SMS Mom Pop Store

 SMS Mom Pop Store

By OffRoadPilots

The term mom-and-pop describes the small business entities that are independent

or family-owned, usually operates in a single location and they provide

personalized products and services to the local community. They operate with

limited capital investment, they handle small business volumes and run with

minimal numbers of employees. Typically, the shops are not franchised and only

operate at single locations. Therefore, their customers are mostly from local

communities, and products and services are more personalized. So, what does

mom-and-pop stores have in common with an aviation safety management system

(SMS)? What they have in common is that there is no value to their existence since

they do not generate measurable short-term gain.

A safety management system

does not provide accident-

free security today, and mom-

and-pop stores does not

generate short-term savings

today. A safety management

system is process control of

service provided, and a mom-

and-pop store is process

control of products and

services. SMS is not instant

gratification of process outcome, and a mom-and-pop store is not instant

gratification in short term savings. Over time, a mom-and-pop store is a long-term

money saver, while shopping at a super centers is a long-term cash saving illusion.

The reason mom-and-pop stores are in decline, is that they charge less in the long-

term, while customers spend more cash in super centers. It’s simple, someone, e.g.

customers, are paying for the super centers to be build and operated. When

purchasing at mom-and-pop stores, goods and products are used, while when

shopping large quantity as lower unit price at super centers, a large percentage is

wasted, and there is no savings in waste. The savings, when purchase at a mom-and-pop store is not in the unit price but is in what they don’t waste. An SMS is not

the lack of accidents, but what is not wasted on unknown processes.

Successful businesses keep a low inventory of products being held for sale. It is a

capital loss to keep a larger volume than what is expected to sell within a specified

time period. Large super complexes transfer their capital loss risk to customers by

offering lower unit prices with larger volume purchases required. Large super

centers have one definite purpose, which is to increase revenue and reduce losses.

A mom-and-pop store becomes an inventory storage location for customers,

where the store carries the capital losses of keeping products held for sale. 

They offset these loses to some degree by higher unit sales prices than super centers

offer, but their customers still reduce their waste products and losses. At a mom-

and-pop store it is also possible to purchase special ordered items, while

customers is required to purchase what is sold at super centers. Principles of a

successful SMS are no different than the principles of a mom-and-pop store.

However, SMS enterprises are falling into a trap to delegate control of their SMS to

larger third-party organizations. A third-party SMS organization transfer their

hazards to individual SMS enterprises, and are without accountability to

operational processes.  Hiring specialized consultants and SMS experts are necessary for SMS enterprises and is also a regulatory requirement for the triennial audit, but these consultants do not assert micromanagement control of the SMS.

The safety management system has developed into a super complex in safety that

very few comprehend. Large organizations set the stage of what an SMS must look

like and demanding the one-fit-all principle. Large organizations are conducting

comprehensive audits, and anyone who pass separate level are incorporated as

members with a compliance certification. SMS has become a system where the

focus for airlines and airports is to receive the highest possible certification and

remain in good standing with the auditor. What is excluded are how individual

airlines and airports operate with process that goes right day in and day out. SMS

enterprise receive a rating level of future expectations based on historical records

and regulatory compliance. While historical records are key performanceindicators are learning tools, they are incapable of providing future data for the

next day, next month or for the coming years.

Every SMS enterprise are

their own mom-and-pop

store. Whichever way an SMS

enterprise wish to look at it,

whatever recognition they are

longing for, or what group

and organization they belong

to, there are no competition

between SMS enterprises,

and they are still their own

independent and unique

mom-and-pop SMS store.

There are no two airports that are alike, and no two airlines with identical operations, but still, cloned process templates are applied to individual airports and airlines. An SMS cloudbased program with standardized requirements, is only applicable to regulatory requirements, which are operating in a static environment. A static environment is where a set of conditions, events, and surroundings that don’t change. In theory, a static environment doesn’t offer new or surprising elements, and does not adapt to operational processes. Operational processes must adapt to the static environment or conform to regulatory requirements. A static environment is any system that is intended to remain unchanged by users and administrators. The goal is to prevent or at least reduce the possibility of changes that could result in reduced security or functional operation. Each SMS enterprises must adapt and create their own unique

processes that conforms to regulatory requirements.

