Steven Bentley MD of Sofema Aviation Services offers the following viewpoint for consideration.
A strong statement but is it fair?
We all accept that SMS is a performance based rather than compliance based system – the problem is that the regulator does not ask the “right” questions. Simply you cannot audit a performance system with compliance “checklist driven questions” but unfortunately this is what is tending to happen
Reality Check
To be effective SMS has to be top down and the very top is the national State Safety Program – the question is how is the SSP driving the SMS. Means how does the state oversight mechanism deliver an affective performance oversight of the various industry SMS programs?
Consider that with appropriate direction and guidance developments can proceed in a more structured and measured way.
Consider:
a) EASA Regulatory approvals once issue do not expire
b) Under EASA Rules the organisation is responsible to manage its own approval in the most effective way
c) The Organisations Quality System delivers an Independent assessment of both regulatory compliance and compliance with the organisations process and procedures. Any discrepancies identified are issued as “findings” (corrective action required)
d) The organisations Safety Manager is responsible to provide a “service” to the management team to ensure that all hazards are identified, associated risks are understood, where relevant and after appropriate analysis mitigations are proposed for the attention of the business area owners.
So we are now understanding that the organisation should identify its own shortfalls and document and present in written form for the senior management team and accountable manager – Is this happening ? The answer unfortunately is not the way it should!
OK, so where are the problems?
The first problem is the manpower commitment required to deliver an effective SMS
Core Activities of the SMS Manager are typically –
1/ Developing & Managing SMS Documentation
2/ Developing SMS Training / Delivering Training & Measuring Training Effectiveness. Please also consider that training is not a one size fits all! (means the SMS training for the accountable manager is not the same training required by a shop floor worker or a pilot or a member of the Safety Action Group) Typically there are between 6 & 8 relevant training courses needed to effectively cover an operation.
3/ Managing and Maintaining the Hazard Log
4/ Responsibility of the Emergency Response Plan – Managing, Maintaining, Updating, Training & Testing.
5/ Safety Auditing, & Safety Assessment
6/ Managing & Leading Risk Analysis & Developing Mitigation Proposal
The above list is by no means all inclusive and simple serves to illustrate it is more than a simple part time task.
However small to medium operators employ a serving pilot as the Safety Manager – means as well as the normal duties (by the way can you keep an eye on items 1 to 6 above! – Clearly it is not serious and can only be justified where the serving pilot is the safety team leader and has typically flight Safety Officer/ Ground Safety Officer / Maintenance Safety Officer plus “sufficient” (note sufficient is a favourite EASA word!
Q: How should the regulator fix this issue – Manpower
A: Not be auditing compliance but by auditing performance
Ask this question
How have you evaluated the manpower requirements to support all the above 1 to 6 elements? This is a piece of work which should be evident so ask for it!
If it does not exist it is a finding – “the operator was not able to demonstrate appropriate analysis of the manpower requirement to deliver the required Safety Management System”
Hazard and Risk Log
The author recently visited a company with 3000 employees and after 6 months of work the safety officer had considered 5% of the estimated Hazard and Risk Log ( HAZLOG) workload – Means a 10 year project (again not serious)
Q: How should the regulator fix this issue – Hazard and Risk Log?
A: Not be auditing compliance but by auditing performance
Ask these Questions
- Have you identified the Risk and Hazards which face your business ?
- How many Hazards where considered ?
- Are you satisfied this represents the “significant” exposures
- Who has performed the analysis
- How have you assessed the competence of the Assessors?
Note these are Performance questions means unlike Compliance auditing it is not a right or wrong answer rather the answer is assessed subjectively relevant to the organisations needs consider the term As low as reasonably practicable (ALARP).
With a strong regulatory driven “push” in the right direction the business leaders will hopefully appreciate both the positive attributes of an effective SMS and find that by fully embracing across the business can indeed lead to additional efficiencies with cost benefits.
About Sofema Aviation Services
SAS offers more than 30 different Safety Management System Courses. It is our firm believe that correctly implemented, SMS provides a significant tool, as well as delivering safety as a prime consideration, to optimise business practice and process with significant organisation benefit.
Over the last 8 years Sofema Aviation Services has delivered regulatory training to more than 10,000 delegates. With 45 years of commercial aviation experience behind our training program, our focus is on delivering real and connected regulatory compliant training which promotes a strong understanding of the options for safe and effective optimization of the organisation. Please see www.sassofia.com or email office@sassofia.com
