may, or may not have operational experience.
Your chances of long term success in this area of your SMS activity is increased tremendously when tackling the hazard register as a group. I always recommend to safety managers that they train the department heads how to identify and document their hazards in the company's aviation risk management software.
If you need software to identify, document and track your hazards, I recommend the Risk Management Solution or the Safety-Quality Assurance Solution. S-Q Solution has all the modules contained in the Risk Management Solution. Since 2007, SMS Pro has been providing SMS databases to operators around the world.
Here are some short videos that include the Proactive Hazard Analysis Tool (PHAT) and the Hazard Register. Even if you don't use SMS Pro, it will be useful to see how professionals manage an ICAO compliant SMS implementation.
If you need a list of hazards to seed your hazard register, you may be interested in this list.
Compare your existing SMS software solution to SMS Pro. See why it is considered the best.