Sunday, August 8, 2021

Your Safety Data System

Your Safety Data System

By Catalina 9

The regulations require that an airport or airline operator implement a safety data system, by either electronic or other means, to monitor and analyze trends in hazards, incidents and accidents. Regulations are scalable and paper format as other means is included to monitor and analyze trends. At some of the smaller airports with only one or two persons managing and maintaining the airport the paper format may work for that size and complexity. For airports with three or more workers or larger airports and airlines, it becomes a humongous and labor-intensive task to conform to regulatory compliance by monitoring and analyzing trends using paper documents.

Unless there is tangible action the SMS is only empty words

The Safety Management System (SMS) is more than data point entries and designing graphs. SMS needs to be built up by a safety data system with tangible actions and results. A safety data system must be autonomous, preserve its integrity, it must be flexible and scalable to size and complexity, or tailored to operational needs. In an autonomous safety data system there is task completion, performance reliability and performance analytics. Performance analytics is the engine, or system, that uncovers insights and reveals hidden value to define new, targeted learning interventions. The result is learning spend that helps aviation safety achieve key objectives.

A requirement for a safety data system is that it acts as an inhibitor against corruption, subjectivity or bias. Corruption is when a system may, intentionally or unintentionally, being altered causing a different outcome. Subjectivity is when someone has a personal interest, or an agenda to manipulate the outcome of data collected, or of facts discovered. Bias is prejudice of outcome based on an assumption or an opinion about someone, or something, simply based on past history. The differences between corruption, subjectivity and bias, is that corruption could be an error, mistake or intentional action, subjectivity is personal to the outcome where facts are ignored, and bias is a decision made prior to an investigation or fact finding mission. A safety data system must prevent these opportunities to occur within its system.
A paper format safety data system is inherent corrupted by self-degradation over time. A document may be legible one year but totally unreadable the next year. Paper documents can also be altered or lost. In an operation with two workers only, such as the Accountable Executive and Airport Manager/ SMS Manager, a paper format may work since any changes are traced to one or the other. If there are three workers, a conflict of interest may arise. Paper documents is an available option under the regulation to accommodate for the simplest common denominator which is one aircraft and one person, or one airport and one person.

Electronic spreadsheets is an option often used by airlines and airport operator as their safety data system. Just as a paper system, an electronic spreadsheet system may also be corrupted, subjective or biased to the facts. A safety data system that in not corrupted, subjective or bias starts with the SMS safety policy. An effective Safety Policy is a tool to manage corruption, subjectivity or bias and must be tailored to the organization so all personnel can recognize accountability, accept accountability for the policy and take ownership of it. Without ownership of the Safety Policy, the policy is an ineffective tool and in itself a hazard to safety.

When there is no accountability to the Safety Policy it becomes more important to adhere to the text in the policy rather than the intent of safety in operations. When the text itself is paramount in the decision-making process, a grammatical error has in the past become the determining factor for a regulatory SMS finding. When selecting a safety data system, the two most important functions to consider are the probability of file deletion, or alternation and the simplicity of reporting. In its simplest form an SMS report should accept a submission with one or two pictures only. A system where files can be deleted by an operator does not preserve the integrity of the system. Files must remain in the safety data system for as long as they are applicable to operations, or personnel, at which time they may be archived, but still available for retrieval. An example would be the Canadian CADORS files for an airport. The airport may analyze CADORS for the past five years, but after 5 years and 1 month, the 1 month may be archived.

If advertising does not work, social media does not affect safety in aviation

CADORS are as much a part of the data collection system as any other report. If CADORS are excluded from the hazard register, an airline or airport operator is operating with a corrupt safety data system and a skewed analysis. Public complaints are also a part of the hazard register, since public opinions affects how the regulator views an airline or airport. As an example, it was not long ago that the regulator revoked a certificate with unsubstantiated findings, or findings added after the inspection, due to public opinion of the operator. Another example is how the public opinion affected a CADORS to be biased against a smaller operator and gave an excuse for the airline’s on-time departure record. The excuse why the airliner entered the runway for backtracking when the smaller aircraft was on base leg was that they needed a VFR departure since the IFR clearance was going to take a while. When the smaller aircraft turned onto final, the taxiing aircraft was ¾ of the way down the runway for takeoff and declared that they had vacated the active runway when they were parked in the turnaround bay. An unbiased CADORS would have stated the facts, which was that a small aircraft had to make an avoidance maneuver due to an airliner backtracking on an active runway. There are several examples of how public opinions or social media affects the CADORS. For an airport or airline to preserve their integrity and fight for their regulatory conformance, CADORS must be investigated and filed in their hazard register. Another short CADORS example shows how social media or public opinions make it into the CADORS [redacted]: An aircraft flew directly overhead an airport [small private airport] northbound, at an altitude of approximately 1000 feet above ground level and a rate of 151 knots ground speed without making any radio calls. Video evidence is available.  

Your Safety Data System must be integrated as a winning combination of your quality control and quality assurance system for incremental safety improvements. SiteDocs is a winning safety data collection tool. Data collected must be preserved and include reports that are both favorable, and unfavorable for your operations. A Safety Data System is more than just collecting and filing reports, it is a tool for the Accountable Executive to learn and comprehend safety in operations and review how lessons learned are derived from the Safety Policy. 



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