Monday, September 20, 2021

SMS Authority

 SMS Authority

By Catalina9

A Safety Management System plays a role in the organizational charts for both airport and airlines, but without overriding any other regulatory requirements the SMS is an administrative tool rather than a safety improvement tool. Since the SMS being a businesslike approach to safety, poor decision makings are allowed, and losses are acceptable. In addition to other regulations, the regulator must verify that airports and airlines comply with all regulations and not just the SMS regulations. This could create conflicts between the SMS regulations and operational regulations. 

It is a lonely road for an AE to find hidden SMS facts.

The two avenues of a Safety Management System are the regulatory and operations avenues. The regulatory avenue includes oversight, policies, systems, research, development, design, compliance, project solutions leadership motivation, quality control, audits, and quality assurance. The operations side of the SMS are processes, procedures, implementation and maintenance, training, data collection, analyses, review, and communication. Oversight is by the Accountable Executive (AE) and operations is by the SMS Manager. 

The two regulatory requirements to act as the AE are that they have control of financial and human resources that are necessary operations. These requirements are different than roles and responsibilities of an AE, since they are only the authority to act as Accountable Executive. Their roles and responsibilities are defined in the regulations as to be accountable on behalf of an airport authority, a mayor, a city council, a corporation, a business, or a person for meeting the requirements of the regulations. Depending on size and complexity of an airport or airline, an Accountable Executive is responsible for between 250-500 regulations. This responsibility is much greater than the asserted responsibility over financial and human resources.  

 

The roles and responsibilities of an SMS Manager are operational in nature. Their responsibilities under the regulations are defined as being responsible for implementation of a reporting system to ensure the timely collection of information related to hazards, incidents and accidents that may adversely affect safety. Timely collection may be different today than yesterday and may look very different tomorrow. When SMS was first invented, timely delivery was by fax. If someone sends a fax today, their report might not arrive on the SMS Manager’s desk. 

 

Another responsibility is to identify hazards and carry out risk analyses of the hazards. This responsibility is so huge that it is almost impossible to comprehend. Identification of hazards are not defined in the regulations as an opinion, but actually of factual hazards. A hazard identified one day is still a hazard the next day. When hazards are identified an SMS Manager has a responsibility to investigate, analyze and identify the root cause of all hazards, incidents and accidents identified. The regulatory requirement is not to identify the root cause of selective hazards, but to identify the root cause of all hazards. 

 

An effective SMS needs a safety data system to be implemented by electronic or other means. This is another responsibility of the SMS Manager. When this requirement was first implemented a paperformat safety data system was acceptable, but as the SMS evolved it became unmanageable as a paperformat system and electronic databases were used. Over time this system also became obsolete since electronic spreadsheets could be manipulated or corrupted by adding or removing data. There are several SMS cloudbased services available, the comprehensive task is to select one that do not demand control over your Safety Management System. There are only a handful cloudbased data collection tools that let you maintain full control over your own SMS.  

 

This leads us to the next responsibility is that the SMS Manger implements a safety data system to monitor and analyze trends. Monitoring is to maintain regular surveillance over events, and to do this at uniform intervals. Monitoring events does do very little to improve safety. After data is collected it is turned into information to be absorbed by one, or all, of the five senses. When absorbed, information turns into knowledge, which is used to analyze for trends. When trends are known, the SMS Manager has a tool to comprehend interconnected links. This tool is also available to the SMS Manager as a tool to monitor and evaluate the results of corrective actions implemented from the analysis. 


Concerns of the aviation industry may vary with experience.

The most comprehensive responsibility that an SMS Manager has is to monitor the concerns of the civil aviation industry in respect of safety and their perceived effect on an airport or airline. There are several responsibilities applied to this regulatory requirement. The first task is to decide what to monitor, another task is to decide when to monitor, with a third task where to monitor, e.g. locally or globally, the next task is define in details why to monitor, in addition to the regulatory requirement, and who should monitor. Monitoring might not be done by the SMS Manager, but could be assigned to dispatch, flight following or airside maintainer. The final task is to decide how to monitor the aviation industry. 


Other responsibility an SMS Manger has is to determine the adequacy of the training required by the SMS Manager and for personnel assigned duties under the safety management system. A person with any responsibility for an aircraft operating airside at an airport or a person with airside responsibilities are personnel assigned duties under the SMS. This includes both the Accountable Executive and SMS Manger in addition to other workers with roles and responsibilities for the safe operations of an aircraft or airport. 

With all these SMS responsibilities both airline operations, or airside regulations will overrule SMS proactive actions. A requirement at an airport is to maintain obstacle free zones for approach surfaces and transitional surfaces. When an SMS identified that tall trees or construction cranes are almost penetrating these surfaces and should be removed as a precautionary action, the overall decisions in the past were that since these obstructions legally conform, they must not be removed or restricted. The same scenario could be applied to a damaged, but legally conforming engine, a stress-damaged wing that is legally conforming, or the tailstrike damage to Air China 601 accident. If SMS is given its intended regulatory powers by an airline or airport will be documented in how recovery in aviation after a pandemic is given accountability to legally conforming concerns. Both pilots and maintenance crew are experiencing the old effect of being “bushed”.  As an old bush-pilot, I've seen people get "bushed" living in the middle of nowhere for months and they would do unthinkable things. What the global aviation industry must comprehend is that pilots and mechanics are being “bushed” by quarantine and other enforced pandemic demands. Since the regulations is not broad enough to include, or cover this aspect of aviation safety, it becomes the responsibility of the airlines and airports to ensure that SMS is allowed to function as intended and capture every “almost” in aviation. 

