Implementing a Safety Management System within an EASA Part 145 Organisation

Implementing a safety management system within an EASA Part 145 Organisation – Sofema Aviation Services (SAS) provides insight!

Do we agree on the purpose of an Aviation SMS?

• According to ICAO – ICAO Doc 9859 para 2.13.2 – ‘A hazard is generically defined by safety practitioners as a condition or an object with the potential to cause death, injuries to personnel, damage to equipment or structures, loss of material, or reduction of the ability to perform a prescribed function.’
• ICAO Doc 9859 para 2.14.2 – ‘Safety risk is the projected likelihood and severity of the consequence or outcome from an existing hazard or situation’.

The Maintenance Organisation / CAMO / Airline – View

To hopefully agree that the overriding purpose of the Safety Management System is to ensure

• Our organisation as well as
• Directly our subcontractors and
• Indirectly our contractors

Our Overriding Safety Objective – To Conduct Safe and Secure Operations and Minimise the Exposure to any Perceived Hazards.

As well as ensuring that we understand all the safety risks faced by the operation and its subcontractors.

From our feedback from 100’s of delegates attending Sofema Training courses a consistent lack of comprehension is evident for example how sure are you of the meaning and difference of the following:

• Hazard / Risk;
• Quality Assurance / Safety Assurance;
• Compliance / Performance.

What does “SMS responsibility related to their role and responsibility within the organisation” – Actually Mean?

So it is important for all of our team to know what “normal” looks like and what “abnormal” looks like. This is easier said than done & requires:

• Workplace Knowledge
• Competence
• Understanding
• Willingness to engage (Organisation Culture Supports & Rewards Reporting

Why is it important to understand the difference between Hazard & Risk?

Because lack of understanding = lack of reporting

The important message to get across is that Hazards are normal components of everyday aviation and the need to report is associated with the perceived risk identified by the observer.

So the message is for you as the reporter to report into your system when in your opinion there is an unacceptable level of Risk related to a particular workplace Hazard.

With a deeper understanding comes confidence and with a positive reporting culture a willingness to report.

So let’s consider the following as a basic understanding

Hazard / Risk

A Hazard is anything which has the “potential” (It does not mean it will!) to cause harm to the business whether it is related to the safety of the operation, the safety of the person, or the safety of the balance sheet.

In fact, we are surrounded by hazards.

Even we can say that hazards are a normal component of an operation.

Sometimes there is confusion as we often talk about  – “The Need to Report Hazards”

– In fact, what we actually mean is to report hazards, but only where the Hazard is “perceived” to create an unacceptable level of risk”. (In your opinion)

Risk is related to how likely a “particular hazard” can hurt the business.

– Risk is not real, it is a “tool” to provide a subjective assessment. (conversely, a hazard is off course real!)

As the Reporter, you do not need to measure risk

Use your judgement and if you “feel” that the hazard is “NOT OK” this is enough to warrant a report or feedback through your organisations SMS reporting process.

Risk is in the “eye” of the Beholder – The challenge then is to educate our team to understand the nature of risk related to any perceived hazard and to be willing to report hazards where they feel that the risk for any given situation is not acceptable.

Quality Assurance / Safety Assurance

Quality Assurance is the independent assessment of compliance both externally with regulatory requirements and internally with the organisations’ written process and procedures.

The key element here is “independent”

QA is NOT part of the Production Delivery Process (This in fact is Quality Control (QC).

Safety Assurance is the Assessment of Risk (or Exposure) to a given real or hypothetical situation – For example what is the risk of “Ground Damage to the aircraft”.

To assess the Risk we need to determine the effectiveness of the preventative barriers. – The following are typical examples of Barriers:

• Training,
• Competence,
• Strength of Procedures,
• Effectiveness of oversight and
• Management.

What Safety Assurance is Not

Safety Assurance is not carrying out audits against a “Compliance” checklist – this is in fact Quality Assurance of a Safety Objective (Understanding this difference is a big step in the right direction).

So checking Safety Barriers are in place is QA and determining the likelihood that Barriers may not be in place is Safety Assurance.

Compliance / Performance

Compliance is related to following the rules whether they are “external” rules or our own “internal” rules. Performance on the other hand is asking the question – how well are we doing?

We need to develop organisational tools by which we can measure “Performance“ –  an example would be to develop a range of Key Performance Indicators (KPI’s).

KPI’s could be based on Service Level Agreements (SLA’s) or other agreed measures.

Introducing a Safety Culture which will not work if it is “enforced”, it has to be led from the top and embraced by all otherwise it WILL fall short of expectations.

Develop a willingness to accept a proactive risk identification and safety management culture.

Conclusion – An effective SMS should not be a complicated process, It should be understood by all the team (currently this is not the case – there is work to do) focus on understanding where are the real exposures throughout the organisation.

The Sooner you Start The better! – Consider the 80/20 Rule – 80% of the exposure can be mitigated with 20% of the effort (Do you agree?)

Next Steps

Please see www.sassofia.com & www.sofemaonline.com or email team@sassofia.com for questions, comments or guidance.

Tags:

aviation, Aviation SMS, Compliance, EASA Part 145, Hazard, Key Performance Indicators, Performance, Quality Assurance, Risk, Risk Assessment, Safety Assurance, Safety Management System, SAS blogs, SMS