There is a difference between regulatory compliance and operational compliance.

Regulatory compliance is in a static environment, and operational compliance is in

a dynamic environment. An example of a regulatory environment is for an airport

operator to have a winter maintenance plan. A winter maintenance plan is

required by the regulations to be developed by the operator after consultations

with a representative sample of the air operators that use the airport.

In a regulatory environment

an airport operator invites

air operators to the

meeting, establishes an

agenda, and keeps detailed

minutes. An airport operator

may farm out the task, or

clone the tasks when

developing processes, but at

this point, there are no

actions initiated for the

airport operator to establish

operational compliance. The next step is for an airport operator to build processes that conform to regulatory requirements. Prior to the completion of processes, an

airport operator is in compliance with the static portion of regulatory requirements but remain in non-compliance with operational performance compliance until the process itself is fully completed. This delay, or gap, is the practical compliance gap.

A winter maintenance manual could be placed on the shelf and an airport operator

would still conform to regulatory requirements to have a winter maintenance plan.

Airports of similar size and complexity may have cloned winter maintenance plans

for regulatory compliance, but their regulatory conforming operational processes

are different based on services provided by the airport operator.

Just as a mom-and-pop store, each airport operator tailor their operations to the

needs of their customers, as opposed to demanding that air operators comply with

established services which suits the airport operator. Aprons, taxiways and

runways are different based on aircraft group number, and wingspan, tail height,

or approach speed. Airports tailor their operations to standard visibility, reduced visibility, or low visibility operations, based on an air operator’s need. A governing factor for airline requirements is aircraft size and distances between departure and arrival airports.

Airports of similar size and

complexity may offer

different services based on

the number of passengers

that are emplaned and the

number of passengers that

are deplaned at the airport.

Two independent airport may

both provide operational

service with a 9,000 FT

runway but may provide

different services based on

number of passengers. One

airport may provide a runway end safety area service, while the other airport decline to provide that service. Both airports are regulatory compliant in a static

environment since one airport has a higher number of passengers than the other, but their different level of service may cause airline operators to prefer the airport with a runway end safety area. In the same manner as mom-and-pop stores, different airports offer different services, but they cater to customers’ needs as opposed to demand that airlines use their airport because it is there.

An airport operator is required to maintain a regulatory compliant safety

management system (SMS) but is also required to maintain operational processes

which conforms to regulatory compliance. These are two distinct and separate

compliance requirements, since one is the regulatory static environment, and the

other is the operational dynamic environment. A regulatory compliant SMS manual

may be placed on the shelf and maintain its regulatory compliance status.

However, an airport operator remains within the regulatory compliance gap until

each operational process are completed with an outcome conforming to regulatory requirements. An operational process may be required to be performed

hourly, daily, weekly, monthly, or annually, which is dependent on services

provided by the airport operator.

Before taking off from, landing at or otherwise operating an aircraft at an

aerodrome, the pilot-in-command (PIC) of the aircraft shall be satisfied that there

is no likelihood of collision with another aircraft or a vehicle, and the aerodrome is

suitable for the intended operation. This regulatory requirement is applicable to

the pilot-in-command of an aircraft, but since an airport operator is required to

comply with the SMS regulations, it becomes a responsibility of an airport operator

to facilitate a level of service for the pilot-in-command to remain in compliance. A

rule of thumb for compliance with the SMS regulations, is when a requirement is

not stated in a regulation, that exactly the reason why an airport operator, as an

SMS enterprise, must develop their own processes founded in their safety policy.

Juts at the mom-and-pop stores providing individual service for customers, airport

operators have an opportunity to establish a level of service to assist pilots to

comply with their operational judgement requirement.

