Management of Change (MoC): A Collaborative Approach To Raising Awareness Amidst a Constant State of Change

Identifying and managing hazards affecting an operation’s integrity is a fundamental objective of all flight departments or organizations working within a risk-based environment. In aviation, more and more operators are coming to the conclusion, and rightly so, that mere regulatory compliance is not an assurance of operational integrity and safety.

Regulations are the lowest common denominator to assure compliance to standards designed to provide a foundation for operational stability and attention to some of the most basic, fundamental risks within aviation. The question should always be, “What more can we achieve over and above regulation to further minimize risk and continually improve our safety standards?”

The Reality of Regulations
While regulatory standards do ostensibly address the typical risks within aviation, many variables and external influencers emerge within the dynamic aviation marketplace that are not promptly addressed by regulations. History has demonstrated that regulation enhancements move at a much slower pace, as regulators and the Notice of Proposed Rulemaking (NPRM) process attempt to catch up to actual operations and events.

We see the FAA’s NPRM process in play with proposed enhancements to 14 CFR Part 5 to include some Part 21 type certificate and production certificate holders, Part 135 charter operators and air tour operations conducted under Part 91.147.

Similarly, the FAA has released a final rule on airport SMS, building off its SMS pilot. What’s important to note is that change is coming, and coordination and collaboration between systems (regulators, airports, operators, etc.) will be critical to ensure they align.

Managing Change Effectively
As discussed in recent SM4 articles, the need to review and enhance an operator’s Emergency Response Plan (ERP) is just one of many changes operators will have to embrace. This article is provided to help focus operators on the need for an effective overall management of change (MoC) process.

Most operators that have embraced the concept of SMS through initiatives such as the International Business Aviation Council’s (IBAC’s) IS-BAO and IS-BAH demonstrate awareness of risks that contribute to the aviation department’s or FBO’s overall performance. The regulations provide a prescriptive regulatory baseline that most operators can easily achieve.

Like checklists and SOPs, which we expect every pilot, mechanic and line service technician to follow, organizational and individual cultures and behaviors may alter commonly held expectations.

The most fundamental question one should ask of its corporate management system is, Has anything changed or will anything soon change that we haven’t effectively accounted for and risk assessed?” Such changes include regulations, company leadership, senior or functional management, facilities, equipment, and processes, to name the most basic group.

Experience has shown that many organizations believe their programs address this question, but few can provide the independent assurance to validate their perceptions.

The Need for Independent, Performance-Based Assessments
Even the most mature, stable, evolved organizations experience disruptions from time to time. This can be due to acquisitions, mergers, consolidations, , business unit shutdowns, new facilities, equipment, and changes in staff. Focusing on staff positions for the moment raises the additional question, “Do job descriptions actually reflect what the employee is responsible for?”

Performing routine, independent, performance-based assessments helps raise the level of organizational awareness and attention to the emerging regulations, threats and cultural biases impacting compliance and conformance. If performed properly, these assessments enable an organization to communicate what is important, throwing a wide net beyond the regulations and pulling in real-time operational data.

Even in an organization with a mature SMS, it is probable that the development of a safety risk profile for any specific change may be biased by the paradigm within which the organization’s people operate. The concern here is that a single person or small group performs the risk assessment.

From these observations, two logical points in the change management process exist that an advanced focus can provide.

The first involves developing the risk profile for a specific change, such as:

• A new aircraft type
• A new airport program (such as an SMS)
• Changes to critical staff
• New ground support equipment
• An amended process for evaluating a new external vendor

A more focused examination of all contributing factors and potential impacts (training, documentation, SOPs, forms, checklists and recordkeeping) can provide a fresh perspective on the proposed change’s influence on the organization. This perspective offers the ability to plan and budget more effectively, in addition to validating or disproving the assumptions that drove the risk assessment process.

Secondly, and equally important, when conducting a post-implementation review of the specific change or new process, a collaborative effort can help uncover any unintended consequences that might otherwise go unnoticed by those too close to the implementation process.

It’s basic risk management and as simple as taking a closer, collaborative look.