When Hazards Are Reactive
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|
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.