Who Is Running Your SMS?
With the implementation of a Safety Management System for airports and airlines came the SMS expectations. These expectations are opinion-based of what actions are required by the operators to conform to regulatory compliance. These expectations are not expectations for airports or airlines to manage operational safety, since they do not address safety. One of these expectations is that there is a safety policy in place that is followed and understood. It’s a simple task to determine if the policy exists, but a bit more difficult to determine if the policy is followed. It’s impossible to determine as a fact that the safety policy is understood. Based upon what this safety policy expectation requires, there are no operators currently conforming to regulatory compliance. Before they even got started with the rest of their SMS, they had all failed the safety policy regulatory requirement.
|Wishes are the expectations of random flow of events.|
Within a Safety Management System intent doesn’t matter. The intent to conform to regulatory requirement, intent to be safe or intent to understand the safety policy is irrelevant. It is the behavior with accountability that matters within an SMS. This goes back to who is running your SMS. Many of us would say it’s the Accountable Executive or the SMS Manager. Well, that would be nice if that was true, but it isn’t. Both these SMS positions are incidental to their real jobs in the organization. This becomes apparent in the Regulations itself, where the Operations Manager does not have any responsibilities pursuant to the SMS system or Quality Assurance Program unless a finding is reported to that person. Operations Managers are not required to action any findings of which they have not received a report of. This itself makes their SMS responsibilities incidental to their Ops Manager responsibilities. An Ops Manager may witness an event, hazard or regulatory finding, but is not required to take any action until after they have received a report.
|You can't eat your cake and have it too!|
The Accountable Executive is in the same boat. The only requirement for the AE is for that person to have control of the financial and human resources that are necessary for the activities and operations authorized under the certificate. By the regulations, the AE position is incidental to their real job in the organization. The primary job function of the AE is to first be the CEO, or President of the company and to ensure the shareholders or owners meet their expected return on investment. It is interesting how the regulations don’t recognize a regulated SMS position, but still expects the SMS to function effectively.
Without a regulated position there is nobody running your SMS. There are no process analysis qualifications requirements to accept any of these positions and the only requirement is that they are willing to accept. Now there are two positions with personnel who make incomplete regulatory and safety decisions. When a system is run incomplete and the loops are not closed, the SMS system becomes its worst enemy. That the AE and SMS Manager don’t comprehend their own SMS is demonstrated by their responses to the Regulator’s findings. They don’t question their findings but folds to the authority with one goal in mind to develop corrective action plans that pleases the Regulator. Safety in operations have become a challenge with the Regulator micromanaging third-parties [airport or airline] Safety Management System. Nobody is running your SMS, but the AE and SMS Manager still expect miracles or safety improvements.
|A duck's perspective of a safety process analysis|
The only option to operate an effective SMS, and to take the load of your mind is to hire qualified SMS personnel, who comprehend your SMS. Just like your organization accepts accountability by seeking advice from a lawyer, accountant, medical personnel, the dentist, maintenance personnel, pilot or the janitor; The time is now for your organization to accept accountability and run your SMS.