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"AIRPORT MANAGEMENT" On-line Course from Northern Lights College.
Never stop learning!
Lawless
By OffRoadPilots
A safety management system (SMS) is a regulatory requirement for airport and
airline operators, the SMS regulations are performance-based, processes must
conform to regulatory requirements, but still, a healthy SMS is lawless. In a lawless
system events are unrestricted, actions are reactive to immediate threats, and
data are collected by random chance. A safety management system contains
multiple components to conduct research study of patterns. Research study design
is a framework, or the set of methods and procedures used to collect and analyse
data on variables specified in a particular research problem. A safety management
system research study designs comes in many shape and forms, with advantages
and limitations. A rule-based SMS is an overcontrolled system to justify an
expected definite and unambiguous output. A system where predetermined
results exists, is a system without trust, without learning, without accountability,
and a system where information sharing impossible. A lawless SMS paints a true
picture of airport and airline operators.
When data collections are
subject to rules, opinions,
and obedience, then data
collected becomes
corrupted data, unreliable
data for analysis and
fraudulent data. It is a
simple task to make an
SMS look acceptable on
paper by immediately
making corrections to
findings without reporting
these to the SMS. Prior to
SMS becoming a regulatory requirements, items and occurrences were repaired,
and documents were properly amended as a part of normal safety control, but they were not systematically documented for statistical process control (SPC)
analysis. One difference with an SMS, is to document findings, report findings to
SMS, fix or repair the findings, and monitor for patterns and compliance after
repairs.
When there are rules and practices for what is allowed to be reported to an SMS
manager, invaluable information is lost. SMS is not as much about reporting
incidents, as it is to establish patterns. Micromanagement of what is allowed does
not change the fact of how workers do their job day in and day out. All it does, is to
show a hazard register with allowable hazards as opposed to actual hazards.
Allowable hazards to report are unwritten organizational rules and practices. Over
time personnel learns to accept what to report and what is not allowed to be
reported. A common mistake by operators is to only accept reported hazards and
taking the position that unreported hazards do not exist. When the position is
taken that verbally reported hazards do not exist, or that verbally reported events
did not happen, operators are creating an officially controlled safety management
system. When an SMS authoritarian system is established, the authority of an SMS
is characterized by highly concentrated and centralized governing powers
maintained by excluding opposition, objections, and challenges. An authoritarian
SMS uses common sense justification to mobilize around the unwritten goals of
the operator. The requirement that the accountable executive is responsible
operations and activities authorized under the certificate and accountable on
behalf of the certificate holder for meeting the requirements of the regulations is
set up for an authoritarian SMS and misrepresentation of the system. Maintaining
regulatory requirements under such a system induces operational pathways with
hazard levels above hazard levels without operating with a safety management
system.
Running a safety management system is a specialty task different from any other
airline or airport operations tasks. A safety management system is not about
safety, but about processes, just as an accounting system is about processes and
not about the bottom line. The bottom line, profit, or loss is affected by accounting
processes applied, but these processes must adhere to accounting principles, evenif the CEO, or AE is the person with the final authority. A CEO cannot, while some
do, arbitrary demand their accountant to go against proper accounting principles
to adjust the outcome for short-term benefits, but long-term harm. In the
accounting world it is fraud to manipulate inputs to the process. Operating an SMS
by manipulating the inputs are also fraud, but difficult to detect for an untrained
eye.
Operating with a safety
management system
requires comprehensive
changes to airport and
airline operations. A fraud
management system needs
to be implemented pursuant
the quality assurance
program when operating
with an SMS, that is
required to conform to
regulatory requirements.
Justification for a fraud management system as an integral part of the quality
assurance program, is to place the oversight in the hands of the SMS manager. In
the pre-SMS era, there were no need for a fraud management system since any
use for the word “safety” justified any actions.
Fraud is intentional deception to secure unfair gain. Unfair gain applicable to a
safety management system, is when multiple operators providing the same
contracted services are gauged by their outputs, as opposed to what is reported.
When other operators only report favorable hazards and minimize their outputs,
while a single operator reports all raw data collected, the single reporting operator
generates 80% of events and hazards. With 80% of hazards and events allocated to
one single operator, this operator is being red-flagged and as unsuitable for further
contracts. What is forgotten in the equation, is that a contracted air operator’s
.right to operate their SMS as they see fit, are the responsibilities that comes with
freedom and rights.
In the face of new fraud methods and increasing incidence of fraud, operators
must continually identify and address vulnerabilities. Success will require core
capabilities in areas of enhanced threat intelligence along client journeys, data-
cycle testing and feedback, advanced data, technology, and analytics, and
transformation of the operating model.
