‘Tis the Season: The Importance of Assessing Your Safety Program’s Performance

As yet another year draws to a close, we turn our attention to planning for the new year. And to plan is to understand, clearly, where we started from, what is before us, and our ultimate destination or end goal.

This brings to mind a paradox best expressed in the classic New England idiom, “You can’t get there from here.”¹

Around this time of year, most organizations are in the process of strategic and budget planning. Accurately forecasting growth, strategic goals, objectives and performance targets suggests the entity is operating from a place of knowledge and understanding of its operational environment. Without that understanding, the idiom rings true.

And in budget planning, most organizations do not like surprises. It is always best to align program reviews with the budget season, so that any additions or needed resources can be factored into the draft budget based on cost/benefit analysis and need.

Many entities with robust safety and quality management systems (SMS/QMS) factor in the assessment as part of a “Year in Review.” This evaluation aids in determining how each program performed with respect to:

• Meeting company goals and objectives
• Performance of their SMS (such as hazard ID, reporting, risk assessments, management of change, safety meetings, safety training and promotion)
• ERP drills
• Lessons learned
• And the list goes on

These companies also use their quality management system or internal audit/evaluation program (IAP/IEP) to provide a health check on the organization’s performance history relative to regulatory compliance and company policies, procedures and process conformance. This assessment also includes voluntary standards, such as IS-BAO, IS-BAH, ACSF and FSF’s BAR program, each recognized as a standard.

Progressive Assessments Based on Complexity

Performing this health check or diagnostic review enables the organization to look back on prior performance, assess trends and determine the required changes to correct and redirect performance. Some prefer more progressive reviews based on the complexity of their organization’s operations, fleet mix and the degree of change taking place within the organization. Safety and quality performance take on a much more dynamic role and are actively reviewed on a more aggressive cadence.

The diagnostic should not be performed in a vacuum, meaning it should not be conducted solely by the person responsible for administering the safety program, but rather in a group setting with stakeholders from all departments. In this way, stakeholders can share insights and feedback from their respective departments and shed light on opportunities for refinement.

It also serves as a great platform to evaluate and refine the organization’s strategic vision with respect to safety risk management, such as:

• Review of safety data and trends
• Key incidents, root cause and corrective action reviews
• The effectiveness of compliance and conformance monitoring systems
• Documentation and guidance relevance
• Safety training effectiveness
• Emergency and business continuity readiness
• Availability of suitable resources
• Evaluation of the goals, objectives and performance targets to further affect change

Once this review is completed, it can be shared with the accountable executive (AE) as the “Year in Review” to raise awareness of resource needs (e.g., more training budget, additional auditors, etc.) and to outline program refinements, such as refreshing the safety policy.

Ensuring that your quality program (internal audit/evaluation) is effectively focused requires a thoughtful assessment of the standards or requirements and the level of granularity you should use to assess them. Taking too high an orbit will obscure your view of actual performance on the flight deck or shop floor. This is why the annual assessment of processes is so critical to the overall functionality of your SMS/QMS programs yet is often overlooked by executive leadership due to a lack of awareness. Or in some cases, there is an assumption that tasks are being performed.

For those Part 135 and 121 Operators, these SMS performance assessment elements are pre-programmed, as stakeholder briefings and meetings are routinely scheduled to coincide with your briefing to the AE and senior leadership team. In fact, many C-suite leaders proactively seek information on historical and emerging risk. Providing a thoughtful, comprehensive and factually correct assessment is a fundamental element of any advanced SMS/QMS. Providing this information, face-to-face, to the AE and senior leadership not only puts safety performance in the open but also demonstrates the importance of these programs to the enterprise’s overall health.

14 CFR Part 5 Awareness

For Organizations that do not have an annual program review built into the calendar may be missing an opportunity to conduct a reality check of a program’s actual level of implementation within all functional areas. For those entities required to meet Part 5, your AE should be aware of these requirements (14 CFR Part 5: §5.23, §5.25, §5.73, and §5.75). It is here that an enlightened safety manager may take advantage of this opportunity to not only present the annual SMS performance to the AE but also use it as a “training event” to raise the AE’s awareness of their accountabilities and responsibilities, as they are peppered throughout Part 5. Failure to do so puts the AE’s position at risk should an event pierce the veil of corporate governance.

For a safety and quality program to flourish, information gathering, analysis and distribution (sharing) are critical to each system and, ultimately, to the organization’s success in achieving its goals, objectives and performance targets. Without these actions, “You can’t get there from here.”

References
¹ Bert and I, Marshall Dodge and Robert Bryan