According to International Civil Aviation Organization (ICAO), a safety management system (SMS) is: “… a toolbox that contains the tools that an aviation organization needs in order to be able to control the safety risks of the consequences of the hazards it must face during the delivery of the services for which the organization is in business.” (ICAO, 2009 p.7-1)
ICAO goes on further to state that, “It is important to acknowledge that an SMS itself is neither a tool nor a process.” (ICAO, 2009 p.7-1) Having determined that you are part of the aviation organization — are you part of the toolbox? The simple answer is — yes!
Imminent FAA mandate for SMS — “We can’t afford it right now!”
The FAA regulations on the requirements for aviation SMS are not yet set, but they are fast approaching with the March 2011 extended deadline for comments on the related NPRM. Are you and your organization going to be ready for it? The first step is to understand what it is and what it is not.
First and foremost, a SMS is a companywide enterprise that includes all departments working together to achieve the same safety and quality goals and objectives. The approach may be different between departments as to how this is done, but the aim is to achieve the same goals of safer and more profitable operations throughout the organization.
As is standard for the FAA, it has provided the areas that must be encompassed by a SMS, but it does not prescribe how to implement it in your own organization. Of course, the implementation is the most difficult part. Without the FAA mandate in place for this implementation, current traction and momentum of several SMS in the aviation industry have either faltered or been put on the back burner. Industry downturn has impacted the SMS implementation in all aviation spheres. This is especially true for many fledgling SMS that were being planned in the maintenance field. Nevertheless, this is a very shortsighted perspective on the return on investment that a SMS can provide for the company as a whole.
Some in the aviation industry believe they cannot afford to implement a SMS at this time. However, if questioned more closely, there is no “good” time to do it. Many smaller operators, such as in general aviation, repair stations, and corporate aviation operators, can barely see their way clear to making a profit, so a new regulatory decree right now is not being readily accepted. Some larger operators are dragging their feet as well. How can placing another obviously onerous requirement on the industry at this time possibly be advantageous to business? Here’s how.
Benefits of a SMS
If the SMS is implemented correctly, with the right level of commitment from all personnel, along with the framework and policies to support it, we in the industry will benefit personally from it as well as our passengers, clients, and consequently our companies. Doesn’t that make business sense? There are other benefits that can also be realized that enhance profitability.
The decrease in insurance claims from less accidents and injuries leads to decreased premiums. The implementation of an effective SMS is a good marketing tool for retaining as well as gaining new clients. This more congruent work environment can also bring into the organization greater human talent as well as retain those already in place. It provides a better work environment due to increased communication between departments, better understanding of each other department’s expectations, and a generally more transparent organization. This can have many other financial benefits such as:
• increased employee morale
• greater job satisfaction
• better retention rates
• retaining greater corporate knowledge
• improved labor relations
• greater organizational ability to adapt to changing markets (due to more people communicating and knowing what is going on)
• providing a data-driven, systemic approach to managing safety (as there are hazard/incident reports reported by front line employees and these are assessed for their potential impact)
The timing for the ICAO ruling on the need for a SMS and the upcoming FAA mandate may not suit the U.S. aviation industry at this point in time. Although upon reflection — when would it? Does change ever occur at a time when we are quite comfortable and ready for it? Not usually.
Other ICAO signatory states such as Canada, Australia, and New Zealand, have fully operational SMS in place and have had for some years. They now have some evidence that they are producing results (CASA, 2009). With this in mind, how long can we resist the necessity of change in safety management in our industry’s own business practices?
As this change is inevitable — and it is normal human nature to find change threatening and therefore resist it — we need to understand why we should not only adopt a SMS, but why we should embrace it and move to adopt it sooner rather than later. It is a different way of doing business than what we are currently used to — and we have heard this before too! However, even with all these possible benefits, why do some people still not want to adopt a SMS? First, let’s look at why we feel uncomfortable with the looming SMS mandate.
Another change going … where?
There is much talk about the SMS mandate being a way for the National Aviation Authority — in our case the FAA — to avoid its safety inspection responsibilities and place the responsibility of regulation onto the aviation entities themselves. It is often seen as a form of self-regulation that frees the regulator from the role of oversight. This is not the intent of a SMS. Does it produce this as a spin off? Bluntly put — to a point — yes it does. However, it does not cease the required regulatory oversight or absolve the regulator of its legal responsibility to maintain its ongoing role as the safety oversight body within our industry. Conversely it does not allow the organization to set its own safety levels.
More work for me!
With an integrated and appropriately functioning SMS there are several types of safety and quality assurance mechanisms and measures that will still be in place to ensure the organization is checking its own backyard for the identification of inadequacies, gaps, and its own oversights. These internal risk assessment tools and audits for both safety and quality within the organization have to be systematically managed and applied and conducted by all employees throughout the organization — not just the “auditors” or “safety people.”
Every person in the organization is a tool in the SMS toolbox. So what other “tools” do we need for a successful SMS? Now that we know why we should adopt a SMS, we need to know what the “tools” in this toolbox are, and how do we go about implementing them. The second segment of this article will address these aspects.
Part 2: What should be in the toolbox?
Majella McDonald is a human factors expert with more than 20 years of professional experience in the aviation and health industries, in areas of SMS, human factors, accident investigation, and change management planning/ implementation. She currently works as a consultant for Baines Simmons Americas and teaches for Embry-Riddle Aeronautical University (ERAU).