A safety management system includes a safety management plan, and the safety

management plan includes a safety policy, roles and responsibilities, performance

goals, a policy for reporting hazards, incidents and accidents, a policy under which

immunity from disciplinary action is granted, and a process for reviewing the safety

management. SMS requirements are unimaginable opportunities for an airport

operator to provide exceptional services to the airline and aviation industry. An

unwritten safety policy is a blank page to be filled with whatever an airport

operator decides, and include a non-punitive policy, roles and responsibilities, SMS

review and reporting. A safety policy may be closed for regulatory compliance, but

operational compliance are airport specific processes.

The savings when purchasing from a mom-and-pop store are reduction of waste

compared to purchasing large quantities at super complexes. A large jar of pickles

may come at a lower unit price at a super complex store, but when accounting for

the waste, the unit price is higher. Let’s say a large jar holds 50 pickles, while a mom-and-pop store jar holds 10 pickles. The unit price for 50 is 20 cents, while the

unit price for 10 is 50 cents. At first the 20 cents deal feels better. When

considering the waste, which are the number of pickles discarded plus pickles

consumed just because they are there. There will always be waste, and waste

often goes unnoticed and is not accounted for. With a new waste-calculation the

lower unit price at the end of the day cost a consumer five times more.

SMS waste are process deviations from expected outcome, or time spent on

unknown processes due to unfamiliar expectations. Cloned, and one-fits-all SMS

processes are encouraging SMS waste by enforcing expectations that are

unfamiliar to SMS operators. Within a mom-and-pop SMS, operational processes

are applied to regulatory requirements, as opposed to regulatory requirements

forcing operational changes. Mom-and-pop SMS also maintain a low inventory by

capturing drift, moving process back on the correct path, and spend minimum time

on irrelevant processes.

OffRoadPilots

Do As I Say And Not As I Do

Do As I Say And Not As I Do

By OffRoadPilots

Do as I say, and not as I do is a common management system within airlines and

airport operators, and it is their definite purpose to set the stage for an

accountable executive (AE) to use ultimate powers at their own discretion. 

The safety management

system (SMS) regulations

are set up for one person to

make the final decision. This

is not wrong, incorrect, or

bad, but safety in aviation

has not yet evolved into the

concept of SMS but is still

operating in the pre-SMS

era where safety was used

as an emotional tool to

design corrective action

plans. Cultural change is

time-consuming, and it could take a generation before SMS has fully evolved. In the meantime, accountable executives will continue to make emotional safety

decisions. The regulator is onboard with this, and it does not help the aviation industry to evolve into a successful SMS, that regulatory inspection focuses on other than SMS assessments. It was not long ago that the regulator admitted not to have fundings for full SMS assessments of operators. At one airport, the only inspection conducted by the regulator the last three years was a wildlife

inspection, which only inspected if there was a perimeter wildlife fence, if

birdstrike reported, and if the wildlife manual was reviewed within two years.

Anyone can pass this inspection with flying colors.

The role of accountable executive is to be accountable to safety and to lead an

airport or airline in aviation safety for continuous safety improvements by

maintaining a viable safety management system. An accountable executive is the final authority over operations authorized to be conducted under the certificate.

An AE controls the financial resources required for the operations to be conducted

under the certificates, and an AE controls the human resources required for the

operations authorized to be conducted under the certificates. An AE is responsible

for designating sufficient management personnel for acceptable safety

performance, for effective operations under the SMS and to facilitate hazard

identification and safety risk assessments. An AE is also the authority of definitions,

and in the event of discrepancies within the text of the safety management system

manual, the accountable executive is authority on interpretation. An AE regularly

review the safety policy to ensure it remains relevant appropriate to the

certificates, and an AE regularly review the safety performance assessment of the

organization and direct actions necessary to address substandard safety

performance in accordance with the regulations for continuous safety

improvements.