 

Catalina9


Monday, September 6, 2021

Exposure

 Exposure

By Catalina9

Exposure in the Safety Management System is an integrated part of a risk assessment and risk analysis. A risk assessment involves several steps and forms the backbone of an overall risk oversight plan. Included in a risk assessment is one or several risk analyses to determine the defining characteristics of each hazard and to assign risk level scores based on the analysis. Key components of a risk analysis are likelihood, severity and exposure. Likelihood is a definition of times between intervals of an active hazard, severity is a defined outcome of the occurrence, and exposure is the variable, defined as common cause variation or special cause variation and a assigned a function, or weight score, between 0 to 1. If the exposure is zero, the hazard does not exist or has been eliminated. When the exposure is one, the impact of a hazard is inevitable.

When common cause variations are treated as special cause variations, the risk analysis has taken the wrong turn at the fork in the road. Common cause variations are integrated in a process, they are necessary for the process and the process would fail if one or more common cause variations were eliminated. An example of common cause variation is ice in clouds and thunderstorms. For ice to form on an aircraft in flight, the air must be cold and contain moisture. Icing conditions frequently occur when moist air is forced upward. As the air rises, it expands and cools. If the air cools to the saturation point, where the temperature equals the dew point, the moisture will condense into clouds or precipitation. For ice to form there must be clouds or precipitation and icing can be most intense near the cloud tops, where the amount of liquid water is often greatest. This part of the cloud has the greatest amount of lifting, cooling, and condensation. Encountering inflight icing in clouds is therefore a common cause variation, while non inflight icing in clouds is a special cause variation.

When applying exposure in a risk analysis the task is to analyse in 3D and measured
in time (hours-minutes-seconds), space (geographical location) and compass (direction). A 3D analysis is to analyse a moving object within the tube itself, rather than from behind, below, above, beside or in front of a moving object. A 3D analysis is the expected view as observed by the pilot at a specific moment in time, location, and direction.

Exposure paints a picture of the past to plan for the future.
The first step when analyzing exposure is to determine if the variation is a common cause variation or a special cause variation. When traveling to or from work, people conduct a mental exposure analysis by leaving at a certain time to avoid the heaviest traffic. In aviation common cause variation analyses are also conducted for arrivals at major airports or during special events. Comprehension of systems is therefore vital to correctly identify the true variation and develop the proper corrective action plan. If encountering inflight icing in clouds was assigned as a special cause variation with a root cause analysis, the analysis would be derailed from the beginning. The analysis could easily take a turn to explain that icing in clouds were not in the forecast. While this might be true, does not make it a special cause variation, since icing in clouds is to be expected anytime an aircraft is flying above freezing level. 

If the freezing level was lower than forecasted still makes it a common cause variation, since this is what the freezing levels do every day. The forecasted freezing level is nothing else but a risk assessed model of what altitude the level might be in the future. Pilots and dispatches often blindfolded accept icing and freezing level computer models, which then could be mistaken for a special cause variation. Level of exposure changes with time, location, and direction of an aircraft. An aircraft on the ground has a zero-exposure level to inflight icing. The exposure level begins when the reach the rotation speed. Inflight icing could be from ice accumulated on the ground and the exposure level for inflight icing is therefore 1,or 100% likelihood, or probability, that the ice will affect aircraft performance. 

One reason for ground de-icing and anti-icing is to reduce the exposure level of inflight icing to an acceptable level and defined as holdover time. Research of anti-ice fluids has determined that the fluid remains effective for a short period of time and when an aircraft is airborne prior to the time expires, the exposure probability, or likelihood, to inflight icing is inconceivable, or times between intervals are imaginary, theoretical, virtual, or fictional.

After it has been determined that a variation is a common cause, the next step is to analyse how the hazard could be exposed, or how the hazard could affect operations. If the hazard is icing in cloud, the analysis shows a likelihood of 1 that flight into known icing will expose the aircraft to inflight icing. The analysis is both a part of the pre-flight planning and inflight operational observations. The severity of icing is determined by several conditions, but for the purpose of icing when entering clouds at a flight level above freezing level, the likelihood of exposure is methodical, planned and dependable, without defining the operational system or processes involved. When analysing flight crew, aircraft and expected level of icing severity, available operational systems play a role. Encountering icing may vary from a level of informational, which is a severity level that is not compatible with another fact or claim of the hazard, to catastrophic which is a severity level where functions, movements, or operations cease to exist, or it could be any level between these two extreme severity levels. Exposure level in SMS is a pre-flight, or pre-task operational tool with actions defined in applicable safety cases.


Special cause variation Beatty NV 1981-03-18
The third step and an analysis of level of exposure to a special cause variation is a totally different approach, since a
special cause variation is unexpected, it is an abnormal condition and a variation that is irrelevant for the process to function as expected. A special cause variation could be a
malfunctioning ITT or Inter Turbine Temperature during takeoff. Special cause variations are excluded from pre-flight planning since they are items covered by other levels of protections. When using the ITT example above, aircraft engines are regularly inspected and found acceptable, or it is removed from the aircraft if unacceptable. When the pilot takes off, the engine is expected to perform as it should without malfunctioning. However, a principle in aviation is to expect the best but to be prepared for the worst. Preparing for the worst at every takeoff is not exposure to an engine failure or other system failures but is a part of an ongoing recurrent training program. Below is an example of how a malfunctioning ITT is identified in a control chart and when this is identified a root cause analysis must be performed. Normally the ITT is running 680°, but one day it was 681°.


This variation did not trigger an incident or ITT exceedance, but it is a variation that is not common within the system itself and must be investigated with a root cause analysis. Exposure levels triggers two actions: The first action is to prepare for common cause variations and the second action is to conduct a root cause analysis of a special cause variation.

Catalina9




SMS Authority

  SMS Authority By Catalina9 A Safety Management System plays a role in the organizational charts for both airport and airlines, but withou...