Communicating or Transmitting SMS
Another great post from CatalinaNJB
There is an expectation that for an SMS program to conform
to regulatory compliance the enterprise must have in place a process for safety
authorities, responsibilities and accountabilities are transmitted to all personnel.
If this process is not in place the enterprise a non-compliance System Finding
under Canadian Aviation Regulation (CARs) 107.02 may be issued to the
operator. CARs 107.02 is system
compliance regulation, or a design regulations for a regulatory compliant
Safety Management System. When the design of the SMS is regulatory compliant,
then the processes executing the SMS design must also conform to regulatory
compliance. In other words, these two compliance components are the design
component and the operations component.
For operators in Canada the design requirements are found in CARs
107.02, for both airlines and airports. The operations requirements are found
in CARs 705.151 and CARs 302.500 respectively.
 |
| The manufacturing of this chain complies with the requirement to produce a chain |
When job descriptions are
transmitted to personnel, in accordance with this expectation, the message may
or may not reach the intended personnel. Transmitting is a one-way
communication and it does not specific direct the communication to the intended
recipient. If the communication only reach a recipient who is in a
non-management position, this information may be overwhelming since it does not
conform to the expectation of the person’s job description. Or, if the
information transmitted reach senior management only, their response may be
incorrect for their job performance expectations. This expectation that “Safety Authorities, Responsibilities And
Accountabilities Are Transmitted To All Personnel” may be compliant to the
expectation itself and also compliant with the regulatory requirements under
operations. However, by following the “letter of the sentence” only there are
other SMS required tasks that are missed and not being performed to acceptable
levels. Since the interpretation of information became a conflict with the
position of the intended audience there is a failure of the system.
The process in this example is functioning as expected, but
the response to communication was in conflict to the job position established
in the organization chart. The effect caused by lack of response was not just
that the information was transmitted to incorrect positions and the job not
done, but also that by not performing as the expectation intended, other parts
of the SMS was crumbling and the system itself did not function.
 |
|
a process could be Destroying and crumble a system.
|
It doesn’t matter how
strong and well maintained 99 links in a chain are when there is one link that
breaks. When the link is broken, there is a broken process somewhere that must
be identified. Repairing the process by replacing the old chain with a new
chain may not necessary work well, since this does not consider the process. It
could be that this link in the chain was being grinded now and then by a
grinding tool required for the process to function. Replacing the old with a
new is an assumption that there is a manufacturing flaw without analyzing the
operational processes. Then the next time it happens everybody is just as
surprised as the 10 previous times. Often, the next step is to change chain
manufacturer, or fire a person who authorized the supplier.
By not conforming to the intent of this expectation that “Safety Authorities, Responsibilities And
Accountabilities Are Transmitted To All Personnel”, the system itself may
fail and everyone is as surprised as the first time when it failed.
CatalinaNJB
