Remote SMS Manager

 Remote SMS Manager

By OffRoadPilots

The person managing the SMS (SMS Manager) for an airline or airport has more opportunities to positively affect safety processes in an organization when there is a physical distance between the operator and SMS Manager. For the integrity of an SMS program, the person managing the SMS is expected to report directly to the Certificate Holder (CH) and remain independent and separate from both airline and airport operations. 

 

It is the CH who appoints a person to manage the safety management system, it is the CH who appoints the Accountable Executive (AE), and it is also the CH who maintain the safety management system. The CH is also the operator, or the operator my be any person in charge of operations, whether as employee, agent, or representative of the CH. The two executive positions as AE and SMS Manager play unique roles by their appointed positions to remain independent of airline or airport operator and preserve the integrity of the SMS. The CH appoints two positions to be responsible for meeting the requirements of the regulations on behalf of the certificate holder. Since their roles are to ensure regulatory compliance, these positions are at equal level in an organisation chart. That an SMS Manager is required to make progress reports to the accountable executive at intervals determined by the accountable executive is a component of the SMS and is not an organizational hierarchy position. However, the AE is the final authority for meeting the requirements of the regulations on behalf of the CH.

The Quality Assurance Program (QAP) is component of the SMS and maintained by the CH. The QAP Manager is not an appointed position by the CH but is an administrative position under the SMS Manager to manage and facilitate QAP responsibilities. By placing the QAP under control of the person managing the safety management system, the program’s integrity is achieved by its independence from the operator. A quality assurance program includes an audit function that consists of an audit of the entire quality assurance program carried out every three years, or a series of audits conducted at intervals set out in a controlled manual to be fully completed triennially. This audit function is performed by an operational independent source and by a person who is not responsible for carrying out operational tasks. An operator does not collect and assess data and performs an audit of its own performance unless the risk is accepted by the Regulator due to size, complexity, and nature of its operations. 

The role of an SMS Manager is to implement a reporting system for the timely collection of information related to observations, hazards, incidents, and accidents. Effective SMS Managers collect data in a timely manner and maintain safety compliance oversight by electronic means, rather than by unreliable paper documents.  An SMS Manager identifies hazards and carry out risk management analyses of those hazards. They investigate, analyze, and identify the cause or probable cause of all hazards, and also identify the root cause of special cause variations. SMS Mangers are required to implement a safety data system, by either electronic or other means, to monitor and analyze trends in hazards. The purpose of data collection and trend analysis in SMS is not to find errors, but to collect data to analyse how the system works compared to its expected outputs. As an example; checking the oil level, tire pressure, or adjusting rear-view mirrors in a vehicle is data collection to learn how a system function, and is not data collection to find errors. In addition, SMS trend analyses must be done within an SPC system (Statistical Process Control) which is not based on opinions or emotions caused by any graph charts. I often hear the phrase: "it is nice that the graph has a downward trend” A downward trend could be a latent hazard ready to explode, or it could be a safety improvement. One does not know if it is a safety improvement or not just because the graph is trending downward. An invaluable program to use is to apply p-control charts and xmr-control charts. These two control charts supplement each other with performance (80/20 rule) and timely delivery (UCL - LCL). A primary responsibility for an SMS Manager is to monitor. SMS Managers also monitor and evaluate the ongoing results of corrective actions, monitor the concerns of the civil aviation industry in respect of safety, and determine the adequacy of the training required. Monitoring is achieved by collecting data daily, or more frequently due to size and complexity, and applying control charts to identify drift in operations. Every role and responsibility of an SMS Manager has already been established as a remote function, even if operations and safety share the same office. 

The safety management system in aviation is a product of a continuing evolution in aviation safety. Early aviation pioneers had little safety experience, or practical experience to guide them. Over the years, each reactive approach to occurrences has led to significant gains in safety. However, even with these significant advances, the term "organizational accident" was developed to describe that accidents are related to organizational decisions and attitudes. SMS is an approach to improving safety at the organizational level. A superior SMS Enterprise applies this concept and include system analyses to examine its operations, its impact on sub-systems, and the effect of decisions implemented. SMS allows an organization to adapt to change, increasing complexity, and limited resources. SMS is also about enhancing organizational policies and processes, the organizational culture of leadership management and forward-looking accountability. 

 

The role of a person managing the safety management system is about processes, and to what level operational processed conforms to regulatory compliance, standard compliance and their safety policy. Since it’s all about processes, an SMS Manager located off-site has greater opportunities to analyze processes independently of operations. A pre-SMS process only expectation was that a safety officer had unlimited powers to fix all unsafe conditions and to make stern statements of the issues. The pre-SMS culture is still alive in SMS organizations, and with the SMS Manger in the office every day, there is a temptation to just “say hi” and ask for an immediate fix. With the SMS Manager at a remote location, this temptation is removed, and the SMS manager has more time to focus on processes. In a successful and effective SMS Enterprise, the person managing the SMS is a confidential adviser to the AE, located in a physical remote location from the operator, independent of operations and is without bias ties to oversight and management by an SMS Enterprise. In other words, a successful SMS Enterprise are using expertise services of a contracted SMS Manager, just as they are contracting other expertise third-party services. This enables the SMS Manager to freely, and without interference, to establish unbiased processes to be presented to the AE for acceptance or rejection. If rejected, the AE must alter identified processes to their own liking, and sign-off in a risk assessment, or system analysis, that the recommendation by SMS Manager was rejected. 

One reason for a safety management system to go off the rails, is that emotions are applied to safety, rather than data, facts and processes. A remote located SMS Manger has a-million more opportunities to successfully keeping SMS on track, than what an in-office employee has.  

 

There are three tools that an SMS Enterprise cannot effectively function without: The SMS Memory Jogger for out-of-control tests, SPCforexcel to analyze trends in performance and delivery, and SiteDocs as an electronic data collection tool.

 

 

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