When Probability and Possibility Becomes Interchangeable

When Probability and Possibility Becomes Interchangeable

By CatalinaNJB

A goal without a plan is just a fantasy of random achievements.

When probability and possibility become interchangeable is when an enterprise has developed an SMS theme with elements of failures. There is an ongoing SMS theme question that an enterprise, being an airline or airport must be able to answer to allow for operations to operate within the intent of the SMS. Without comprehending the basic “Why” of SMS, the foundation for an enterprise to actively achieve safety-improvement goals is not established. An enterprise without an active goal achievement plan is an open door for goal-wishes and random goal achievement without directions. The basic SMS question is “Why does the Global Aviation Industry, being Airlines or Airports, need a Safety Management System (SMS) today, when they were safe yesterday without an SMS?”

When approaching SMS as safety only, there is a biased view of the question which restricts the comprehension of the answer. The answer is not in safety, but in the processes. Operators are required by regulations to assign the title of Accountable Executive (AE), SMS Manager or QA Manager to personnel who are identified by the org-chart, which eliminates the opportunity to assign personnel who comprehend the SMS. 

Assigning by org-chart and not by technical skills or comprehension is to expect that someone can obtain their SMS skills by given a title within the SMS system. The only SMS skill required for developing a corrective action plan is a title. In addition, they convene with other unskilled personnel with titles to implement these CAPs. Holding the title as the AE and having full authority of the SMS does not make that person an expert on SMS. 

When the Regulator delivers the findings to an enterprise, the AE immediately folds since they don’t have the skills or comprehension to support and backup their own SMS actions and processes. Upon notification of the finding there are no reasons for the AE not to accept or reject the findings with a clear explanation and in addition, provide both a short-term CAP and long-term CAP to the regulator. The AE profession is one of the few professions where a title is the governing qualifications for decision-making in safety critical areas, including regulatory requirements for an unskilled person to make these decisions.   

SMS is set up for failure by the regulatory AE qualifications requirements.

Probability and possibility are incorrectly applied to the SMS as being interchangeable within a safety management system. When applied in a risk assessment, the possibility is applied to the exposure element as a virtual exposure, or possible exposure and always applicable. There is an opinion among SMS personnel that there is always a possibility for an engine failure after takeoff since the flight crew conducts a pre-takeoff briefing and includes in the briefing the procedure in the event of an engine failure. That this possibility exist is a true statement, since possibilities are virtual, or fantasy events without facts. In addition, there is conventional wisdom among enterprises and regulators that this possibility must be converted into exposure in a risk assessment. Without SMS comprehension the bar becomes to “error on the side of safety” and possibility is therefore applied interchangeable with probability. This is another avenue for SMS to becomes its worst enemy and setting itself up for failure. There is a hazard within the regulatory system itself when there are no requirements for the AE to comprehend SMS communication.

CatalinaNJB

Concierge SMS

Concierge SMS:  Contracted out Safety Management Systems

So you are required to have a Safety Management System, SMS, by regulation.  There is so much confusion as to what constitutes a good and continuously improving SMS.  You look to hire an SMS Manager that knows all the intricacies and requirements of SMS that satisfy regulatory requirements. A really good SMS Manager has to have so many skills that it is hard to find the right fit. The trend in today’s world is to have services done for us. UberEats™, Carvana™, Freshly™and Randstad™ Staffing services are just a few examples of “services”provided to make our lives easier. What if you can hire a team of SMS experts to design, develop and run your complete SMS for about the cost of hiring 1 SMS manager. 

More Airlines and Airports are Contracting out SMS Services

The BIG question is this:

Will the regulator accept this new initiative? The short answer is yes. 

The International Civil Aviation Organization, ICAO, dictates to the State countries what SMS requirments are needed to be passed down to the enterprises in their respective countries. 

ICAO has already accepted “Airside Integrators” in ANNEX 14 for aerodromes. As long as the Doc9859 Audits requirements pass, it doesn’t matter how the enterprise achieves it. After all, the SMS system is the responsibility of the Aerodrome or enterprise anyway.  

