Changing the Safety Mindset

ORLANDO – As airports and FAA begin to get their arms around the concept of a safety management system, the National Air Transportation Association has taken the lead in bringing SMS to airport-based
businesses. In late March, NATA held another of its Safety 1st
management system workshops, which incorporate risk management and safety as core values. Since its inception, the Safety 1st SMS
program has been a living document that has evolved with new regulations and user feedback. Not only can the NATA SMS program assist a company in enhancing its safety initiative, but with FAA’s insistence that it will comply with ICAO Annex 6 by January 2009, it could soon become mandatory.

NATA defines SMS as “a systematic, comprehensive program for the management of safety risks. The program integrates operations and technical systems with financial and human resource management for all activities related to aircraft ground operations.”

Further, NATA states that “for the first time aviation business will be able to measure safety and monitor improvements. SMS is a data driven, business approach to safety management.”

Taking a ‘work in progress’ approach to SMS helps the program evolve as needed in terms of a company’s particular safety needs as well as heeding the FAA’s call for safety management programs, says NATA. “When we wrote [the SMS], we knew there would be several renditions of it,” says Amy Koranda, NATA director of safety management.

SMS contains many documents that can be instrumental in establishing a company’s safety management system. If there’s an area that is particularly lacking, NATA asks users what they can be doing better. They can add or subtract parts of the program as they see necessary.

Gap analysis

One of the key additions to the system has been the gap analysis survey. Currently consisting of 54 questions, the gap analysis survey asks safety managers to answer questions regarding a company’s current safety policies and to classify each risk category in terms of importance. For example, what are the immediate implications if the risk category is not included in the current safety program? Could non-compliance result in injury or death?

The survey helps a safety manager plan future initiatives by requiring a set target date for completing the corrective action and also indicating where — when completed — the written documentation will be located for future reference.

One feature that users have found particularly helpful is a reference guide to FAA Advisory Circular (AC) 120-92. The survey has a column for identifying which section of the FAA A.C. they are satisfying with the successful completion of each question. [Question 1: Is there a policy statement by top management that defines the safety goals of the company? Successful completion of this question in part satisfies section 4.2A of the Advisory Circular.]

Value to Part 135s

According to Russ Lawton, NATA director of safety and security, it’s beneficial for charter companies to start their SMS programs now, because FAA is eventually going to make it a requirement for all Part 135 operators. “The FAA said that they will comply with ICAO Annex 6 by January 2009,” Lawton says. “By people signing up with an SMS effort now, they will get out ahead of the curve. So when it becomes mandated by the FAA, they’ll already be working on it or have it in place.”

Comments NATA’s Koranda, “I was at the AEA [Aircraft Electronics Association] conference presenting the business side of SMS and the gentleman who got up to speak from the FAA said that we have a regulatory responsibility to mandate this by January 2009.”

Lawton suggests that the industry could see a Notice of Proposed Rulemaking (NPRM) as soon as early 2008 that will make it mandatory for anyone who holds an operator certificate. “I would suspect that in 2008 we would see an NPRM that would make it a requirement,” Lawton says. “What kind of a period it would be, I don’t know. Whether to have it implemented by 2010 or what, that is kind of being debated by FAA now.”

Critical to a program’s success, says Lawton, is for a high-ranking manager to be accountable for the company’s SMS. “The company safety culture has to come from the top down. It’s not a bottom up kind of effort; if the upper management of a company doesn’t support it then it won’t work well at all.”

Groundside, airside

There is both a groundside and airside operations SMS. NATA had been working on the groundside SMS for almost a year, before beginning work on the airside. The association worked with airport consulting firm SH&E to create the original SMS.

“The insurance companies were very instrumental in saying that this is a program long overdue,” explains Koranda. “They recognized NATA’s success in training and thought to develop this further.”

Development of the initial SMS was sponsored by five oil companies and five insurance companies. “[The sponsors] were willing to step up to the plate for one year and entertain up to three years, and they’ve been true to their word. They have sponsored the first three years and [now] we’re going to try on go it on our own,” Koranda says.

Reducing exposure

According to NATA’s Lawton, depending on the profit margin of the company, the annual cost of events (damage to aircraft) is not a static number based on the amount directly associated with the event’s repair. Thus, implementing an SMS program can have a significant financial impact on a company.

For example, he says, if a company’s annual incident costs are, say, $100,000, a company may need to make as much as $2 million the following year to recoup those losses.

“Everyone thinks it’s a one to one cost,” Lawton says. “What does that really mean in terms of the amount of business you lost and what did you really lose over and above that $100,000? It’s an exponential factor.

“If you look at the dollars and cents of it, the money you’re going to spend on implementing the SMS and having a strong safety program is going to save you more than the cost of a repair bill,” Lawton says. “Any little incident that can be prevented by having a proactive safety program in risk management is going to go directly to the bottom line.” Reducing losses can also help reduce insurance premiums, he says.

Audit checklists

NATA’s SMS program dedicates a section to OSHA audit checklists specifically for areas applicable to the industry. The checklists range from respiratory protection to personal protective equipment, and offer a description of compliant or acceptable working conditions.

The process leads safety managers to scrutinize possible areas for improvement — those which may have been neglected or overlooked in the past.
It was during the OSHA audit process that one participant, Dawn Letellier, director of safety and security with Encore FBO [the former Business Aviation Services], recognized an area requiring improvement.

“The first time that I was conducting my own location’s audit based on that checklist, we got to the [hearing protection] part and realized that we had never done this before. It was clear that it was something that we needed to initiate,” Letellier says. “I worked with our insurance company and had them come and do the decibel sampling to see if the noise levels were over the OSHA guidelines, and we found one area [maintenance] of our company was affected.”

Participant reactions

Letellier of Encore, who is based in Sioux Falls, SD was the first user of the Safety 1st SMS, beginning in April 2005. She says she completed instituting the program over a nine-month period.

“[The SMS] really helps your company define its whole philosophy on safety and security,” Letellier says. “One of the benefits that I saw when I first started this was in going out and talking to employees, conducting job hazard analyses, and working with the front line. The employees really appreciate the company focusing on safety; you get more buy-in.”

According to Letellier, in the first full year that the company had the SMS program in place, the FBO had zero deductible claims, its rate for employee injuries improved, and the company saw a 36-percent decrease in ‘hangar rash’ incidents.

Letellier was able to fast track the new safety initiative because her company already had a few components in place, such as a safety committee. She says that NATA’s twelve-month timetable is realistic, depending on how big the company is and the resources that are available to the safety manager.

After participating in the workshop in Orlando, Million Air Cleveland’s operations manager James Price says he realized that he had to start from scratch. “It made me realize that I had really let a couple things lapse,” Price says of the company’s current safety initiatives. “[Now] I’m rewriting job descriptions; I have to select the safety committee; and the owner and I are still working on writing the manual. I think once we get everything written and in place, it will just be a natural flow of things.” Price says that in being part of a smaller operation [20 employees], “the only delay is trying to find the time to sit down and compose it all.”

On the topic of selecting an internal safety committee, Price says, “I think that [the safety committee] is the crucial link that will tie everything together and get everyone involved. We certainly won’t be the record breakers in getting [SMS] implemented, but I want to do it right.”