Saturday, January 7, 2023

When an Enterprise Quits SMS

 When an Enterprise Quits SMS

By OffRoadPilots

There are several ways to quit a safety management system (SMS) and an SMS enterprise may unintentionally or unknowingly have quit their SMS. A safety management system is an expensive system, requires hard work and the benefits are unknown, assumed, or abstract benefits. Benefits, if any, remain unknown since an SMS cannot tell the future, or make predications to what, where, where, why, who and how an incident will occur.

When a justification is presented to an SMS enterprise, a CAO, a CEO, or municipality, that SMS is expensive and without tangible results there is a strong temptation to accept these facts. There is no evidence that the SMS will cause a reduction of future accidents, incidents or hazards, there is no evidence of higher return on investment, and there is no evidence that an SMS has

produced better qualified flight crew, maintenance crew or airport personnel. That an enterprise quits SMS does not imply that they abolish their SMS program, but that it is possible to operate an ineffective SMS by while producing desired results.

A crucial question to answer for an airline or airport to operate with a successful SMS is “Why does the Global Aviation Industry, being Airlines or Airports, need a Safety Management System (SMS) today, when they were safe yesterday without an SMS?” The simple answer is that an SMS is needed to generate system analyses specific applicable to an airline or airport, and to have a road map when arriving at the fork in the road. An SMS enterprise is operating with defined processes to conform to regulatory requirements and each task within a system analysis is applied to a regulatory requirement and followed up with a quality control system.

An airline or airport operating with an SMS has at the least an SMS Manual in place that includes multiple processes conforming to regulatory requirements. An SMS manual contains at a minimum a safety policy, a process for setting goals and for measuring the attainment of those goals, a process for identifying hazards to aviation, a process for ensuring

that personnel are trained and competent to perform their duties, a process for analyzing of hazards, incidents and accidents and for taking corrective actions to prevent their recurrence, a document containing all safety management system processes and a process for making personnel aware of their responsibilities with respect to them, a quality assurance program, a process for periodic reviews or audits, and any additional requirements for the safety management system.

In addition, the SMS manual contains specific roles and responsibilities for the person managing the safety management system. These responsibilities are to maintain a reporting system for collecting information related to hazards, incidents and accidents, identify hazards and carry out risk management analyses of those hazards, investigate, analyze and identify the cause or probable cause of all hazards, incidents and accidents, maintain a safety data system by electronic means to monitor and analyze trends in hazards, incidents and accidents, and monitors, at defined intervals, and evaluate the results of corrective actions. An SMS manager also monitor the concerns of the civil aviation industry in respect of safety and their perceived effect on the Certificate Holder (CH), and determine the adequacy of the training for the person managing the safety management system and for personnel assigned duties under the safety management system. 

An SMS manager determines what, if any, corrective actions are required and carry out those actions, keeps records of any determination made, and the reason for it. The responsibility of an SMS manager closes the Plan-Do-Check-Act cycle by notifying the CH of any systemic deficiency and of the corrective action taken. A systemic deficiency includes the implementation of a new system to manage the safety management system.

A Certificate Holder lay their foundation from a blueprint of regulatory requirements and builds their SMS system on top of their foundation. The system must be a stable system, where minor deviations are detected as drift, and special cause variations are analyzed within the context of the SMS system with corrective action plans. If a change leading to an identified special cause variations were intended by the airline or airport, the corrective action also includes a safety case for change. A change could be a policy change, process change, or a change in acceptable practices. When drift, or deviations goes unattended, or unmonitored, an AE would have a difficult time to capture that their SMS had fallen into noncompliance. Conventional wisdom is that a previous accepted SMS manual conforms to regulatory requirements, and that new changes to the system does not affect SMS compliance.

An accountable executive is responsible for operations or activities authorized under the certificate and accountable on behalf of the certificate holder for meeting the requirements of the regulations. Without in-depth knowledge of applicable regulations and how operational processes affects these requirements, an AE may take a non-conforming turn at the fork in the road. Generally speaking, a sole proprietor business owner, or a CEO of a corporation review their financial statements regularly. At some point a demand is placed on personnel to assess expenses and find methods and areas to reduce expenses. When analyzing the safety management system, there were zero hazard reports, zero incident reports, zero accident reports and zero concerns raised by personnel about safety in operations. For an untrained eye, when analyzing the SMS with zero results, the cost of operating with an SMS system that does not produce results should be reduced, or eliminated. Since the elimination mitigation of an SMS is unavailable due to regulatory requirements, the prior step backwards is to mitigate the SMS. There are several ways to mitigate an SMS, but a common business solutions are to eliminate non-essential tasks expenses and eliminate tasks that are producing zero results. By eliminating task, such as the task conformance matrix, a new SMS system is linked to the SMS manual. This system is a conforming system, but since it is a totally new system put in place, all prior data, corrective actions and system analyses are invalidated. When a new system is put in place of how to operate an SMS, an airline or airport starts their SMS process all over again.

Simply said, when processes are removed, when a cloudbased SMS service provider is changed, the data collation system is changed, the analysis system is changed or when operational processes are changed for other than identified improvement changes, another first-time gap analysis is needed. Since results are abstract, it is an ongoing uphill battle to raise support for an effective safety management system that does not identify occurrences. An SMS requires hazards, incidents, and accidents to earn this support.


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