Just as a CEO of a corporation may reject an accountant’s recommendation for tax-

filing, an AE may reject a recommendation from the risk management expert, or

the SMS manager. Rejecting an accountant’s recommendation has consequences,

while rejecting an SMS manger’s recommendation does not. An AE may at

anytime, and without cause, reject a recommendation and issue a directive of the

accountable executive. When an accountable executive rejects a control action or

reject the assigned risk level of a system analysis, it is not within their SMS

authority to demand that it is the SMS manager who does the changes. An SMS

manger is appointed by the certificate holder, and this would be intentional

manipulation of a risk analysis if specific outcomes were demanded. On the other

hand, there are often other operational tools available for an AE to intimidate the

SMS manger to make changes. Intimidations are never documented and did

therefore not happen. It is the prerogative of an AE to use the “Do as I say, and not

as I do” principle. An acceptable method is for an AE to conduct their own risk

analysis, or system analysis and sign their own assessment as the accepted control

action or risk level of a system analysis.

An AE directive is when, in

the opinion of the AE, there

is substandard safety

performance. Public

relations and customer

service may be an integrated

part of safety performance

and the AE may apply

different data inputs for an

analysis. In organizations,

being an airport or airline,

the SMS manager is often

the person responsible to maintain a positive customer relationship. A customer relationship may be terminated should an SMS manager oppose to comply with a

third-party, or customer’s risk assessment opinions. An AE may assess the safety

risk level from a different point of view than the SMS manager and issues an AE

directive to satisfy their customers.

When SMS was implemented with the four-year phase-in exemption, the

expectation was that it would take 12-15 years before SMS was fully accepted and

evolved into its definite purpose. Over the following years SMS was misunderstood

with large groups of opposition. SMS was also assigned blame for accidents, and

for future accidents that had not happened yet.

A 2013 survey of Canada’s aviation inspectors shows they are increasingly

concerned about aviation safety because of Transport Canada rules that leave

responsibility for setting acceptable levels of risk up to the airlines. The survey,

conducted by Abacus Data on behalf of the Canadian Federal Pilots Association

(CFPA), indicates 67 per cent of Canadian aviation inspectors believe the current

system increases the risk of a major aviation accident, up from 61 per cent in 2007.

It should be noted at this point the CFPA, has had a record of opposing SMS for the

start. They are the major critics of the SMS approach. A similar survey in 2007

found 74 per cent of inspectors expected a major aviation accident or incident in

Issuance of a directive is intended for a leader.the near future. Now, 84 per cent of inspects expect such an accident. 

This survey was set up for the SMS to fail. Ten years later, there are zero reports that the

safety management system was the root cause of any aviation accident.

On 4 March 2019, an aircraft was attempting to land off an ILS approach in

procedure-minima weather conditions flew an unsuccessful first approach and a

second in similar conditions which ended in a crash landing abeam the intended

landing runway substantially damaging the aircraft. The accident was attributed to

the crew decision to continue below the applicable minima without acquiring the

required visual reference and noted that the ILS localiser had not been aligned

with the runway extended centreline and that a recent crew report of this fault

had not been promptly passed to the same Operator. Three days after the

accident, a flight inspection of the runway ILS confirmed that the LOC signal was

out of tolerance by about 200 feet to the right of course. The depth of

accumulated snow around the LOC signal transmitter was estimated at between 2

feet and 5 feet in the area of the LOC signal transmitter. After this snow had been

removed, another inspection found that both LOC and GS signals were within the

required tolerances and the ILS was returned to service. With an airport SMS, the

airport at a minimum had process tools available for snow removal. It is not the

SMS causing accidents, it is the lack of using available tools.

Safety accountability is a safety culture for personnel with roles or responsibilities

under the safety management system. All personnel are accountable within their

job function, job description, or job performance are accountable to safety and the

safety management system.

