COUNTERFEIT SMS

 COUNTERFEIT SMS

By OffRoadPilots

A counterfeit Safety Management System (SMS) is not simply a weak or

immature system; it is a system that never truly operates in daily decision-

making. It exists primarily to satisfy oversight expectations rather than to

control operational risk. The first and most reliable indicator appears in

behavior changes during oversight. Before an audit, work is informal,

hazards are handled verbally, and production dominates choices. During an

audit, employees suddenly quote policy, manuals are referenced, reports

appear, and safety terminology becomes fluent. Afterward, operations

return to normal. A real SMS permanently changes how decisions are

made; a counterfeit one only changes how people speak when observed. If

safety language disappears when oversight leaves, the system is theatrical

rather than functional.

Another major sign is the

presence of reports without

operational change. Genuine

systems convert hazard

reports into removal of risk.

Counterfeit systems convert

reports into records. You will

see repeated hazards logged

over months or years,

corrective actions labelled as

“monitor,” and files closed

without verification. A

decisive question is whether

the organization can

demonstrate a hazard

eliminated because someone

reported it. If the only evidence consists of meetings, investigations, or

discussion rather than removal, the SMS is administrative. Safety

.performance must be measured in hazards removed, not documents

produced.

Risk assessments also reveal authenticity. In counterfeit environments,

assessments consistently conclude that risk is acceptable. Probability

values are copied across forms, different hazards receive identical ratings,

and existing controls are re-listed as new mitigation. The purpose becomes

approval of planned work rather than understanding exposure. A real SMS

frequently produces inconvenient outcomes: delays, redesign, additional

cost, or cancellation. If risk assessment never disrupts production, it is

authorizing risk rather than analyzing it.

Counterfeit systems

commonly assign safety to

a department or individual

instead of embedding it

across the organization.

Employees say “talk to

safety” or “the SMS office

handles that.” In a real

system, maintenance can

delay flights, dispatch can

reject plans, supervisors can

stop tasks, and workers

intervene without permission. When safety belongs to a single role, operations belong entirely to production. When safety belongs to everyone, behavior changes across the organization. A safety office should coordinate safety, never contain it.

SMS.Investigation quality is another clear diagnostic. Counterfeit investigations

end with human error: inattention, lack of awareness, complacency, or need

for retraining. Real investigations identify system conditions such as time

pressure, staffing levels, conflicting priorities, procedure design, or

equipment usability. If corrective actions repeatedly retrain individuals, the

organization is repairing people instead of repairing the environment that

shaped behavior. Human error should begin an investigation, not conclude

it.

Worker communication reveals the true operating climate. In counterfeit

systems employees speak cautiously, requesting anonymity and warning

investigators not to document their statements. They describe how they

“make it work” or how things have always been done. In real systems

employees reference previous reports, known fixes, and management-

supported changes. Psychological safety determines operational safety.

When workers must protect themselves from reporting, the reporting

system itself becomes a hazard.

Safety meetings also

differentiate real and false

systems. Counterfeit

meetings review statistics,

discuss events abstractly,

and end without assigned

actions or deadlines.

Agendas repeat monthly.

Real meetings conclude

with clear responsibilities,

completion dates, and

verification methods.Meetings that generate discussion but no operational decision function as

public relations rather than risk control.

Performance indicators can mislead when they measure activity instead of exposure. Counting reports, inspections, or training hours demonstrates motion, not safety. Authentic indicators track risk movement, such as the time required to mitigate a hazard, recurrence rates after corrective action,

or exposure reduction trends. If performance graphs cannot demonstrate

decreased operational exposure, they measure bureaucracy rather than

protection.

Change management provides another decisive indicator. In counterfeit

systems the organization documents risk after implementing the change:

procedures already in use before assessment, equipment installed before

review, staffing reduced before analysis. Documentation becomes

historical justification rather than prevention. In functioning SMS

environments, operational staff expect no change to proceed before risk

understanding.

Emergency preparedness

exposes similar patterns.

Counterfeit plans are precise

but impractical, listing

unavailable personnel,

outdated contacts, and

unrealistic timelines.

Exercises emphasize

attendance rather than

performance. When

responders privately describewhat would actually happen, the gap between reality and documentation

reveals system authenticity. A real plan reflects how people truly operate under pressure.

Ultimately, a counterfeit SMS manages regulatory exposure, while a real SMS manages operational exposure. One protects the organization from

findings; the other protects people from harm. The difference appears in

consequences. In a functioning system work sometimes stops, schedules

move, costs increase, and leaders accept delay. Safety competes with

production and sometimes wins. If safety never meaningfully influences

decisions, it is not part of operations.

A final diagnostic question captures the distinction: ask any employee to

describe the last time safety overruled operations. If the organization

struggles to answer, the SMS exists on paper. If multiple employees

immediately provide different real examples, the system is alive.

OffRoadPilots