Sunday, July 15, 2018

How To Build A Safety Policy

How To Build A Safety Policy
Post by CatalinaNJB

A Safety Policy in an effective Safety Management System is a forward-looking policy, the policy is organizational guidance maternal for operational policies and processes, a road map, a vision of an end-result with increased profit margin or higher return on investment and a plan to prepare each flight or operations at an airport to be completed without an incident. One of the questions a safety policy must answer is the reason for implementing a safety management system when an operator is operating safely without incidents, without a safety policy and without a Safety Management System. A safety policy is not about the operator’s commitment of safety, or what an organization is committed to in regards to the safety of operations, but rather how the organization is committed to make safety work. 
If the Safety Policy does not build the future, it doesn’t build anything
Building a safety policy needs a blueprint just like the construction of a building or building a road. Without a safety policy blueprint, or directions, the policy could become anything but a safety policy. A safety policy blueprint is to establish directions for the policy, directions for the accountable executive and all personnel. A blueprint is to avoid making the policy a safety-first priority policy, which could take the policy all over the map without directions as long as it was determined to be safe by someone’s opinion. If a safety policy states that safety must be first priority it must be accompanied by a safety risk level assessment of how safety always will be a priority. Safety cannot be a priority, since there will always be an inherited risk in aviation. When safety is an organizational priority operations becomes incidental to safety, or takes second place. In an organization where safety is priority there is no activity, since there are risks involved at the moment an aircraft is in motion or at the moment when an airport operator is on the field. If there is a risk present, safety is no longer the priority. However, when there are acceptable safety risks levels defined, then safety is paramount and safety can be achieved in operations. 
The first building block in a safety policy is to decide and commit to what the purpose of the policy is. A safety policy that is paramount is a policy with a purpose, it is a practical policy that personnel comprehend, it is a vision of the future and a vision of where the organization is headed, and a commitment to safety with zero tolerance to compromise safety. The base and first building block in a safety policy is to make safety paramount where there zero tolerance to compromise safety, or acceptable short-cuts. 
The second building block of a safety policy is to establish safety critical areas and safety critical functions. Without safety critical areas in the policy there are no criteria established to develop safety goals and objectives. Safety critical areas are your tools as an operator to establish measurable goals, and to develop steps of objectives to reach these goals. With step one and two completed, we know what direction we are headed and where we are going. 
The third building block of a safety policy is to get everyone onboard, or on the same page. It is a comprehensive task to get everyone onboard and to agree. That someone disagree with the SMS process does not imply that they are against safety. As a matter of fact, a Safety Management System that does not allow for personnel to disagree or question the system itself, has become a failed safety management system. Any safety opinion given, or process decisions made, must be backed up with documented data and facts. That there are individuals who disagree with is safety decisions an the SMS, is because the Director of Safety or Accountable Executive not been able to deliver, backed up, or communicate their safety improvements with reasons, facts or data. There will also be times in an organization where management is incorrect and personnel in the field have the better and safer solutions. 
Leadership in safety management is to guide with clear directions
Safety Management System requires leadership. This leadership is not only for safety improvements, but leadership when implementing policies that will be acceptable to all personnel. SMS is not a paperwork program to document safety records, but a live program, and a program in motion. SMS is a program where hazard, incident and accident reports are submitted for assessment, investigation and risk analysis to improve safety in operations. 
One option to establish a reason for personnel to buy the SMS is to include a confidential reporting system for all personnel. A confidential reporting system is not an anonymous reporting system, but a reporting system with limited access at the receiving end. This system is not to mislead operational management, but a system made available to address the issue as a safety issue rather than as an operational issue. In addition, operational management has agreed on, by the implementation of SMS, that none of these reports are available to use for punitive actions against a person. The question many asks is if this is a “get out of jail free” card, or where is the line in the sand drawn. 
It is oversimplified to state that there is no disciplinary action unless the act was illegal activity, negligence, willful misconduct. When the bar for disciplinary action is set at illegal activity, negligence, willful misconduct, any report submitted will be below that bar, or will not cross the line drawn in the sand. By implementing these activities in the safety policy, the policy itself becomes an obstruction to safety. Disciplinary actions may be the only option, even if the action was not illegal activity, negligence, willful misconduct. For a moment, let’s assume that an aircraft taxiing at a higher than normal taxi speed, and the flight crew is pre-occupied with after landing checks. During the taxi the aircraft strikes a taxiway edge lights, misses the turn in the taxiway, then taxi across the island of grass and enter the taxiway on the other side. When the reports comes in to safety department, the report states that the taxi was slow, flight crew was blinded by another aircraft and by the time they realized they were off the taxiway the aircraft was entering back onto the taxi way on the side. When reading this report, the operator has no way of knowing if this was either an illegal activity, negligence or willful misconduct. An operator may assume that it was, but it is not an illegal activity, negligence or willful misconduct unless the notice of suspension or termination states this specifically. There are very few operators that would make such bold statements in a termination report.  By raising the bar to this level, there is no room for safety improvements. In the virtual example above there is lots of room for disciplinary actions when the operator, during the investigation, discovers that the flight crew did not make true statements. 
On the other side, when the bar for unacceptable activities is set at the level of Safety Critical Areas and Safety Critical Functions, there are opportunities for safety improvements. Pilots may be offered refresher training, stress management training, operational policies review training or other training to improve skills and accept safety as being paramount. By defining safety critical areas, flight crews, maintenance crews and others know what these areas are and they may establish their own goals in their tasks of duties to improve safety. 
These are the three first steps, or building blocks of an effective Safety Policy. Without safety being paramount, there is no strategy for safety in operations. Without safety critical areas there are no defined goals for safety in operations. Without personnel accepting and participating in an organizational safety management system, there are no human resources available for safety in operations.  


