How to Regulate an SMS compliant company!

First, let’s understand the foundational objective of having a Safety Management System. It is clear that the regulators, i.e. FAA and Transport Canada, can not be everywhere and at times. SMS put the onus on the company to “Control Themselves.”

Control means to have standard operating procedures, follow them, audit them to make sure they are being followed and then take data from the processes and analyze them to improve their systems. The result will not only be a safety company but, will also improve efficiency of the companies processes that will result in money savings. 

In the past, regulators typically have performed audits against the regulations. If the regulator is doing this, they might as well be on the companies payroll. Under SMS the company becomes “self healing” of it’s own regulatory contraventions. The company institutes in own Findings, Corrective Actions, Root cause analysis, and Follow-up. The regulator is now is a position to simply ASSESS that the self controlling system is effective. 

EXAMPLE: Under the old Audit system, the regulator would pull a sample of pilot training records. If they found a deficient record, i.e. missing dates, signatures...etc, the Inspector would write up the record for corrective action and ask for a CAP to prevent that from happening again. 

Under SMS, the regulator will pull a sample of pilot training records, if they found a deficient record, then they would ask the question, “Why did we find it, You should have found it if you have an SMS?” Assessment is much easier to accomplish and will communicate to the company that they are responsible for their own CONTROL!

Transport Canada has been the most successful at implementing their Assessment and Systems Approach Surveillance program. The FAA has not really grasped the idea of Assessment and still is conducting Audits that are labor intensive and does nothing to determine efficiency of the companies SYSTEM. Your thoughts....

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