Discussion Paper by Sofema Aviation Services (www.sassofia.com)
Introduction
There are many misconceptions and misunderstandings regarding aviation Safety Management Systems (SMS) and Quality Management Systems (QMS).
The following is intended to hopefully clear up this misunderstanding:
a) QMS and SMS – Offers many common methods and techniques, but provides different outcomes and objectives;
b) Sufficient competent resources are critical to the success of both the CM system and the SMS;
c) In essence, Quality Assurance is determining gaps based on non-compliance with either the regulatory requirements or organizational requirements;
d) Safety Assurance is looking at weakness in the organisational system which raises the exposure to risk;
e) Safety Assurance is a forward-looking process and Quality Assurance is a reward looking process.
Quality is essentially looking at compliance, and Safety is looking at Risk.
*Note: It is also important to realise that essentially the role of both QMS and SMS is to provide a service to the management team to understand both the non-conformities and risks which they face within the business areas.
QMS Objective is Compliance Focused – EASA Quality systems are focused on demonstrating continuous compliance (quite different in fact from the goals and objectives of the ISO audit system which focuses on continuous improvement).
Where is the Challenge of Auditing Aviation Safety Management Systems?
The Challenge is how to audit the SMS System – which of course is part of the compliance obligations of the QMS.
Why?
Simply because SMS is a Performance-Based System and it is not effective to validate such a system using compliance techniques alone.
Sure the basic audit can look at compliance factors – however additional questions need to be asked which will demonstrate that the SMS is achieving its objectives.
Consider the Following as SMS Background Understanding:
a) A high level of Competence is required within the SMS related to the challenging area of Hazard Identification, Safety Risk Analysis, System Evaluation, and Mitigation Proposal.
b) SMS applies a systematic approach to organisational safety and promotes a formal and structured approach to dealing with risk and exposure across the business.
c) Safety Management Systems should focus extensively on the analysis of the data derived from the contributing elements of the various impacted areas.
d) The Safety Management System identifies as an essential goal the improvement of the Safety Performance. In doing so the SMS aims to deliver an improvement in the risk exposure.
So to Consider the Practicalities of a Quality Audit of the Safety Management System
Regarding the Compliance Elements of an SMS
Regarding the basic functionality, let’s call it the compliance elements the SMS audit is straight forward and we look at the usual areas of:
a) Management
b) Training
c) Documentation
d) Communication
e) Marketing
f) Process & Procedures
So for the above elements, we are in familiar water and can audit in the normal way.
– What should happen?
– Is it happening as documented/stated?
If yes good & If not then we have the basis of a finding!
Regarding the Performance Elements of SMS Audit
Essentially to audit a “performance system” use an auditing technique which relates to performance questions.
1/ How are you measuring the effectiveness of your SMS system?
2/ Is the “measurement” process working ? (How can this be demonstrated?)
3/ Is “Data” being collected from “All” business areas?
4/ Is the Data sufficient? (means are all exposures – or enough to demonstrate an effective process delivery being captured)
5/ Is the Safety Review driven by Change Management visible & viable
6/ Do the front-line employees identify with the SMS – how is this evidenced?
7/ Does Senior Management Identify with the SMS – how is this evidenced?
Auditing the Management of Change Process for Effectiveness
Multiple changes WILL occur within the aviation system, both internal and external including regulatory changes, management changes, equipment changes, changes in procedures process or manning levels.
A change management process should be a documented strategy to proactively identify and manage the safety risks that can accompany change, whilst it is focused on significant change, in fact, any change may have a “knock-on” or trickle-down effect.
An effective process will assess in fact all change. Changes may impact existing mitigations or introduce new risks and exposures and it is necessary to have a formal process to assess and measure the impact.
This process requires the full force of the SMS Hazard and Risk Assessment Process which requires that any perceived safety risks connected to the consequences of hazards to be analysed, developed, implemented and subsequently evaluated and measured for effectiveness.
Whenever we are assessing the risk or effectiveness of a process against expectations (not a standard but a subjective expectation), then we are in the domain of Safety Auditing.
The Change Management Process should ensure that any hazards associated with the change are formally and systematically identified and managed and that a formal process exists to ensure the management of the change is continually evaluated and monitored.
The competence of the persons involved in the evaluation process is highly critical to the effectiveness of the process. Consideration should be given to ensure that stakeholders from all departments affected in the change have direct input into the evaluation process. In any event, a formal competence management process is expected.
Safety Assurance should ensure that throughout the lifecycle of the change, management is presented with feedback regarding the effectiveness of the implemented processes as well as the overall health of the system.
Consider the effectiveness of the various mechanisms which exist in your Change Management System.
How are you able to measure these elements? (essentially to consider that to achieve the maximum effectiveness then we should be able to demonstrate a measure against which we can assess each and every element.)
Please see the following link https://sassofia.com/aviation-quality/
For additional information please see www.sassofia.com or email office@sassofia.com
Tags:
Aviation Quality Audit, EASA, Quality Management System, Safety Management System, SMS
