How dependent is an EASA or GCAA compliant organization on the effectiveness of the Safety Management System (SMS) Manager? Immeasurably is the simple answer, with the changes in organizational thinking driven by ICAO and others which we have seen introduced over the last decade or so, leading to the more or less de facto acceptance of the organization’s core role as being pivotal in the delivery of an effective Safety Management System (SMS) as a top down system.
When we examine in detail the role of the Safety Manager we may appreciate there is a significant difference in being corporately responsible for a role and a nominated person being equipped to deliver the role, this is where the competence of the safety manager becomes paramount, and where in many companies there is a fundamental shortfall which creates a catch 22 situation.
The organization is in fact reliant on the person who should identify the GAP’s within the organization Safety Management System, however sometimes due to issues of competency they are not able to either identify the issues or get the message to the people who need to hear it. (or both).
Sometimes it seems as if the Safety Manager is simply a passenger on the company train and every time either the train stops or someone operates the emergency alarm he tries ( sometimes successfully but often unsuccessfully to deal with the issues as presented)
But this is only one part of the message of missed opportunities, because if we embrace improvements designed to optimize the effectiveness of the organizational processes, driven by the data gathered from within the SMS system we can usually see real and tangible benefits related to performance as well as risk reduction strategies.
So a weak Safety Management Role in fact inadvertently may miss many of the opportunities and effectively serves to minimize or limit the possible upside.
Therefore this inability to represent effectively the role of Safety Manager (SM) within the organization becomes the new challenge. How to break this disconnect so that the organization assumes a positive direction ?
It is my contention that the way forward is dependent on the active participation of the Regulator in order to reset any organizational disconnect – read on !
Consider company “A” a small airline operating a mixed fleet of Medium Size Passenger Jets and Short Haul Propeller Aircraft. The Safety Manager (SM) is an experienced Pilot but his flying duties mean that he has limited time to do enough to adequate support the SMS role.
The SMS system in this company is simply not functioning by any measure of effectiveness it is not gathering data in the way it needs, to, in fact it is fair to say that proactive risk assessment does not really exist in any meaningful way within the organization, for his part the SM tries very hard to do everything which needs to be done ( He is a knowledgeable and competent pilot) but is he competent as a SM?
Lets consider for a minute what we mean by competence – that the person has the necessary skills knowledge, process and procedures required and understanding necessary to perform the role which is required. If the person is missing an element of competence it is not a criticism rather an understanding of a “training need”
Now consider what we want our SM to do for us:
a) facilitate hazard identification, risk analysis and management;
b) monitor the implementation of the safety action plan ;
c) provide periodic reports on safety performance;
d) ensure maintenance of safety management documentation;
e) ensure that there is safety management training available and that it meets acceptable standards
f) provide advice on safety matters; and
g) initiate and participate in internal occurrence / accident investigations
When we consider the job role of the SM are we talking about Compliance or Risk?
In fact in each of the above items we are talking about Compliance, means that we can in fact assess it in a prescriptive way , to measure it for acceptability not just from the organizational viewpoint but from an external point of view whether it is a regulatory or industry driven assessment.
From an auditors perspective to assess an element we first need to consider what is the standard, next to look at the evidence, means what do we actually see, then we can ask the question is it meeting the objective as stated, means is it fit for purpose?
So for the above elements we could ask the following questions:
a) facilitate hazard identification, risk analysis and management;
1/ How does the SM Facilitate hazard Identification Risk Analysis and Management ? Have the organizational objectives been transferred to a working action and implementation plan
2/ Has an assessment been made of the man hours necessary to perform the activities required to meet the objectives ? Does he have the necessary facilities and manpower to achieve it ?
3/ Is there a risk register ? How is it managed and how is it communicated to the management team ?
4/ Is there a documented procedure to assesses manage and mitigate risk which has been shown to work ? view the evidence and ask to witness the process ? How many assessments take place ? When do they take place ? Who is involved ? (has each person who is involved received appropriate training) What is appropriate training for risk assessors – view the training program and ask how it is measured for effectiveness.
5/ How are we identifying hazards within the organization – means how many activities are actually taking place Safety Auditing ? Safety Assessments view the evidence for Proactive Safety activities if it is happening there will be multiple evidences
6/ What training is taking place to identify hazards – how are we communicating to the employees our expectation and how they can support the objectives
7/ Where is the SMS Proactive Data acquisition plan for the coming year ? what does the organization plan to achieve.
b) Monitor the implementation of the safety action plan ;
1/ Where is the safety action plan document ?
2/ Where are we in respect of this plan ?
3/ Remember the need for continuous improvement what was achieved last year – evidence, what is scheduled for this year and finally what will it look like next year – review for effectiveness
c) Provide periodic reports on safety performance;
1/ What do we mean by periodic reports ? monthly or quarterly ? ( the organization should decide)
2/ In any event to be effective the reports should be meaningful substantive and have content which is business wide in origin.
3/ Who is in receipt of this information – in fact all Post Holders, Stake Holders and Business Area Owners should be in continuous receipt of information relevant to their business area.
d) Ensure maintenance of safety management documentation;
1/ What is the current revision status of the documentation ?
2/ When was it last updated ?
3/ How is the contents assessed for suitability and validity when will it likely be updated in future light of lessons which are learned.
e) Ensure that there is safety management training available and that it meets acceptable standards
1/ What is the current revision status of the Training Documentation ? (how is it kept current and relevant – responsible person and evidence)
2/ Are there separate Role Specific SMS Training programs available for each group of staff ? and how the training program contents is assessed for suitability and validity for each group
3/ Who delivers the training and how is the training standard measured ? consider Instructor competence.
f) Provide advice on Safety Matters
1/ What evidence is available to support the provision of advice and guidance from the Safety .
2/ What communication channels and process are used by the Safety System to communicate with the management and staff
g) Initiate and Participate in Internal Occurrence and Accident Investigations
1/ What evidence is available to support the management of investigations in particular to focus on proactive investigations driven by safety assessments
2/ Consider the amount of report data arriving in the SMS system also consider that the ratio of events to potential lapses is 30 to 1, so to see how many voluntary reports have been raised over the last 12 months and to compare with the mandatory reports.
Sofema Aviation Services offers multiple Safety Management System training courses to suit different organizational objectives. Please see www.sasssofia.com or email office@sasssofia.com
