A review paper by Steven Bentley Managing Director of Sofema Aviation Services.
Many organisations ask for the legal obligations regarding the training of Safety Management Systems, the purpose of this document is to put into context an understanding of the requirement.
Origins of the need for SMS training
In fact the need started to crystallize during the 1980âs when it was understood that organisations as well as individuals often had a degree of culpability in the aftermath of an incident or accident.
The International Civil Aviation Organization, (ICAO) issued a Standard and Recommended Practice (SARP) obliging ICAO (Effectively all United Nations  member states) to implement a State Safety Program (SSP) and to require Operators, Maintainers, Aerodrome Operators and Air Navigation Service Providers to implement a Safety Management System (SMS) within the organization.
The SMS Challenge
An SMS system is a performance related system not a compliance related system, however of course there is a need to comply with the structure and form required to show the SMS is in place.
This makes it particularly hard for the regulator to audit, the compliance element being the easiest element to audit, the performance element being particularly challenging, in respect to acceptable audit criteria.
What this means in practice is that an Organization can have a SMS manual and nominated personnel, It can have various meetings, even it appears to comply with the regulatory obligations, but it is not actually delivering an effective product.
The Organisation should strive to view regulatory compliance as a minimum compliance with the upper limits in fact set by the organisations own willingness to manage its risk and exposure and to develop the most effective organization wide mitigations
Is SMS Mandatory?
ICAO can not mandate a requirement it can only issue a recommendation, however the state has an obligation to comply with UN protocols and obligations,
The FAA has not made SMS mandatory; currently it exists as an advisory circular, (AC) however, should an organization in the aftermath of an incident or accident be found to be deficient in respect of the effectiveness of its SMS the legal damages could be significant.
EASA has made implementation of an SMS mandatory so far, for operators and in the next 12 to 15 months (from September 2013) for MRO and Part M Organisations.
Do Regulatory authorities approve SMS trainings?
No, the Organization is responsible to determine its own training needs based on the obligation of the organization to manage the competence of its personnel, from the Accountable Manager to the shop floor, all need to have an understanding of their individual and joint responsibilities in respect of Safety Management.
Typically the Quality and Safety Managers together with the Accountable Manager will âapproveâ the internal training program, this will also be audited of course by the regulatory authority that will look for an effective process, which is managed and documented.
What will SMS mean for my Company?
SMS is scalable, depending on the size of the company, will provide an indication of how extensive will be the SMS.
The major change with the implementation of the ânewâ proactive SMS is that the responsibility of Safety Management lay not with the Safety Manager but with the various post holders and business area managers.
Are your Post Holders and Business Area Managers fully conversant with the requirements of SMS (if not possibly they require training to refresh and stay current.
How many employees will need training? In a medium size organization there will be a continuous need for SMS training so you may consider it worthwhile to nominate several persons for SMS Train the Trainer Course.
The Role of the Quality and Safety Manager are closely related in a proactive SMS with the need to consider the various obligations to deliver Quality Audits and Safety Audits, to understand the differing roles of Quality Assurance and Safety Assurance, how to Measure Manage and Audit Risk.
A 2 day training is available specifically aimed at the needs and understanding of the Quality and Safety Managers, this training explores all the specific areas of activity related to SMS.
How long does it take to implement SMS?
ICAO recognizes that it can take up to 5 years to implement fully SMS, it is an organizational wide intensive system which implemented correctly reaches into every corner of the organization.
However most Organisations given the appropriate resources can have an SMS up and running within around 15 months, and enough Data to be able to drive a Proactive SMS within 2 years or so
A 3 Day Training is available which will allow your key people and other stakeholders in the SMS system to fully understand the needs for the SMS
As part of the course they will perform a Gap Analysis of the current status of the Organization in respect to SMS conformity.
In addition they will identify an Organisational specific time line for the implementation of the various elements, including an Emergency Response Plan (ERP)
What is the Fundamental Role of the SMS and how does it differ from previous?
The SMS is constructed in such a way that it is able to gather data throughout the organization, This data is then processed in such a way as to understand the various hazards which the organization faces, these hazards are considered in respect of the risk and exposure they pose to the organisation.
In addition the methodology of performing evaluations is of key importance to manage the risks and develop appropriate mitigations.
The previous role of SMS was to react to incidents, accidents and events. Which is why the process is termed reactive, the ânewâ SMS involves going out and âfindingâ potential shortfalls or exposures before they create an incident, therefore to âfixâ the issue before it becomes a problem. In such a way we behave proactively.
A 2 Day training is available which helps to understand the process of gathering data and developing mitigations.
About Sofema Aviation Services
Sofema Aviation Services www.sassofia.com has been supporting the effective implementation of SMS since 2008. If you have any questions please do not hesitate to contact office@sassofia.com
Tags:
aviation safety, Aviation Training, Safety Management System, SMS training