Friday, July 13, 2018

So..Your SMS is not Continuously Improving.....Chill Out!

So..Your SMS is not Continuously Improving.....Chill Out!

The Greyhound is the fastest dog in the world, but they need to chill out too. 
After working with dozens of different enterprises, implementing Safety Management Systems, SMS, and Quality Assurance Programs,QAP, I have discovered several reasons why the SMS/QA stops working after a while. 

The following are some reasons you need to examine in your own company:

Loss of Interest in the Regularly Scheduled Safety Meetings:

When an SMS is first implemented, everyone is on board and enthusistic about the Process so the weekly safety meeting are well attended. Over time people begin to lose interest in the weekly safety meetings. Managers start falling back into their pre-sms modes. It is imperative that upper management stress the importance of the participation in the weekly meetings. These meetings are where we roll up our sleeves and really look at the reports and analyze root cause. The result of the weekly meetings should be corrective action plans that actually provide the action to continuous improvement.

The Deming Cycle for Continuous Improvement
Hazard/Incident reports as well as audits results drive the Risk assessment, Root Cause Analysis and Corrective Action Plans that are results of the weekly meeting. 

This is the engine of the SMS. See

Reduction of DATA Collection

There are some great SMS Software programs. I have experienced SMS Pro and Vortex and found these to be excellent programs. But, "Garbage in - Garbage out." In order to maintain "CONTROL" we need to consistently measure our processes to provide quality data. Yearly audits just don't cut it. 

A consistent audit verification program provides excellent data to enter into the SMS engine analysis system. The Hazard and Incident reporting system must be encouraged by middle and upper management. A good SMS Software program will keep track of the progress of each report, communicate to key people, and help the SMS manager to control the flow and completion process of each report. 

Poor Corrective Action Plan implementation

Once the Causal factors have been determined through a robust Root Cause Analysis, RCA, it is important that the corrective action be "realistic" and supported by upper management. Of all the impediments to a successful continuous improvement program, lack of follow-through on the corrective action plan is the highest.  All CAPs should be monitored and checked by the Quality Assurance department to make sure that what we said we would do is actually what we did.