According to Dr. Fethi Chebil, PhD,  Recognized ICAO Safety Expert, “A new trend to evolve is the emergence of companies dedicated to managing and integrating an airport’s complex safety systems, reducing its operational costs and ensuring regulatory compliance. Airside activities at airports are, of course, highly regulated and subject to a government enforcement process, and this has led to an ever-increasing number of airport operators successfully transferring the risk of regulatory compliance and safety to a new type of dedicated cost effective company – the ‘airside integrator’*1. 

Privatized airports are turning to 'airside integrators' to help
them reduce costs, increase safety and boost efficiency, writes
ICAO sarety consultant Dr. Fethi Chebil.

Canada: Just recently Transport Canada has permitted Kelowna International Airport to actually “Bid” out the SMS functions at their airport. A private SMS firm won the bid and is now running the SMS program at Kelowna Airport in British Columbia. As long as the regulations are met and the company can prove the SMS is effective, there is no reason why the company can simply hire out this intricate function of their system. 

Canadian Aviation Enterprises required to have SMS, such as 705 carriers, can also take advantage of the concierge SMS. The concierge SMS provides a responsible person that will be the SMS Manager for the company and assume all responsibilities for the SMS. Transport Canada has stated, “…we are the concerned that the enterprise’s SMS meet regulatory requirements and is effective…how the company achieves this goal is up to them..”  Jonathan D. White, ex-Transport Canada principle inspector. There seems to be a knowledge gap in the implementation of an effective SMS. Finding an SMS Manager that knows ALL the components and elements and how to actually apply them to make the system work is hard to find. The knowledge, Skills and Ability of the SMS encompass at least the following:

• SMS Manual Creation and Control
• Maintaining the SMS Database and Software
• Design and Develop SMS Procedures
• Monitor the progress of Safety Reports through the System
• Risk Assessments
• Daily Monitoring of Processes
• Facilitating Manager Meetings
• Facilitating Root Cause Analysis Sessions
• Training Personnel in SMS and Quality Assurance
• Tracking results of Quality Assurance Audits
• Management of Change
• Developing Safety Cases
• Monitoring the Progress of Corrective Action Plans
• Training personnel on RA, RCA and CAPs
• Developing and Maintaining a Hazard Register
• Developing and Maintaining a Safety Risk Profile
• Interfacing with the Regulator
• Conducting Investigations of Hazards and Incidents
• Representing and Interfacing SMS with the Customers
• Risk Assessing Sub-contractors and Vendor SMS
• Risk Assessing Changes in the organization
• Briefing Upper Management of the Progress of the SMS
• Continuously Improving the System
• Developing Key Performance Indicators 
• Monitoring Trends using Statistical Process Control
• Monitoring Safety Performance Indicators
• ….and more

Keeping up with the rigors of running a complex SMS can be daunting to an individual. Contracted service providers can perform Inspection and maintenance, reporting and monitoring promoting continuous improvements. According to Dr. Chebil, “They provide a core team of inspectors, operators and on-site agents supported by internationally deployed experts using the most advanced safety and compliance management systems. • Cost effectiveness: As ‘airside integrators’ operate airside and SMS at airports across the world and own proprietary safety management systems, the development costs and the deployment cost are shared among a global network of projects and sites –everyone wins”

Concierge Safety Managment System Implementatio

The advantages of contracted SMS are obvious: No need for hiring a person when you can get an entire team. No Human Resource headaches.  No benefits packages, All costs are tax deductible, Upper management no longer has to worry about SMS compliance with the regulator….etc. Where can I find a contract SMS Service in Canada?  DTI Training Canada Ltd. is one of the First companies to provide this service to Airports, for Annex 14 SMS compliance, and all aviation enterprises to meet the CAR107 requirements for SMS. DTI Training Consortium International can provide contracted SMS service to International Aerodromes and Aviation enterprises that need to be in compliance with Annex 14 Doc 9859 Requirements and ICAO SMS regulations passed down by the state to Aviation enterprises. 

*1 Airport World/Nov-Dec 2018,  page 35, Airfield Operations, "The next big thing?" article by Dr. Fedhi Chebil. 

For more information or a FREE consult at your facility: dtiquality.com/concierge 

Why SMS?

Why SMS?