An airport operator needs to design and develop airside operations plans to

establish operational processes. There might not be a regulatory requirement to

clear snow by the ILS antenna, which then become the reason why an airport

operator needs to take on that accountability. A precision approach path indicator

(PAPI) is a visual guidance system to the runway. There is guidance material for

PAPI maintenance, and there is a standard requirement for a preventive

maintenance program in order to prevent a failure or degradation of` facilities andsystems. A preventive maintenance program may not directly specify ILS antenna

maintenance, but when reviewing one maintenance item, the airport also must

review other facilities requiring maintenance. Airside operations of facilities

without guidance material, is no different than developing a corrective action plan

after an identified root cause. When conducting a root cause analysis, the problem

must be defined, and assigned to a system, process, procedure or acceptable work

practice within human factors, organizational factors, supervision factors or

environmental factors. An airport operator must action airside facilities in the

same way as a root cause analysis and develop a corrective action plan, or an

airside operations plan for that facility. An AE may have reference statements in

their SMS policy to the matter but excluding it from operational accountability.

Airside operations plans are also designed corrective action plans for airside

findings and may only require minor adjustment to make finding corrections.

A system analysis is required

prior to changes affecting

the SMS, operations, or

acceptable work practices. A

system analysis process is to

establish the context.

Establishing the context is to

understand the safety

performance objectives of

the system, operations, or

SMS. For system impacts,

and to analyze risk controls developed under a safety risk management system

(SRM) and review the system analysis conducted under SRM. Included in the

system analysis is to identify the objective of the analysis. The objective is to

analyze safety performance of a system, of an operation, and the SMS itself. Data

must be secured appropriately. Securing data is the framework for data sources of

internal reports, external reports, incidents and accidents reports prepared

internally, or by TSB, daily occurrence reports, internal surveys, onsite

observations, newspapers and other information sources or publicly available data information sources. Data needed may be already on hand, or additional data-

gathering may be needed, such as conducting a special audit with focus on a

specific problems. An appropriate data analysis method must be selected. Data is

entered into a spreadsheet and processes analyzed in a Statistical Process Control

(SPC) software. An effective SPC software is SPCforExcel. Data is compared to other

data, including routine reporting data compared to unplanned event data. Data is

collected from both airline or airport operations as it relates to the system analysis,

including respective subdepartments or third-party contractors. Third-party

contractors are included since they perform tasks on behalf of the AE and affect

the perception of oversight by the accountable executive.

The SMS manger conducts the system analysis in cooperation with associate

departments and make recommendations to the accountable executive. An

accountable executive should not be a part of the system analysis team since the

AE is the final authority, and to preserve the integrity of the analysis. As the final

authority the AE may accept or reject the analysis. Conventional wisdom and

acceptable practices at the AE level, is to allocate errors to persons. The root cause

may incorrectly be assigned to compliance failure, and as a tool to prevent further

occurrences of error and omissions, enforcement statements directed to

personnel are published. What is missing in this equation is that human errors are

symptoms, or an incomplete level in the analysis, of human factors, organizational

factors, supervision factors or environmental factors, which may be assigned as

root cause.

As a virtual example an accountable executive may issue statements to enforce

compliance with “Do as I say, and not as I do”. Such statements may include that

multiple requests have been sent to attain details regarding an accident, or a

hazard, that the AE as attained no feedback or updates, nor has an SMS manager

attempted to contact the AE and ignored messages. Such behavior is a deviation

from expectations and portrays an image identifying that defining a root cause and

mitigation are not important, and nor is safety within the safety department

important. There is a significant lack in professional ethic and has only gotten

worse.

A safety policy, signed by the

accountable executive may

state that the safety

commitment is to maintain a

fully functional safety

management system with

continuous improvements of

the level of safety throughout the organization and fulfill safety goals andobjective. When intimidating statements are published an SMS enterprise is on a path drifting away from a fully functional SMS. However, since the regulator does not conduct complete SMS assessment inspections, and operators are accident- free, these enforcement statements are hidden within the bureaucracy of an SMS enterprise. Do as I say, [by actions and intimidation] and not as I do [by the text in the SMS policy] is an effective AE oversight tool. By random chance this type of

oversight management does not lead to accidents.

OffRoadPilots