Turn Over

According to the United States Small Business Administration,SBA, "..employee turn-over is the highest cost to a small business." Because of this reason, it is important that your enterprise have a "system" of control. All job functions throughout your company must be controlled through robust procedures. New employees need to be taught to depend on procedures to perform functions. Do things by the book. 

Dr. Joseph Juran, Founder of the famous Juran Institute 
Dr. Joseph Juran, " all processes should be so well documented that you could replace an entire department with new employees and you should be able to make the same product with the same quality..." The "system" approach assures that processes are not people dependent. 

In addition, new employees must hired and trained with the same or greater commitment to the SMS. It is the job of management to permeate the organization with a safety oriented culture.

Communication breaks down

Its so easy to fall back into old habits. Managers get absorbed into their day-to-day routines. Communication begins to slow down between the SMS teams and we begin to forget the importance of robust safety communications between departments. Management needs to continually emphasis to the workforce the importance of reporting incidents and hazards. 


Entropy defined, "lack of order or predictability; gradual decline into disorder." How do we fight entropy in our system?  The secret is constant renewal of Goals and Objective. As we gain control of an area or process, identified as high risk areas, we need to replace the goals and objectives with new ones that come from our Safety Risk Profile and Hazard Registry, ( see goals and objective from your Safety Risk Profile.) 

Another tool to fight entropy is training.  There should be constant and robust training offered throughout the organization. Training not only equips people to do a job, but it is also a very effective tool of communication. Many policies can be reinforced in the training courses. 

Entropy can be fought off through recognizing success stories within the organization. Remember we are collecting data through reports and audit results. Well, do we recognize areas that pass their audits. SMS and Quality Assurance is often looked at as a system that recognizes failure. We should applaud success as well. 

In my 30+ years implementing Quality and Safety Management Systems I can testify to the fact that if we remain diligent, we can achieve a true process of continous improvement. We have many success stories to back up this claim. It is up to management to recognize this and support it in order to make the organization successful. 

The SMS Memory Jogger II 
Dennis Taboada, M.eng.,CQE,CQM                                                                                                 CEO, President DTI Training Consortium Atlanta USA and DTI Training Canada Ltd. Richmond BC Canada

Suggested Reading: "The SMS Memory Jogger II." Available at Publisher GOAL/QPC , search SMS. Also,

Monday, July 2, 2018

When SMS Stays On The Shelf

When SMS Stays On The Shelf

Post by CatalinaNJB

Products that do not generate revenue greater that the cost of the shelf in a supermarket are removed from the shelf. If a product is required to be carried to conform to regulatory requirements, the product may be sitting on the shelf untouched as a dust collector. SMS is in the same boat since it was introduced as a regulatory requirement. As a regulatory requirement the SMS might just sit on the shelf and collect dust since an enterprise keeps it there without a return on investment. That the SMS is put on the shelf does not imply that the SMS processes are ignored, that hazard and incident reports are not processed, that root cause analysis are not conducted or that personnel are not trained in SMS. All this is happening while the SMS is sitting on the shelf. An enterprise that has placed the SMS on the shelf is an organization that is not able to identify and describe what the SMS does for the operator. SMS is intended to be a program for improved safety in aviation. 

If the implementation of a safety program does not directly contribute to safety improvement, the program has become nothing else but a paper-shuffling task and labor-intensive ticking checkboxes. The one reason SMS is kept on the shelf is due to regulatory requirement by the Aviation Authority (Government). The SMS stays on the shelf even if it does not serve customer service or produce what the cost of the shelf is. This cos is not to produce a positive return of investment, or cash flow, but also with reference to return of safety-investment or continuous improvements. 

SMS is a system where discrepancies are clarified
The safety management system has been described as an umbrella of the operations. The purpose of an umbrella is to shield, protect, buffer, shelter or safeguard. If an SMS operating as an umbrella the enterprise has a system in place to ensure a safe flight for all passengers and freight. When the SMS is an umbrella, the system functions and protects without any further actions. It’s a wonderful system. Or, maybe not…a system that protects is not a fail-free system and may give a false impression that safety is paramount in existing operations, while the opposite could be the actual fact. 

