It has been said that size and complexity is not taken into consideration for an Enterprise required to conform to regulatory compliance. Often this implies that regulations are targeted to fit large organizations and does not accommodate smaller Enterprises.
Both small and large organizations must conform to regulatory requirements to be regulatory compliant. A small organization should apply less complex systems to meet these requirements than what is expected from a large organization.
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| On a foggy morning, size and complexity might not be obvious.
The issue is not that expectations are the same for both large and small, but rather that the small Operators are adapting processes to identify how a large organization conforms to regulatory compliance. Small Operators do not have manpower to operate in the same manner as large Organizations.
A Safety Management System, SMS, Enterprise has a system in place for the capture of information of hazards, incidents and accidents. In a small organization this may be done by submitting paper records direct to the SMS Manager. This report is hand delivery directly by the contributor and noted in the records. In a large organization a paper form submitted may be required to be scanned into an electronic database, entered in a database and submitted to a pre-scan manager for assessment, entered to the Hazard Register and then to the SMS Manager who delegates investigation. After risks have been investigated the report may be submitted for Corrective Action Plan through a committee or safety group. When a form is electronically submitted, several administrative tasks may be automated and the contributor may receive an electronic receipt with a generated tracking number.
Apply the right tool and don't use a broken jar as filing cabinet.
In large organizations there are often several individual involved prior to the hazard is risk-assessed. Should a small Operator attempt to follow the same complexity as a large Operator, they may be taking on a much greater task than what the organization is designed to manage.
Both small and large must conform to Regulatory Requirements for Regulatory Compliance. This is achieved by managing processes differently to conform to documented SMS processes. Regulatory Compliance is not achieved by conforming to systems which are not designed for the Enterprise.
Your thoughts.......
BirdsEye59604
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When talking about the difference between large and small enterprises, we need to focus in on the "output" or results of the Management System. All SMS enterprises MUST demonstrate that management is in control of all of their processes. A small organization can simply have a checklist procedure that is followed and checked periodically by a 3 rd party. The scope is much less than the control requirement for a large organization. What help these small organizations to gain and maintain control is the use a proper "Tools." I recommend getting the booklet: "The Safety Management System Memory Jogger II" Published by GoalQPC. There is also a Symposium that deals with the multitude of "tools" that companies can use to gain control. For information on both the Memory Jogger and the "Tools" Symposium at Disney World Fl. goto: dtitraining.com click on memory jogger and/or symposium.
ReplyDeleteThanks for your comment! What proper tools are there for a small operator/AMO willing to comply with SMS requirements based on ICAO Doc. 9859? Where can I get them? I am getting the memory jogger booklet.
DeleteThis is a very interesting discussions and I have been dealing with this challenge of SMS to large and small organizations for long time. What we have in general come up with is that the small organization has to have all the basic elements of the SMS in place but the processes are simpler. Like for example the safety reporting system, the hazard identification process, the safety assurance process and the training, as long as the duties held by personnel. However the elements in the system are there and they function with less activity but still active. Cooperation to other organization regarding SMS is an idea that I would think that could help many smaller organizations as well as regular outside assistance, such as to manage a change or on regular tasks like safety audits, safety studies etc.
ReplyDeleteHow to deal with SMS implementation on a small operator/AMO when there is no one appointed as Safety Manager?
ReplyDeleteIs there a minimum list of programs to comply with and still be compliant with SMS requirements?