Aviation SMS Implemented in Top-Down Approach
Every aviation safety management system (SMS) must be implemented in a top-down fashion.
There can be no other way, regardless of how liberal you think your company is.
But what is the top-down approach, and why are safety managers failing at SMS implementations when using this "top-down" SMS implementation strategy?
After witnessing many SMS implementations over the past dozen years, we have some observations regarding what works for safety managers and what may not.
We will quickly look at:
- What is the top-down approach;
- Two reasons why upper-level management fails; and
- Offer suggestions to aviation safety managers.
Related Aviation Safety Manager Articles
- What Makes a Good Aviation Safety Manager?
- 5 Habits of Highly Effective Aviation Safety Managers
- 5 Types of Aviation Safety Managers
What Is Top-Down Approach in Your Aviation SMS
For those who took Organizational Behavior as one of your college courses, you may recognize the autocratic leadership style, while those of us who have learned SMS outside of college know this as the top-down management approach.
For aviation SMS, top-down leadership is where the Accountable Executive drives change that requires the aviation service provider to implement and maintain their aviation SMS. We know that in practice, the Accountable Executive appoints employees to implement and manage the SMS. For example, in FAA's Part 5, there are explicit regulations for the "Designation of management personnel."
§ 5.25(c) Designation of management personnel. The accountable executive must designate sufficient management personnel who, on behalf of the accountable executive, is responsible for the following:
- Coordinate implementation, maintenance, and integration of the SMS throughout the certificate holder’s organization.
- Facilitate hazard identification and safety risk analysis.
- Monitor the effectiveness of safety risk controls.
- Ensure safety promotion throughout the certificate holder’s organization as required in subpart E of this part.
- Regularly report to the accountable executive on the performance of the SMS and on any need for improvement.
As we can see, regulatory requirements spell out the responsibilities delegated to the safety manager, or in larger operations, the Director of Safety.
Safety Managers Fail If They Drive Change Alone
The most common reason that aviation SMS implementations fail is due to the lack of top management support. Without the accountable executive's blessing, the SMS implementation will fail. End of story.
Top management support comes in the form of continuous demonstrations of commitment to the SMS. This commitment is most commonly seen as:
- Attendance at safety meetings;
- Visible physical support (walkarounds) with safety managers;
- Regular safety communications coming directly from Accountable Executive; and
- Providing resources to implement and maintain the aviation SMS.
Without this support, the best-intentioned aviation safety manager will fail. Now let's take a look at the bottom-up approach.
Related Aviation Safety Manager Articles
- 3 Essential Communication Techniques for Aviation Safety Managers
- Career Advice for Aspiring Safety Managers
- How to Tell If Aviation Safety Manager Is Doing Their Job
Bottom-Up Approach in Safety Management Systems
Joe is a pilot. He is an energetic, Type A personality who prides himself on achieving the impossible. A manager in the company tells Joe today that he is the new Safety Manager. "Joe, you are still the pilot, but you are also the safety manager."
This is a common scenario. Maybe the owner told Joe he was the safety manager, maybe a department head gave the order. Regardless, Joe is left to try to "figure out this SMS business."
Other employees may know that Joe is the "safety guy." Other employees may give him some token recognition, but Joe must charge ahead and
- Learn what is required in an aviation SMS;
- Review or create the SMS manual;
- Learn risk management processes and document them;
- Put together a process to monitor the SMS for effectiveness;
- Get other employees involved (earnestly) in the SMS;
- Be prepared for regulatory and client auditors of the SMS's progress.
Related Aviation Safety Manager Articles
- How Safety Managers Increase Their Power in Aviation SMS
- How to Be a Better Aviation Safety Manager
- Hardest Challenges of Aviation Safety Managers in Modern SMS
Learning What Is Required through Aviation SMS Training Courses
Joe has a lot of work. Remember, Joe is still a pilot and must still "be an earner." Only larger companies (greater than 60-80 employees) have dedicated safety managers. If he is lucky, and the company has a budget, he may get management to send him to an SMS course, such as those at:
- USC SMS Manager Course;
- SCSC Safety Courses;
- Cranfield University's Safety Management Systems Courses; or
- MITRE's SMS Courses.
What we see more commonly is that Joe will hire a consultant that can come to his location and provide some SMS training. These consultants have become very common within the past six years. It has become difficult to find a good SMS consultant because anyone who can spell SMS has called themselves an expert. If you are Joe and need a short list of SMS consultants, consider these highly qualified SMS consultants:
- Mike Doiron at Cirrus Aviation Safety Services;
- Aviation Consulting Group headed by Dr. Bob Baron; and
- Gordon & Rene Dupont at System Safety Services.
- JDA Aviation Technology Solutions
Yes, I'm sure there are more, but I cannot vouch for them.
What Safety Managers Learn at SMS Training Courses
Regardless of whether Joe attends an SMS training course or the SMS consultant comes to Joe's site, Joe will learn that for their company's SMS to be successful, he must have absolute support from the Accountable Executive. If there isn't a defined Accountable Executive, then Joe must do the "needful."
Yes, he must find the accountable executive and ensure the accountable executive understands;
- What is an aviation SMS;
- The SMS is required (in most cases if you are an aviation service provider);
- His legal and moral responsibility regarding the success of the SMS; and
- What is required to have a healthy SMS?
In short, Joe must turn around the bottom up the assignment of being the safety manager. No longer will Joe be implementing "Joe's Safety Program." Joe must return the responsibility of this SMS implementation and place it back where it belongs:
- On the Accountable Executive's plate.
Joe Must Be Implementing the Boss' SMS
There is a misconception that the safety manager owns the SMS. In reality, the accountable executive owns the aviation SMS and all employees must realize that the safety manager is merely "managing" or "helping out" the accountable executive in ensuring the SMS is properly implemented and maintained.
Related Safety Manager Articles
- Distinguishing between Responsibility, Authority, and Accountability in Your Aviation SMS
- 4 Tools to Find Resistance to Your Boss' Aviation SMS
- 3 Scenarios Accountable Executives Need to Minimize Risk to Aviation SMS
What Are the Two Reasons Safety Managers Fail
In conclusion, we see that safety managers fail because:
- They are implementing "their" SMS and not the Boss' SMS; and
- The Boss doesn't know if it's really his SMS; or
- Accountable Executive is not taking ownership of the SMS.
SMS training for both the boss and safety managers will certainly help rectify this issue.
And Another Major Reason?
Another reason aviation SMS fails is related to the above topic: Lack of adequate tools to manage the SMS. This stems from ignorance and is often caused by SMS consultants wanting to sound knowledgeable and leaving Excel spreadsheets with their clients.
Your SMS consultant is not doing you a favor if he gives you an Excel spreadsheet and Word docs to manage your SMS.
Excel spreadsheets are not effective to manage an SMS. I've worked with literally hundreds of companies' SMS. Excel does not work and is the short-term measure (or corrective action). Long-term corrective actions will focus on a database for your data management strategy. That is why EASA now requires a database for aviation service providers to store their SMS reports.
Related EASA SMS Database Articles
- See How Spreadsheet Not EASA Compliant Aviation Hazard Reporting Database
- Spreadsheets vs Software for Aviation Safety Management
- 5 Things Spreadsheets Can't Do for Your SMS
Below are some inexpensive alternatives to MS Excel spreadsheets that will give your Accountable Executive some peace of mind. Furthermore, an SMS database will reduce the risk to the SMS and make it more sustainable.
Last updated May 2023.