Do We All Know What Is Aviation Safety Management?
Aviation service providers coordinate materials and activities of their core business model in order to achieve desired objectives. These objectives vary by industry segment type, including:
- Aircraft maintenance;
- Transporting cargo and passengers;
- Aircraft fueling operations;
- Baggage and ramp handling services;
- Air navigation services; and
- Providing facilities for aircraft storage and operations.
Safety management is always included as an important consideration for production-focused enterprises as well as service-oriented businesses. Aviation operations inherently possess high degrees of risk with the potential for catastrophic consequences should a hazard manifest itself.
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Too often, aviation professionals and laymen alike hear about "aviation SMS" without really understanding the fundamentals or background of aviation safety management. This is not a history lesson.
Safety Management Composed of Simple and Complex Processes
Aviation safety management entertains multiple, inter-twined processes, including:
- Controlling risk;
- Performance monitoring; and
These are all iterative, ongoing activities that when taken independently, may not seem overwhelming. Putting them all together in an ever-changing environment, managing these processes becomes more challenging.
Aviation service providers operate in an open system, meaning that there will always be uncontrolled external environmental factors influencing the operations of each aviation service provider. Open systems are naturally riskier than controlled, closed systems. In case you are not a business management major, these external factors include:
- New technological changes;
- Regulatory changes;
- Legislative changes;
- Social factors;
- Political instability; and
- Economic factors.
Safety Management in Aviation Stops When the Business Does
As aviation service providers continue to operate in open systems, their aviation safety management processes are never complete. Service providers must continually monitor the environment and review their processes to ensure that their processes remain effective.
The external factors outlined above are constantly evolving. The industry has recognized that change is required. Aviation service providers are unable to "do business as usual."
Old-school thinking does not bode well for aviation organizations that wish to survive. Yet this aversion to change remains the biggest deterrent to ineffective safety management. Toxic safety cultures must evolve. Resistance from all levels of the organization must be eliminated before aviation service providers benefit from modern, structured aviation risk management practices.
When this resistance is not properly managed, the toxic safety culture will not allow service providers to continue to operate. Sooner or later, regulatory authorities will demand change or the organization will suffer from "The Accident" that we all know is coming, but we don't know:
- To whom?
- Where? or
But we do know "why." Modern safety management is a sound process; however, the process will not work when management and employees resist the opportunity to implement modern risk management strategies.
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Will Aviation Service Providers Ever Be Safe Enough?
Commercial aviation may be considered the safest form of transportation available; however, aviation professionals recognize the need for improvement. Not all service providers maintain "best-in-class aviation safety management practices." In fact, I know many who are doing the bare minimum.
The phenomenon of safety management is like "security management." Security management is expensive to do right and is also difficult to measure when processes are effective. With this thought, how will we know we have reached "as low as reasonably practical" (ALARP) as a global system?
When will aviation safety management programs be "good enough?"
These are philosophical questions, but we can all agree, that the time has not yet arrived when we can rest on what we currently have implemented. We can certainly do better.
Need to Self-Police to Maintain Consumer Confidence
Let's consider medicine as another risky industry. Doctors don't like to broadcast to the public the high rate of medical practice errors, as bad news may cause the public to lose confidence in "the system." The aviation industry is more transparent, and when an aircraft goes down, we usually hear about it in the news. However, there are many close calls or near misses that the public never hears about.
Aviation professionals are very cognizant of these unreported anomalies that may manifest themselves into an incredibly serious event. This is why management recognizes the need for "global aviation system improvements."
"As of November 23, 2006 States shall require, as part of their safety programme, that an [operator, maintenance organization, ATS provider, certified aerodrome] implements a safety management system (SMS) accepted by the State that, as a minimum:
- Identifies safety hazards.
- Ensures that remedial action necessary to maintain an acceptable level of safety is implemented.
- Provides continuous monitoring and regular assessment of the safety level achieved.
