Strategies for SMS Expectations
Another insightful post from Helena1320 (The 100th post in fact!!).
A Safety Policy is an organizational guidance principle which describe the operational culture and core purpose for airport or airline operations. Canadian Aviation Regulations (CARs) requires airports and airlines to operate a Safety Management System which is based on this Safety Policy. In addition to the generality of a Safety Policy, this policy requirement is to establish a clear enterprise commitment to safety. The challenge for airports and airlines becomes to define what a clear commitment to safety is. A clear commitment to safety is not just a statement to be safe, but it is to capture defined expectations for operational processes.
Expectations are defined by Transport Canada in their SMS Document Review Guide (DRG), which was distributed to airlines and airports during the implementations phases of SMS.
An airport, or airline that has not established a link to the expectation of a safety policy is assessed to be in non-compliance with the Canadian Aviation Regulations. Often the findings by Transport Canada states that “There is an expectation that…”
The comment continues that there is no link between SMS design, or SMS operations and the expectation of a Safety Policy. The expectation is that an airport or airline fully comply with the expectation for complete regulatory compliance.
The Document Review Guide of a Safety Management System has established an expectation of a Safety Policy that: “The organization has based its safety management system on the safety policy and there is a clear commitment to safety.” Reference to CARs are 107.03, 302.502(a)(i), 705.152(1), where 107.03 and 302.502 are applicable to airports and 107.03 and 705.152 are applicable to airlines. Under CARs 107.03 the requirements are to design a Safety Policy and CARs 302.502 and 705.152 are operational processes which are expected to conform to regulatory requirements.
A Safety Policy is expected to have a design with a clear commitment to safety. An overarching safety policy is a commitment of Zero Tolerance To Compromise Aviation Safety and includes all Components of a Safety Management System. The first commitment of a Safety Policy is for an airport or airline to establish and maintain regulatory compliance.
Without regulatory compliance there is no authority to establish, or maintain operational processes A clear commitment to safety is blurred by assumptions of safety.
as airport or airline.
As a second component to the Safety Policy is the performance requirements. These components are found in CARs 302.202 for airports and 705.152 for airlines. This intent of a Safety Policy is to establish and maintain operational processes which perform to regulatory compliance and that these processes do not in any way compromise aviation safety. There is no guarantee that a regulatory conforming process at all the times promote safety. However, the guarantee to safety is when an airport or airline accepts accountability, establish and follow-up in all aspects of operational processes with a commitment of Zero Tolerance To Compromise Aviation Safety.