Roles Of An SMS Manager
By OffRoadPilots
A safety management system (SMS) is required for an applicant for an air operator certificate or an applicant for an airport certificate. An applicant is any person or entity applying for one of the certificates. A certificate is issued to the applicant, who becomes the certificate holder and the operator upon receiving the certificate. An applicant may choose to assign the role as an operator and certificate holder (CH) to any person or entity. An operator in respect of an airport is the certificate holder of the appropriate aviation document that is in force.
The appointment of an accountable executive (AE) and having an operational SMS in place is required for an applicant of an aviation document to establish their compliance record prior to issuing the certificate. An airport certificate is issued to an applicant authorizing the applicant to operate an aerodrome as an airport if the proposed airport operations manual is approved by the regulator, and the airport standards are met. An airport certificate is an operations certificate issued to the airport land parcel, and an airport manager (APM) is required to manage operational tasks, since the parcel itself in not capable of these tasks. This coordination between a certificate and certificate holder is unique since other aviation documents has a person attached to operations. There is no aviation document, certificate, or license required to hold a position as an airport manager. However, the airport manager position becomes a regulated position when the APM is the certificate holder, with regulatory responsibilities to appoint the AE to be responsible on behalf of the certificate holder, with regulatory responsibilities to maintain a safety management system, and regulatory responsibility to appoint a person to manage the safety management system. In an organizational hierarchy, the accountable executive, the SMS manager, and the airport manager, reports directly and independently to the certificate holder. At airports where the airport manager maintains the role of a certificate holder, there could be a conflict of interest between the APM as certificate holder and the APM in the non-regulated airport operations position.
The role of an accountable executive is operational oversight of the SMS and its daily quality control systems, to be responsible for operations, and accountable on behalf of the certificate holder for meeting the requirements of the regulations. The AE reports to the certificate holder. The role of the person managing the safety management system is operational control of the SMS, and to be responsibilities for processes to remain in conformity with regulatory requirements. The SMS manager reports to the certificate holder. The role of the certificate holder is to facilitate for their systems to operate with support from the safety management system.
The quality assurance program is a component of a safety management system, with a responsibility of the certificate holder to maintain the program. At several airports, the person holding their certificate is the airport manager and is therefore the person responsible for the program. A program is a set of related measures or activities with a particular long-term aim. A quality assurance program includes a process for periodic audits of activities authorized under a certificate and audits for cause of those activities. For cause audits are audits conducted for various compelling reasons. An airport manager, as the certificate holder, must establish the audit process, e.g. audit checklists, and the frequency of audits, not to exceed beyond three years from their firs audit. There is no regulated position as a quality assurance manager, and the certificate holder may therefore assign audit duties to any preferred person or organization, except these duties must be fulfilled by persons who are not responsible for carrying out those tasks or activities which are being audited. A prerequisite for a quality assurance program is an SMS enterprise’s daily quality control program. Without a quality control program an audit under the quality assurance program must fail all audit line-items, since compliance are at random as opposed to compliance due to oversight and management.
The difference is that QA is process oriented and QC is product or service oriented. Testing for quality does not assuring quality, it is process control that assures desired outcomes. Quality assurance oversight is to establish processes to identify patterns caused by processes and maintain control of those processes.
A quality assurance program includes a followup inspection of corrective action plans (CAP), and current controls implemented. The implementation of corrective actions are changes inserted into processes, or design and develop new processes to establish a regulatory compliant outcome. Regulatory compliance is a static mode of operations, and actual compliance is unknown until the process is put in place by workers. These processes must include a control measure to establish if they actually function and produces the expected outcome of the CAP.
The roles of a person managing the safety management system includes responsibilities to the certificate holder, accountable executive, and the quality assurance program. Their first responsibility is to the accountable executive since the AE is the person responsible for operations and accountable on behalf of the certificate holder for meeting the requirements of the regulations. Their second responsibility is to the certificate holder, since the CH must ensure that the person managing the safety management system performs their duties required by the safety management system. Their third responsibility is to the quality assurance program since the program requires daily quality control processes to perform its audit functions. When these three lines of responsibility are opened up, the person managing the safety management system may design and develop their duties to fulfill their responsibilities.
There are several regulated responsibilities for an SMS manager, but their most important and crucial responsibility to a safety management system is not defined in the regulations. Their responsibility to an SMS is to find, assign and document patterns within each system of human factors, organizational factors, supervision factors and environmental factors.
Some of the responsibilities for the person managing the safety management system is to implement a reporting system to ensure the timely collection of information related to hazards, incidents and accidents that may adversely affect safety. An accident or incident have already adversely affected aviation safety and a reporting system must include these two items. Hazards are defined differently from person to person since hazards are opinions and an event has not occurred. References to future possible events are based on comprehension of systems and opinions of interpretations. An SMS should include an unrestricted hazard submission clause. Timely delivery of these reports is also an opinion and how an SMS enterprise communicate internally. Today, and with access to electronic data bases, a simple cloudbased SMS program that meets the regulatory requirements is SiteDocs and accessible for review by emailing offroadpilots@gmail.com.
An SMS manager must identify hazards and carry out risk management analyses of those hazards. Processes for identifying hazards may take different shape and turns, but the most commonly used process is for workers to report what they interpret as a hazard. Each regulatory non-compliance is a hazard, and hazards are therefore identified in line-item audits. Without a line-item audit of regulatory requirements, the audit may be a biased review of an SMS enterprise. Hazard identification process may also be from publicly available aviation hazards, incidents and accidents data, and applied as applicable as hazard for an SMS enterprise. Whan carrying out risk management analysis it is crucial that the SMS manager identify the scope and authority of the hazard. A hazard may be detrimental to aviation safety, but changes must be within the authority of an SMS manger and solutions may be different than making changes to a hazardous environment.
The role of an SMS manager is to investigate, analyze and identify the cause or probable cause of all hazards, incidents and accidents. Identifying a cause of all hazards is an enormous task. Identifying probable cause is simple since these are opinion statements without support in data or facts. When identifying a probable cause, only one event or hazard is needed to establish the cause. When identifying a cause, or root cause of a hazard, a system analysis is required to ensure that all supporting statements and justifications are referenced with data and facts.
Monitoring trends, or patterns is the responsibility of an SMS manager. Since regulations were written in the onset of common access to electronic devices, paper trending was acceptable. However, paper trending of patterns is very labor intensive and the use of electronic SMS cloud based programs should be the preferred process. Data must be statistically analyzed in a statistical process control program to avoid the trap of overcontrolling processes.
A safety management system is a businesslike approach to safety and is an excellent to for marketing of your airline or airport. A responsibility of an SMS manager is to monitor the concerns of the civil aviation industry in respect of safety and their perceived effect on the holder of the certificate. Prospects, clients or customers are highly sensitive to perceived safety levels of your organization. Social media places an important role on perceived risks, or safety levels by rating your organization with approval stars. Unless the full screen, normally 5 stars, is filled, a prospect moves on to the next service or goods supplier. In addition to ratings, your SMS enterprise must be placed Above the Fold, as it is in the Daily Rundown System, for prospects to learn about your existence.
There are several other regulated responsibilities of an SMS manger, and everything an SMS manger does must link to the AE as competent to maintain regulatory compliance, it must link to the CH to facilitate for regulatory compliance, and it must link to the QA manager with a daily quality control system.
OffRoadPilots
No comments:
Post a Comment