Even as fraud threats have become more sophisticated, customers are demanding
more streamlined and low-friction journeys. Addressing these challenges requires
an enhanced strategy that has strong customer experience and fraud prevention
components and bases its long-term success on prioritizing 360-degree
intelligence. An operator, being airports or airlines must know their customers,
know their own operations and SMS, vulnerabilities, and capability gaps, and know
their competitors. A competitor may me a customer, an operator in the same
business, or the general public.
Analyzing the huge volume of intelligence data now available is a real challenge.
The traditional manual approach driven by individual investigators are fading away.
Instead, companies need a new at-scale technology-enabled solution and
multidisciplinary approach. A client intelligence and fraud prevention center can
better source and integrate threat intelligence and analysis to serve antifraud
decision making. This involves the creation of trusted stakeholder networks, both
within the organization and among clients, partners, and government entities, to
facilitate collaboration across silos and organizations. The cross-functional team
includes business leaders, experience designers, marketing specialists, product
development specialists, fraud specialists, investigators, operations specialists,
data scientists, technologists, and cyber experts.
To ensure that client journeys and controls provide the required protection against
vulnerabilities and that the organization meets defined and goals. Airport and
airline operators run data on files to identify nonfraudulent and fraudulentbehaviors and match them against actual SMS reports. Implementation of new
fraud control could cause the loss of a significant amount of business unless it is
performed properly. This is averted by reactive testing the control against
historical populations to gauge the outcome before implementation was under
way. Spelling out all the key outcomes allows operators to determine which special
cause variation generate the root cause of potential loss of customers and enable
them to devise a plan to address these special cause variations.
When conducting testing, test parameters of SMS reports must be established.
Testing is conducted randomly throughout SMS reports journey, with controlled
setup in live tests. Determining which version performs better enables operators
to identify the impact on fraud rates and customer satisfaction.
Learning from ongoing tests
requires a mindset shift by
leaders and specialists in
operations, technology,
customer experience, and
compliance and risk. Test
results should be
synthesized and reviewed in
a rapid feedback loop. By
adopting this rapid testing
cycle, airports and operates
can continuously adapt its
fraud controls and prevention measures as fraud threats evolve.
Airports and airlines need multilayer defenses with sophisticated data analytics
that enable rapid decision making for applications and nearly instant response
rates for monitoring. Technology needs to be flexible, adaptive, and quick enough
to react to fast-paced fraud attacks. Equally important is the need for insightful
and actionable analytics to identify fraud attacks quickly, enabling SMS enterprises
to modify controls and strategies.
Operators need to build the data and analytics that allow them to understand
customer experiences and changes in behavior after a fraud incident and across a
hazard’s journeys. They also need predictions and triggers to handle fraud
experiences rapidly and proactively, such as communications about why fraud
occurred and ways to protect the account in the future.
This requires data models that incorporate both internal and external sources.
Internal data, which should be combined across product silos, could be related to
fraud, identification, SMS reports profiles, and connected interactions across
channels. External sources could include device, biometric, and social data. The
model should also be updated to include new value-added data sources
continually. Additionally, it requires an orchestration layer that integrates different
systems and allows fraud management teams to think across the value chain,
capture complex fraud patterns, and identify fraud earlier. It should also enable
them to orchestrate the response and communication so SMS team members can
handle the experience in their area of expertise and department.
For SMS enterprises to
support advanced fraud
management, they should
consider enhancing their
operating model across
human factors,
organizational factors,
supervision factors and
environmental factors.
The safety management
system is defined as a
businesslike approach to safety. With a businesslike approach, an SMS must include a businesslike fraud management system. Fraud management of internal
processes and common cause variations, e.g. the AE demands certain input actions and results, are different than fraud management of special cause variations occurring because of how the work is done, e.g. an SMS report could be shared with ability to make changes and cause unintended consequences.
Fraud prevention is a regulatory requirement to ensure the integrity of a safety
management system. Regulations require SMS enterprises to operate with a fraud
management system of their recording systems, which includes computer records,
that do not comprise entries on paper. Computer records requires measures to
ensure that the records contained in the recording systems are protected against
inadvertent loss or destruction and against tampering, and a copy of the records
contained in the recording systems can be printed on paper to verify the integer of
processes.
In a lawless SMS organization, there are no restrictions on what area allowed to be
reported and there is no requirement for obedience to one single communication
process.
OffRoadPilots
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