When Hazards Are Reactive

 When Hazards Are Reactive

By Catalina9

It is a regulatory requirement that an airport or airline has a process in place for identifying hazards to aviation safety. It is also expected that an airport or airline has a proactive process or system that provides for the capture of information identified as hazards. At the time when the Safety Management System (SMS) was implemented, both airlines and airports established a reactive process to capture operational hazards as they were relaying on organizational personnel to identify and report hazards. This process in itself is a hazard, but was put in place without a risk assessment or change management analysis. The directive was simply for their personnel to head out to identify and report hazards.

Some activity is a hazard simply due to regulatory non-compliance

Within the SMS regulations, hazards are defined as a proactive process. A proactive process is to recognize an opportunity and plan a change. It is also to test the change by carrying out a small-scale study or apply your SMS random sampling process. After testing is completed, the task is to review the test, analyze the results, and identify what you have learned. The next critical step, which is a step often assumed as an unwritten rule, is to make a decision. A decision is more than decide on what path to take, it is to identify and document hazards and make a risk analysis decision. A final .step of the decision circle is to take action based on what you learned in the study step. If the change did not work, go through the cycle again with a different plan. If you were successful, incorporate what you learned from the test into wider changes. Use what you learned to plan new improvements, beginning the cycle again.

At the time of SMS implementation and when airports and airlines made their decision for operational personnel to identify and report hazards, they had overlooked the decision step. Since the step was overlooked, or ignored, they unknowingly placed their personnel in a hazardous environment. It was understandable to all that no consideration to this issue was made at that time since there were no changes to their current operational processes. Pilots were still flying airplanes the same way, ground personnel did their regular jobs, mechanics kept on fixing airplanes and airport personnel continued with their same tasks as they had done for years. In their own mind there were no change management analysis required. However, if their analysis had included a decision process, a door would have opened to the fact that SMS regulations were a new and require a change management analysis, or a safety case. Organizations, small and large, are still sending their personnel out in the minefield of hazard identification. 

At first glance it may not seem like a high risk to send personnel out looking for hazards, since they had worked in that same hazard environment prior to SMS implementation. To an extent this is true, except that SMS was a new regulation and required to come with a proactive hazard approach and personnel assigned duties are required to be trained. In addition, that all personnel were aware of the hazard environment they worked in was an assumption causing an assumed and untrue risk level. When airlines or airports are sending personnel out looking for hazards without guidance, they are accepting a risk beyond their own imagination. 

Identifying hazards is a process and like any other process which includes training and that there is a documented process to identify training requirements so that personnel are competent to perform their duties. An Accountable Executive is responsible for operations and accountable for meeting the regulatory requirements. It only takes a label, or organizational position to be accepted as an accountable executive, without any knowledge of SMS processes. The accountable executives for both airports and airlines have a responsibility to identify hazards prior to assigning personnel in their operations to identify these hazards. 

The task is to conduct a pre-hazard assessment and define the hazard as Safety Critical Areas (SCA) and Safety Critical Functions (SCF). The Safety Critical Function is a sub-category of the Safety Critical Area. It is assumed that any accountable executive has the knowledge and comprehension of their operations to develop their SCA and SCF. When a comprehensive list of SCA and SFC are developed, and personnel trained, they are qualified to go looking for hazards and report how they affect their operational tasks. An airport may assign their SCA to runways, taxiways, aprons, approaches, the runway strip etc, and assign SCF, or hazards that are common within those areas. The same concept goes for airlines, to establish SCA of ground operations, cockpit, cabin etc, and assign SCF to these areas.

Some years ago, I climbed a
tree to take a picture.
There was an inherent
risk by climbing
while the true risk
was waiting below.   

    One question I am often asked is if a pilot or airport person, should         report the same hazard day after day and the answer is no, they             don’t. Hazards which are present daily and regularly are inherent         risks of aviation, or common cause variations and are mitigated             progressively. In addition, knowledge of these risks are learned by         obtaining a pilot license, crew training, company flight training,             airport manger certificate or other operational training. Knowing             what not to report is just as much a part of organizational hazard             training as knowing what to report. This type of training is also             commonly called Judgement Training.

    Operators without a Judgement Training program are operating with     a reactive hazard reporting system. A couple of examples would be        an aircraft leaving the gate may have to navigate different routes            from time to time due to vehicle traffic or oncoming aircraft. These       are hazards, but not expected to be reported. 

    However, if a vehicle moves in an uncomfortable proximity to the       aircraft it becomes a reportable hazard. For airport operations, snow   on  the runway, while still reported as runway surface conditions, is   also a common, or inherent risk in aviation and not to be reported as a   hazard. On the other hand, if the snow is at a rate and quantity require   the airport to close, it becomes a reportable hazard. 

Catalina9