Saturday, August 20, 2022

The Practical Applications of SMS

The Practical Applications of SMS 

By OffRoadPilots

The Safety Management System (SMS) for aviation is a practical system to lead personnel, manage equipment and validate operational design for improved performance above the safety risk level bar. The bar is always set at an acceptable risk level. This level may vary with size and complexity of an organization, prior experience and accepted practices, risk analysis and justification, or simply by arbitrary lines drawn-in-the-sand. There are no rules within a safety management system of what reasoning to use to establish the level of the safety risk bar. One reason could be that we always did it this way, or another reason could be to do what is least stressful and creating less of a workload.  


There are regulatory requirements for a safety management system to include a safety policy, a process for setting goals and attainment of those goals, a process for identifying hazards and managing the associated risks, a process for training personnel and that they are competent to perform duties, a process for reporting and analyzing hazards, incidents and accidents and for taking corrective actions,  a document containing all SMS processes and a process, a quality assurance program, a process for conducting periodic audits and any additional requirements for the SMS to function as intended. Regulatory requirements are applied to a static operation, where there is no aircraft movement or airside operations. Certificates are issues based on expected performance and maintained based on past performance. A practical application of the SMS comes into play when operations are alive. 


If the SMS seems to be overwhelming and practically unreachable objectives and goals, it is a simple solution to move to the Some-Day-Island. On the Some-Day-Island there is no accountability, no responsibility, the island is isolated, there is unlimited safety, it is a perfect place to make excuses and there are no reasons to get up and work with initiatives. Since the Some-Day-Island is located within a personality and not an actual geo-location, there are some traits that recognizes a person living on this island. They would paint a picture of an elephant in the room that is the cause for all their failures. They see all activities to make changes as useless and waist of time and that there is nothing else to learn, since they already know all that there is to know. A person living on the Some-Day-Island expect their organization, being airline or airport, to be in top-notch condition, but still slumbers on the island hoping that someone else, and often someone they don’t know, will take initiative to get them into the top-notch-condition. Living on the Some-Day-Island is a hazardous place, but it is also the place where everything is played safe.    

 

A misconception often assumed by the Accountable Executive (AE) is that the primary task of an SMS is to complete the check boxes for regulatory compliance. While it is true that the check boxes must be completed for tracking and data-points purposes, this task is incidental to operational tasks preceding the checkbox entries. The primary task is to complete a task that conforms to regulatory requirements. An effective SMS has established regulatory compliance for each individual task within the system. These tasks are monitored, checkboxes completed and by the end of the day their required daily quality control system is completed.

 

The practical application of an SMS are the acceptable practices. An acceptable practice may be a written procedure to adhere to, or an unwritten acceptable practice that has taken form over time as a reliable and practical process. Aerial tankers, waterbomber and forest fires air suppression are examples when unwritten and acceptable practices take over and applied within a safety management system. When SMS takes control, practical application of the SMS becomes paramount. An aerodrome means any area of land, water (including the frozen surface thereof) or other supporting surface used, designed, prepared, equipped or set apart for use either in whole or in part for the arrival, departure, movement or servicing of aircraft and includes any buildings, installations and equipment situated thereon or associated therewith. In layman’s term, an aerodrome is anywhere an aircraft, including drones, operates.


When a waterbomber scoops up water from a lake, that portion of the lake becomes an aerodrome, and the regulations are applicable to operations. Regulations are not just applicable to the flight crew and air navigation, but also to the aerodrome itself. Aerodrome regulations applies in respect of all aerodromes and includes any surface of land or water where an aircraft operates. The operator of an aerodrome, other than a water aerodrome, shall install red flags or red cones along the boundary of an unserviceable movement area.  By this definition a waterbomber scooping up water may use any portion of a lake to pick up water. On the other hand, a heliport servicing a forest fire area, needs to be cleared and delineated.


The airspace above a forest fire is automatically closed and becomes restricted airspace. Only aircraft authorized into the airspace are allowed to enter. Before taking off from, landing at or otherwise operating an aircraft at an aerodrome, the pilot-in-command of the aircraft shall be satisfied that there is no likelihood of collision with another aircraft or a vehicle, and the aerodrome is suitable for the intended operation. When operating out of a lake, there is little or no data available to assess if the aerodrome is suitable. Suitability of the lake becomes an operational, or mental risk analysis task. Prior to the first pickup, the pilot may circle the lake to collect data for the risk analysis. From above any reefs and low grounds are easily identifiable and the task becomes to remember their location to align their approach and runway between the reefs. The second task of the aerodrome risk analysis is to assess both approach and departure ends for snags, hills, or other obstacles. This analysis may be based on prior experience at that particular lake or based on experience from other lakes with similar length and surrounding terrain. A third task of the aerodrome risk analysis is to assess mobile objects, boats, or recreational use of the lake. 

 

With several waterbombers picking up at the same lake, the pilot in command of each aircraft establishes a procedure to pick up at the same area, climbing turn in the same direction after takeoff, and to arrive on final for the next pickup in the same order as their previous arrival. When there are operational changes, the first aircraft to change becomes the lead aircraft and for the others to follow. This is a practical use of the SMS and were established decades before SMS became regulatory required. When looking at SMS as a practical application, the implementation of SMS did not change any operational processes. Any changes were unnecessary self-imposed by operators. 

 

When operating in an area where there are few and far between acceptable lakes for pickups, air tankers are used as the primary tool for forest fires suppression. An air tanker loads up fire retardant at the airport and heads for the fire. These turnarounds could be long and time consuming, but when using large aircraft, such as the DC-10, one load of fire retardant covers a large area. Continuous flying the DC-10 at low altitude is a variation of what the aircraft originally was designed for. The aircraft was designed for long haul transportation at high altitudes. During normal operations there is minimal control movements after takeoff and when established oncourse. Flying the DC-10 as an airtanker is a special cause variation and requires a root cause analysis of the hazard. A hazard does not imply that the operations is unsafe or dangerous, but that the operations is different than what an airline DC-10 Captain is trained for. In addition, the continuous strain of low-level turbulence and maneuvering is also different than the original certification. In 2002 two airtankers, of personal interest, crashed during firefighting operations due to material fatigue and the strain this type of operations puts on the aircraft, and pilots. When practical application of the SMS is applied, special cause variations are analyzed, assessed, and classified by its safety critical area and safety critical function. A practical application of the SMS does not eliminate accidents since it is impossible to predict an accident until the last minute. What a practical application of the SMS does, is to accept that there are inherent risks in aviation, learn from accidents, and apply past experience of how operations went well to build on that knowledge for continuous safety improvements.  

 

 

OffRoadPilots

 

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