If the SMS is controlled by the umbrella, an enterprise, operational systems must unconditionally follow the umbrella wherever it goes. This is the old way of looking at safety, where safety is the “big-bad-wolf” who directs operations in all different safety directions. Or, on the other hand, if operations under the umbrella are in control of where the umbrella travels, then safety decisions rests with the operations, which is the NextGen of aviation safety. The purpose of the umbrella is oversight of safety processes, and not the safety in operations itself. When SMS takes on this role, it becomes the Quality Assurance program. 
Generally speaking there are two ways to operate with a safety management system. One way is to apply SMS as a duplicate control system to discover if there are any errors in the first audit. This is a method when the SMS system conducts audit of operations and validates or invalidate the current result. It becomes a control system of the first or prior checks conducted. If both results come up with the same conclusion it is assumed that the first result also was correct. If the second result is different than the first result, it is assumed that the first result was incorrect and a corrective action plan (CAP) must be implemented. This CAP is not a process or system CAP, or a CAP of how the task is performed, but a CAP of the failure itself. If the issue was a light bulb, this CAP would replace the burnt out light bulb, but not address the issue of why a newly replaced light bulb burned out. This is when safety is covered under the umbrella without directions and difficult to define how SMS improves safety. 

1)     Time how long it takes to spot the 6 differences;
2)     When differences are spotted, time it again how long it takes to spot the 6 differences;
3)     This is SMS – to spot the differences and it only becomes more effective with training.
The other method of applying SMS within the organization is to apply SMS as the oversight body of safety processes. Operations establish processes for acceptable safety levels, and the SMS assess these processes in an oversight capacity. The SMS process is to audit all operational processes by random sampling of selected operational audits. If there are only a handful of audits conducted the process would audit all the samples. As a system audit of operational safety checks, this audit would establish if the organization is performing safety tasks to acceptable risk levels established by organizational policies. E.g. If there is an annual company flight-check scheduled, the audit would discover if these flight checks were conducted. The flight check result of the audit is irrelevant to a system audit, since this task, or CAP, was already performed by flight operations and based on the flight check result.  If the system audit found that the flight checks were conducted to a 95% confidence level of all operational checks, then the system in in statistical control. Should the process be out of statistical control, then a CAP must be initiated to move the line to an acceptable safety risk level. 

As a Quality Assurance system the SMS has an opportunity to change incompetent processes. However, if keeping SMS on the shelf for reasons of regulatory requirement only, the SMS in itself becomes a hazard to aviation by its travel in the wrong direction at the fork in the road.     


Saturday, June 16, 2018

When Human Factors Snaps

When Human Factors Snaps

Post by CatalinaNJB

Quality assurance is a vital part of production in the manufacturing industry. There are several data collection points during the processes with the end result that the product is reliable. Whatever the manufacturing is, products are tested over and over again to ensure the quality delivered equals quality promised. These tests could be NDT (Non Destructive Testing) tests, destructive tests, endurance tests, or any other tests that are applicable to establish a confidence level of quality above the bar, or above promised quality. If the quality level is below the bar, there are two available options; 1) lower expectations of the product or promises; 2) improve the quality to a desired and acceptable quality level. The simplest solution is to lower the expectations of the product, which some manufacturer decide to do when coming to a fork in the road. There is some truth to the saying that “you get what you pay for”. 