By CatalinaMJB

A Blog Analysis Of Aviation SMS

This same question is being asked by operators over and over again: “Why does the Global Aviation Industry, being Airlines or Airports, need a Safety Management System (SMS) today, when they were safe yesterday without an SMS?” There are many great safety tools within an SMS program, but SMS does not provide an answer to the question itself.  

SMS is the process of performing while avoiding reverse at high speed.

SMS was sold to the aviation industry as being the perfect reactive safety process and they fell for it. Reactive measures were how safety was improved in the old days, ever since Orville Wright’s first flight. So, if operating with an SMS does not prevent accidents or improve safety, why are we doing it? If SMS was not viewed as the perfect safety tool, the Regulator would accept a frequency of fatal aviation accidents, just like they accept accidents on the road for small vehicles and big-trucks. But they don’t. This does not in any way, shape or form imply that the Aviation Industry, the Regulator or the Public must accept any aviation accidents, but rather that the Regulator by implementing SMS, have accepted the inherent risk in flying that goes beyond the capability of regulating safety in operational control.  

In December of 2017 there was another fatal accident when an SMS airline crashed shortly after the aircraft became airborne. One reason for the crash is that SMS is still working in the concept of possibility and have not yet moved into flight-specific probability. With a bush-pilot approach to departure, where the probability for a successful takeoff is assessed, a pre-takeoff probability analysis would have pre-determined the outcome. SMS is detailed hard work and analysis of each pre-flight and not a trend analysis of past performance.

The TSB report from the accident back in December of 2017 states that “…taking off with contamination on critical surfaces is a deviation that has become normalized. Therefore, providing adequate de-icing and anti-icing equipment may not be sufficient to reduce the likelihood of aircraft taking off with contaminated critical surfaces.” This TSB report actually states that both airport or airline operators accept lower standards than what’s in their SMS manual by allowing for contaminated aircraft to depart. This event parallels the Dryden accident, where flight attendants or passengers were not allowed to question the Captain’s decision. Airport operators do not see it as their role in safety to promote the clean aircraft concept. With the implementation of SMS software and SMS paperwork the emotions of human factors have been removed from the equation to a point where safety is no longer paramount, but a check-box task.

When there is adequate de-icing equipment in place, TSB reports that airlines are rejecting to use their equipment and airport operators makes equipment unavailable by blocking it with snowbanks. SMS was intended to build bridges and remove silos. The TSB report shows that gaps between airport and airline safety has become wider over the years since SMS was implemented.

SMS has become its own worst enemy when airlines and airports do not comprehend the fact that SMS is more specialized than what they can ever imagine and more than they can manage themselves.  Airports and airlines have personnel and position filled to ensure that all checkboxes are filled in and that the Regulator accepts their documentation, but they are operating without comprehending the SMS. This is simply stated in the TSB report as “…deviation that has become normalized “. The SMS hierarchy itself by the position of the Accountable executive (AE) makes it difficult to allow comprehension of SMS since the AE is too far removed from the operations itself. The AE might be regulatory required to accept SMS, but if the AE does not comprehend SMS this will trickle down in the organization. E.g. if the AE does not believe in training, this attitude will filter throughout the organizations, or if the AE has not developed the SMS leadership skills this will also trickle down in the organization. AE might be regulated to comprehend SMS, but this does not ensure an operational sound SMS program.

SMS today is to the AE what an empty wallet to a financial advisor

An effective SMS operation needs to implement and operate with an emotionally independent specialty team. This is a team of operational, but independent, integrated personnel to ensure SMS project planning and quality leadership. It’s vital for a successful SMS that airlines and airports comprehend why they need an SMS today, when they were safe yesterday without an SMS. This question is not going away. If they are looking for a quick-fix and one-fit-all answer they are searching in someone else’s haystack. If they don’t think this is a valid question, they already took the wrong turn at the fork in the road. Since there still are accidents after SMS, the key to the answer is not about safety but about probability. The answer is found in the position contracts established by the organizational chart and in the accountable executive’s opinion. It’s a myth that airports and airlines were safe yesterday and that’s the reason we need SMS with Quality Leadership today.

CatalinaNJB