Another post from CatalinaNJB
A small operator communicates differently with their personnel than how a mega-enterprise would communicate. An airport with 2 or 3 people, being an Airport Manager, SMS Manager and Accountable Executive may communicate verbally without much documentation, while a larger airport may use multiple levels of communications processes. Both operators must meet the same requirement of the expectation that communication processes (written, meetings, electronic, etc.) are commensurate with the size and complexity of the organization. When applying this expectation without ambiguity, or applying the expectation with fairness to the expectation itself, both operators are expected to apply the exact same processes in communication. The simplest avenue when assessing for regulatory compliance is to apply the more complex communication processes to both operators. When applying this approach, the smaller airport’s SMS becomes a bureaucratic, unprofessional and ineffective tool for safe operations.
Small airport communication has also changed with the times.
At first glance it looks great that a small airport is expected to operate with different communication processes than a large airport, but when analyzing all available options, there is very little tolerance, or none, to apply this expectation in any other way than a prescriptive regulatory requirement. It is only when the operation is understood that the expectation can be applied with ambiguity, and with unfairness to the expectation itself, for an effective communication process for any size and complexity airport operators.
When there is a finding at a small, or large airport that the communication did not meet the regulatory requirement through this expectation, in that the information had been forgotten, misplaced or incorrectly interpreted, the operator is required to identify policies, processes procedures and practices involved that allowed for this non-compliance to occur. This in itself, that an operator allowed for a non-conformance to occur is a statement of bias in the finding implying that the operator had an option not to let this non-compliance occur. If this option was available at that time, the operatory would have taken different steps. The reason the non-compliance occurred is that the option to make a change was not available at the time when it occurred. All systems within the SMS were not function property and often it is the systems of human factors, organizational factors, supervision factors or environmental factors. Reviewing a finding in 20/20 hindsight is a simple task and to point out what could have been done differently becomes the task of applying the most complex process. However, when the operations is in the moment, the options at that location and point in time are limited to snapshots only of information, knowledge and comprehension of the events.
Human factors in communication is today integrated in automation and not visible.
Since there is an assumption in the root cause analysis requirements that the non-compliance was allowed, the question to the finding is no longer what happened, but why the operator allowed this event to escalate beyond regulatory requirements. The difference between a “what” and a “why” question is that “what” is data and “why” is someone’s opinion. When the finding is issued during an audit by the regulatory oversight team, the answer to the “why” question becomes the opinion of one person only of that team. When the opinion of that person becomes the determining factor of a root cause analysis it has become impossible to analyze the event for a factual root cause. It could also be that the answerer to the “why” question becomes a compromised, or an average of the views of all inspectors, in which the answer is no longer relevant to the finding, but to a process where all opinions are considered. On the other hand, when the “what” question becomes the determining factor, each link to what happened must be supported by data and documented events. If the events of the “what” cannot be answered first, or before any other questions are answered, it has become an impossible task to assign a root cause to the finding. When the “what” question is answered, then a change to the “what” may be assigned and implemented.
This does not imply that the “why” question is not to be asked, but it becomes a factor of how the “why” is asked, and if the determining factor to the “why” question is an agreement between several people in a group to assign an average of indifferences, or if the “why” question is answered to the “what” question. When applying the 5-why process, the answer, or root cause, is established by the answer to the first “why”, since the rest of the answers must be locked in to the first. The more effective root cause analyses are the “fish-bone”, the “5-why matrix”, or the “fork-in-the-road” test.
When the requirement of the second expectation, as stated in the root cause analysis document, that the non-compliance was allowed, it changes the first expectation within an SMS element of different communication based on size and complexity of the airport to a prescriptive regulatory requirement. The prescriptive requirement then becomes the common denominator for the event that was allowed to occur and must be applied to the most complex communication process. The simplest way to look at this is that when the “allowed to” is allowed to be applied to an event, it is assumed that human variations do not exist and that the system is operating in an undisputed perfect virtual environment.