Quality assurance is decided at the fork in the road.
When a product is manufactured as a larger piece of a system, it is tested prior to entry onto the assembly line. It becomes obvious that not all products, or all 100% of a sample, can be tested for quality by destructive testing, since there then would not be any parts left to assemble. The quality of parts within a system where a destructive testing is required is therefore based on random sampling of these pieces and applied to the remaining sample. Turbine blades and vanes in a jet engine cannot all be tested for material stress. Random samples are tested to establish a confidence level of product warranty. Should the sample “fail”, and the test is performed according to standard, it’s not the failure of the sample itself, but the process that lead up to the finished sample. Service industries also perform sampling of services for quality assurance. A service industry may sample how personnel perform in customer service relations, and they may sample the product they are servicing. A gas station may find that one supplier of gas often deliver poor quality, or they may find that one vendor often delivers poor quality dairy products. When a customer is complaining about the product, they are actually complaining about the service delivered. A customer expects that a service provider (E.g. gas station or general store) have a quality assurance system in place to ensure that each product they service is delivered to expected quality. This type of quality control is more difficult than strictly product quality, since the service provider must have confidence in, not only the manufacturer, but also in the vendor. The service provider must establish a confidence level of a manufacturer and the vendor that is at or above the bar of what a customer expects, and do this for each product they sell. 

Both manufacturer quality assurance and service provider quality assurance can be tested and evaluated based on known data that affects products or services. Sampling of what the vendor delivers can be evaluated based on known data that affects products or services. Sampling of what the vendor delivers can be taken at each delivery. Yes, they would lose the sale of that one item, but by sampling they can apply this data in their quality assurance system. Some years ago, a small produce wholesaler conducted their product quality assurance by asking each employee to pack themselves a bag of randomly selected fruits and vegetables every weekend. This competitive edge of testing the product weekly blew the larger and established competitors away. Eventually this small organization purchased the well established large produce wholesale companies. Not only did this improve their edge of product quality, but it improved their edge in customer service by having live and current testimonies of their quality. It could be that the manufacturer delivered a good product, while the quality deteriorated while in the possession of the vendor. By sampling the vendor, the quality of the product itself cannot be sampled. However, this is often the only practical solution to collect samples for quality assurance. This solution points the blame at the vendor and may not address the actual root cause. This approach is often applied, since it’s a simple and a justifiable action, to blame the nearest source when the failure happened. In addition, this type of root cause assessment does not have any cost incurred and it doesn’t require any special skills, knowledge or training.

Data is collected to analyze why the selected process didn’t win.
An effective Safety Management System operates the same way as a manufacturing system and service system by collecting data for quality assurance. Except that the SMS collects data of human factors, or human errors for lack of better words, of how much pressure it takes for human factors to snap, break or to malfunction in job performance. Personnel may be required to perform conflicting tasks in job performance, work with incomplete systems and must have resilience to change or divert a process when things go wrong, as they sometimes will. When applying this concept to an airport or airline, the airport makes an effort to maintain safe customer service, while regulatory requirements may demand that the airport temporary closes. A pilot may be tasked with flying in hazardous weather conditions, while simultaneously being tasked with unacceptable ATC clearances due to the closed airport. The question becomes how many combine tasks does it take before the performance of human factors snaps.

Human factors system was the forgotten system until the concept of SMS was introduced. After an aircraft accident the blame was immediately assign to the pilot. The pilot became the root cause, and it was named pilot error. Simple, closed and no questions allowed to be asked. This was safety in the old days. Nobody had the right to argue with safety. When the safety-card was played, the discussion ended. SMS is different. In a healthy safety system, there are discussions about safety issues and the root cause does not paint a person into a corner. However, there are few options to test human factors and test a person for acceptable pressure level. The task is not as simple as in a manufacturing process. Often the acceptable pressure level is not identified until after an accident. Now it’s time to investigate the underlying systems, organizational processes, environmental factors, supervision and the human factors concept itself to establish a root cause that can be further discussed and mitigated. 

