Sustaining Your Safety Management System

Recently, FAA Administrator Randy Babbitt stated: “The cost of SMS is far less than the cost of an accident.” Saying that you don’t have time for SMS is the functional equivalent of saying that you don’t have time for safety. Babbitt characterized SMS thus: “You identify the problem, you analyze it, you come up with a solution, you train to the solution and then you check how you’re doing. [It’s] a safety feedback loop.”

Building a Safety Management System (SMS) typically takes significant effort by your flight organization’s staff. After thoroughly going through the development of your Flight Operations Manuals, Emergency Response Plan and creating a means of collecting, analyzing and disseminating your safety information, a flight organization team often feels as if they “have arrived”.

However, your journey has just begun. After putting the SMS infrastructure together, the organization then moves into a learning phase. Very similar to a pilot obtaining their private pilot certificate, you now have a license to learn and gain experience for your organization. An SMS follows a similar path.

Many organizations fall short as their next audit comes around. IS -BAO Phase I looks primarily at your SMS infrastructure, but as you move towards Phase II, performance is what counts. Some of the issues we hear most from auditors and companies in regards to sustaining SMS are:

Keeping documents current – After your first audit, did your documents go on the shelf with little or no updates? The Operations manual is your primary risk mitigation tool and must be reviewed and updated frequently to assure that risk exposures are addressed. It sets the standard, mitigates risks and clearly defines the expectations for the entire aviation staff. Aviation is ever changing and to keep your documents up to date can be challenging. looking at changes in standards ( “http://www.ibac.org/isbao.php“IS-BAO, “http://www.acsf.aero/” ACSF, etc.), best practices, regulatory changes, and, in particular, changes going on in your organization? How often is your staff referring to the documents in everyday operation?

Collecting and analyzing safety data and reporting on the results – What data are you collecting? Hazard Reports, Risk Assessments, Change Management and deviations from policy are a few of the critical data points that ALL of the aviation staff must contribute to on a daily basis. Documenting and establishing a workflow to collect and analyze this information with the capability to report on the results takes some effort and may be problematic if a workable system is not established early on.

Internal Audits – How often are you comparing your flight organization to the standards that have been set in place? By regularly completing internal audits, flight organizations can monitor their compliance to the standards they have set.

It takes leadership to encourage a total commitment from your staff. Each individual must be encouraged to have a personal commitment to contribute to a successful Safety Management System and their job descriptions may even state in no uncertain term that they do so. An everyday example is those pesky potholes in the road. When was the last time you reported one to your local DOT? You can relate this to your flight operation – everything must be looked at and, rather than ignoring a situation. Remember to look for all those potholes with your SMS. Stay focused on the little things so that nothing big happens.

What should you be doing to keep your SMS alive? How? Keep it simple and appropriate for your organization. Be sure your documentation is updated as appropriate, exercise the Emergency Response Plan and be sure your system of collecting and reporting safety data is functioning.

The easier the SMS system is to use, the greater the chance everyone will participate. We find the easier it is to collect and submit safety information, the more you will be able to collect. Typically paper based workflow will require handling, sorting and shuffling that will require additional limited resources. Use of an appropriate technology solution can make the reporting functionality much easier for everyone and especially your safety advisor and safety team as well. The data you collect will point you in the right direction and will enable you to identify those hazards that may bite you if you do nothing about them. You will be surprised what you find out about your operation and the risk exposures that are looming out there.