- Aims to make continuous improvement to the overall level of safety."
Since 2006, there has been a big rush for aviation service providers to adopt SMS according to ICAO's recommended model. You may know this model as having four components (or pillars) and 13 elements.
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Aviation SMS Synonymous with Aviation Safety Management
Today, when we speak of aviation safety management, every aviation safety professional assumes that we are talking about aviation SMS which is a formal process that has many benefits, including:
- Offering an international standard to aspire to;
- Elevating safety awareness;
- Holding airlines to a higher safety standard;
- Increasing regulatory oversight; and
- Engaging customers demand formal safety processes.
While this may be true to some extent, aviation SMS goes much deeper than mere aviation safety management. Using SMS processes, operators can reduce operational risk while at the same time increasing profit margins. This is what needs to be stressed to upper management. SMS is not simply another regulatory hurdle to leap and "check the box." SMS can be a profit driver when implemented properly.
Aviation SMS Has Teeth to Ensure Accountability
In most cases, implementing an aviation SMS is not optional. SMS are implemented in a top-down approach, meaning that each service provider will appoint an accountable executive who is responsible for the proper implementation of the SMS. Furthermore, accountable executives must continue to monitor the SMS to ensure it is performing as designed throughout the organization. Failure to abide results in fines and potential jail for accountable executives in extreme cases of neglect.
Due to these potential consequences, regulatory authorities need to hold someone accountable for SMS implementation and performance. This responsibility rests on one person in most organizations. I have heard that larger corporations may have their "board members" act as accountable executive, but I've never seen it in practice. To me, there is a stronger commitment to avoid potential consequences when the responsibility rests with one person, the accountable executive.
According to the FAA under 14 CFR Part 5 regulation, the accountable executive:
- Is the final authority over operations authorized to be conducted under the certificate holder’s certificate(s).
- Controls the financial resources required for the operations to be conducted under the certificate holder’s certificate(s).
- Controls the human resources required for the operations authorized to be conducted under the certificate holder’s certificate(s).
- Retains ultimate responsibility for the safety performance of the operations conducted under the certificate holder’s certificate.
In short, the accountable executive has financial power and must influence organizational members to both implement and sustain the aviation SMS. Otherwise, the accountable executive will be the one who will be held, well I hate to say this, but "accountable."
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Aviation SMS Requires Performance Monitoring
When SMS first became a requirement in 2006, there was little effective oversight. In the following two years, we saw many GA operators go out and buy SMS manuals from safety consultants. In MANY cases, these operators would only change the name on the front of the manual and proclaim, "We have an SMS. Here is our manual."
This worked for a couple of years. Operators would fly to regions requiring SMS and present their manuals, which were deemed indicative of the SMS. Inspectors could do very little but allow operators to enter their country with their "paper SMS." The chances of this occurring today are still good, but oversight has become better.
If you are in Canada, Australia, or Western Europe, you should not count on your paper SMS to survive. As SMS oversight becomes better and inspectors are more consistent in performing SMS regulatory audits, the accountable executive will have to demonstrate that the SMS is performing. They will be required to regularly monitor safety performance and be able to mitigate substandard SMS performance.
Culture plays a large part in the implementation and sustainability of the SMS. I'm not only talking about safety culture but regional cultures. When a populace has the mindset that "we can do anything we like as long as we don't get caught," then implemented SMS will only be paper SMS at best where operators continue to react to SMS auditors and continue to "check the box" instead of "working the process."
This is unfortunate because the process works. Safety cultures take time to change. A country's culture takes even longer to change and corruption continues to undermine the implementation efforts of many countries. This is seen where auditors are paid to look the other way and present favorable reports, else they risk not being invited back to audit the organization.
How long do you think it will take?
If you are implementing a safety management system, or even if you are reviewing your existing safety management system, then I encourage you to review an SMS implementation plan. It is crucial that you understand the framework and requirements.
Updated January 2023