When human factors become the subject of testing for quality assurance there are different processes than testing for material quality or product quality. However, the principles remain the same, that testing is required to establish to what level of quality systems are performing. First, it becomes a factor to establish the expected performance level of human factors and second, establishing training programs to ensure that pilots always perform above the established expectation, or their breaking point of performance. Everybody has a breaking point at witch time they are not capable of performing expected tasks.  E.g. Air France 447: “…completely surprised by technical problems experienced at high altitude and engaged in increasingly de-structured actions until suffering the total loss of cognitive control of the situation.”-BEA Report

The point of no return back to safe operations is the point when human factors snaps. The beauty of an effective Safety Management System is not only to assess for accidents, but to lead personnel on a path where they will never fly beyond a point of no return. In other words, SMS is not just about preventing accidents, it’s to establish a confidence level of air service safety warranty. Remember, without an SMS there is a safety confidence level of zero. 


Friday, June 1, 2018

There Is No SMS Without A Just Culture

There Is No SMS Without A Just Culture

Post by CatalinaNJB

A safety management system cannot exist without a just culture since a non-just culture in itself is an opposition to forward looking accountability. Not only does a non-just culture oppose forward looking accountability, but it also opposes the principles of continuous safety improvements. In a traditional safety culture, safety is a mandate established by senior management and demanded that all personnel strictly follow these mandates. Aviation accidents are still classified as a failure to comply with regulations, policies or procedures. The conclusions are often that If only those pilots had complied with regulations, policies and processes there would not be a single aviation accident anymore.  Well, we know that’s not true. In 1956 and the Grand Canyon disaster both Captains of both airlines were following regulations, policies and procedures and they ended up in a mid-air collision. On the other hand, if KLM 4805 had continued their first takeoff roll without a clearance, is there a possibility they could have cleared Pan Am 1736? There are times when following the rule could have avoided an accident, but there also are times when not following the rule prevents an accident. Regulatory requirement serves a different purpose, or role, than operational safety. A finding that following regulations, policies and processes would have prevented an accident is not a fact of the true root cause. A true root cause analysis identifies what was done rather what was not done.
Just culture is to line elements for comprehension and continuous safety improvements.

An enterprise may conduct a self analysis of their own just culture. There are several variations of valuable just culture assessments tools available for an enterprise to conduct evaluation. A just culture self-evaluation is more than tick the correct boxes. It is to find the true culture in the organization. With a fully operational safety management system an operator is expected to operate within a just culture. It becomes a failure to the SMS unless the culture is present. An operator could believe that they are operating within a just culture while there is no data to support their opinion.  A just culture is not the same as a non-punitive culture, but a culture that is just in the assessment of root causes. A non-punitive culture is in itself a hazard to aviation safety when it is not incorporated in a just culture. The four parameters of a just culture are trust, learning, accountability and information sharing. When the system of just culture is effective the outcome is comprehension of SMS and continuous safety improvements.

Visualizing a just culture is to line up six dices in a row where all dices are displaying equal numbers. SMS process implemented needs one process to generate trust, one process to instill learning, one process to accept accountability and one process to share information. When these four processes are established, the effectiveness is shown in the output of system comprehension and continuous safety improvements.

A great safety change today could be obsolete over time.
In a non-just culture there is only one dice; the pilot. When things go wrong the pilot is blamed. By improving the process, a second dice was added; the nav-aids. Eventually other processes are put in place and with the third dice; the air traffic controller. In this example of a just culture, these are the three first elements of the culture, where the pilot is trusted the authority, the nav-aids provide guidance and support, the third is to place accountability on ATC, in that ATC has the authority to maintain safe air to air and air to ground separation. The fourth element of a just culture is to share this information by reporting of hazards, incidents accidents and safety concerns. Sharing this information improve individual comprehension of the SMS systems and how implemented improvements equals continuous safety improvements.

A just culture is expected to eliminate accidents. Some might say that it’s not possible to eliminate all, but if one flight can be safe, what are the reason for the next flight not to be safe. In a true story the safety process did not include all four elements with a fatal outcome. A person had sat down in front of a fire-trucks door and dozed off. The fire department was called out, opened the doors and run over the person sitting there. The fire department process had placed the role of safety on the person at the door, without considerations of the other elements. This is also the old-way in aviation safety. There is only one safeguard and that is the pilot. This safeguard is placing unreasonable expectations on one person to be perfect in all tasks, to always be vigilant and to never let person or mind leave the post. The new way of SMS and just culture is to implement support systems for continuous safety improvements for the flying customers and aviation services.  


