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.  

CatalinaNJB