While the specifics may vary slightly from one organization to another, the core principles of an aviation Safety Management System (SMS) remain consistent. These four components (which in turn are broken down into twelve elements) are listed in ICAO Document 9859 and it is likely that you are already familiar with them, particularly if you have implemented your own SMS by now.
The following article examines how each of these four components should be developing in your organization by asking a number of questions that might be phrased by your NAA inspectors as they seek to determine if your SMS is delivering your stated safety objectives and is improving continuously as part of the Performance Based Oversight objectives discussed in Annex 19, Revision 1.
Policy
- Is your safety policy easily accessible, and is your workforce fully engaged and supportive?
- Do employees understand the importance of hazard identification and safety reporting?
- Is timely and adequate feedback provided to those who report hazards?
These three questions apply across the entire organization and are not confined to Flight Operations. This can only be achieved if management are likewise engaged and empowered to deliver the safety policy. What evidence is available to demonstrate your enterprise approach to safety management? Items such as an increase in voluntary reporting rates for all departments can be used. Furthermore, the establishment of a Just Culture (ASAP in the USA) must be evidenced and must be used by management at all levels.
Risk Management
- Is your safety reporting system user-friendly and easily accessible? Complex systems can deter employees from reporting hazards.
- Are hazard reports acted upon, and is feedback provided to the reporters?
- Are your risk registers up-to-date and accessible to management?
- How do you monitor the effectiveness of risk controls and mitigations?
- Do you have adequate resources to meet the requirements of implemented risk controls?
- Are there processes in place for safety issue risk assessments and management of change?
- Does your risk process consider the broader impact of risks, including financial, reputational, and environmental factors?
- How are risks communicated to the workforce? Are visual tools like Bow Tie diagrams used to simplify understanding?
A primary objective of the risk control process should be to ensure that the appropriate resource is allocated to mitigate identified risks. Ideally, a register of all controls should be maintained alongside the risk register. All identified risks must be accepted by a responsible manager and high-level decisions should be made using risk-based analysis. Finally, there must be suitable processes in place to review and monitor all risks listed in the register as part of the assurance processes.
Assurance
- Are your risk controls implemented and effective?
- Are controls reviewed regularly?
- Is your SMS improving continuously?
- Is your SMS delivering your stated safety objectives?
- Have you agreed to operate to an Acceptable Level of Safety Performance (ALoSP) with your Regulator and can you demonstrate that you are achieving this?
Assurance is a critical component of an SMS. Safety Performance Indicators (SPIs) and Safety Performance Targets (SPTs) are typically used to meet these requirements, as detailed in Document 9859 (Issue 4). Without these, it’s challenging to demonstrate ALoSP and continuous improvement.
Promotion
Unless the safety policy and its objectives are communicated widely and in a format that is designed to engage all employees, it is unlikely to be effective. Poster campaigns can be useful, but short lived. Management must promote the safety policy continuously. This could be in the form of monthly safety newsletters by fleet managers (which could be a leading SPI if used). Again, this process should be adopted across all departments and whilst safety promotion is often very good in the flight operation:
- Is your safety policy communicated effectively across all departments?
- When was the last time the commercial department participated in a risk assessment or safety meeting?
The quotation below is by William Voss (past CEO of the Flight Safety Foundation). It encapsulates how an effective SMS should function and also demonstrates the need for good safety promotion across an organization:
“Go back to last year’s budget and see if you can find one single instance where information from your SMS caused you to spend money differently to how you had planned. If you cannot find an example of that in your operation you either have an extraordinarily brilliant budgeting process or your SMS is not delivering. I would bet on the latter.”
Beyond the Four Pillars of SMS
To ensure that your organization implements an effective safety management system, you need to be able to continuously monitor each aspect of your system and question whether your implemented processes are as effective as they could be.An effective SMS goes beyond these four principles. It encompasses numerous aspects that airlines must consider to ensure safety and compliance.