Sunday, May 20, 2018

What To Report In SMS

What To Report In SMS

Post by CatalinaNJB

The Safety Management System (SMS) is a safety tool for an imperfect organization, being an airline or airport, to discover hazards and maintain an acceptable level of safety. Airlines and airports in North America are mostly implementing their SMS for regulatory compliance and not for safety improvements. SMS is simply implemented as a requirement to maintain the operations certificate. As a regulatory demand SMS might be viewed as another bureaucratic burden to satisfy paperwork trails. However, after working with SMS and comprehend the systems, operators may experience changes of opinion and discovered the benefits, including a higher return on investment, by the implementation of SMS.  Any operator, who does not require an SMS for regulatory compliance, would benefit strongly by implementing an SMS program voluntarily and be ready when SMS eventually becomes a regulatory requirement. This timeframe period would build SMS comprehension and readiness for SMS compliance. SMS is a safety tool, and a speciality tool required, to coordinate both complex and simple systems and as a tool for cooperation with continuous safety improvements. 

The Safety Bunny is attentive, listens and looks out for hazards.
SMS is a tool in the beginning stage of supporting safety in aviation. Safety does not happen overnight but is a change in operational culture. SMS is a tool to be accepted on an equal platform as an accounting department, human resource department and sales and marketing department in a successful business. In addition, there are several other organizational functions that are required to support the business success. However, SMS is not just another tool, but the single most important tool in promoting business activities. Aviation cannot be promoted without SMS as the core purpose in bringing passengers and freight safely home. 

Hazard reporting in SMS has everything to do with an effective SMS and continuous safety improvements. When SMS is first implemented there is no prior data collected to establish the organizational confidence level of safety. An enterprise without an SMS may believe that they are 100 % safe, while in fact they operate with a zero percent confidence level of safety. Without documented safety processes there is no safety. It’s only the random probability of hitting the jackpot. A common trend when rolling out the SMS is to promote everything to be reported. Everything includes hazard reports and any incident or accident observed or being involved in. Hazards are subjective and individually assessed as a risk based on opinion and experience. Exposure intervals to specific hazard often changes the opinion of the safety risk involved. When rolling out a brand-new SMS all hazards should be reported. It should not be expected that untrained personnel make risk assessment of a hazard and decide if it is reportable or not. There is a reason why a hazard was observed, and it is that a condition caught someone’s attention. It is simply a hazard because it was discovered. There is no magic to discover and report hazards. When assessing the risk factor of a specific hazard it could well be that it is irrelevant to aviation safety, but it doesn’t take away the fact that in the moment someone determined that it was. 

What's important is how changes are managed when the line is washed out.
The first purpose of SMS is to establish a baseline of current operational processes. This baseline is not a safety level baseline, but strictly a baseline of current processes. The next step is to assess current processes to regulatory requirements. If current processes are equal to or exceed an outcome for regulatory compliance, then this baseline is acceptable to proceed to the next step. An enterprise must have processes in place where the outcome of these processes conforms to regulatory compliance before continuing to the next step, which is continuous safety improvements.  The continuous safety improvement step is to draw the line in the sand or establish an objective of where to set the safety bar. When the safety bar is accepted and set by an enterprise the opportunities for improvements are infinite. This bar may vary from one operator to another operator. It is vital for success in safety not to compare safety bar levels between operators, but to compare current result to established goals. When an operator restricts hazard reports, they are restricting the evolution of SMS and safety will maintain status quo. This might be acceptable for an operator who is safety-superior, but not for operators with a goal for continuous safety improvements.     


How To Build A Safety Policy

How To Build A Safety Policy Post by CatalinaNJB A Safety Policy in an effective Safety Management System is a forward-looking polic...