This month we conclude a three-part series on Safety Management System (SMS) implementation for small air operators. Using the Input-Process-Output (IPO) functional mode as our framework, our focus has been on the requirements for the implementation of SMS scaled to small operators (the input), and the specific efforts needed for implementation (the process).Back to Articles
The implementation process comes with a first thorough risk assessment of the organization whereby the most important hazards and risks faced by the organization are defined together with the necessary additional defences needed for improved safety performance. Once the system is in place – the output is available - the organizational effort needs to be on how to keep the output to a good standard – a SMS that is current and functional.
A pre-requisite for the ongoing functionality and currency of the SMS is the organisational buy-in (in relation to this management tool), as discussed when the requirements for implementation were introduced in Part 1.
The developers of the SMS framework at the International Civil Aviation Organisation (ICAO) have foreseen an important component of SMS in support of its on-going currency and functionality; namely the continuous improvement component of safety assurance in SMS. This concept is ‘borrowed’ from quality management and refers to continuous alternation of the components of the ‘Plan > Do > Check > Act’ quality loop for ever improved ‘customer satisfaction’.
Small flight departments – like all other organizations with SMS implemented – can only continuously improve if they are proactive in their effort to do so. Safety management cannot be considered as a ‘one off’ exercise. It cannot rely only on an initial risk assessment because – in James Reason’s (author of Managing the Risks of Organisational Accidents) words – “there are currents acting within the safety space that lead the organization towards increased vulnerability. One of these currents is complacency.”
For an organization with an implemented SMS to be considered as operating safely, it needs to use all kinds of relevant and risk-assessed safety information – most eminently the information derived from the reports of near misses - and carry out the risk-mitigation actions required.
The implementation of the SMS will have come with an air safety reporting system in place. The reporting system is certainly to be used in those serious instances that lead to ‘mandatory occurrence reports’, but should also be used in the cases of ‘near misses’ which Reason defines as “those instances that could have bad consequences but actually do not”.
Reason discusses several advantages related to collecting data from, and analysing near-misses. If the right conclusions are drawn and acted upon, they work like ‘vaccines’ to mobilize the system’s defences against more serious occurrences in the future - without damaging anybody or anything in the process. Near misses can provide qualitative insights into how small defensive failures can line up to create large disasters, summarizes Reason.
Because near misses occur more frequently than bad outcomes, they yield the numbers required for more penetrating quantitative analyses. Near misses also provide a powerful reminder of the hazards confronting the system, thus reinforcing a healthy sense of fear that prevents operational short-cuts.
Small Organization Hurdles
The problem with small organizations however is that available resources are scarce; especially in terms of time available for adequate oversight of the SMS by safety-competent personnel that could already be involved in several other tasks. Furthermore, small organisations may have very low aircraft utilization rates, leading to the availability of literally only a handful of air safety reports each year. Statistical analysis on such a limited dataset may be of limited use.
One way to overcome the problem of limited time among safety-competent personnel in small flight departments is to hire a safety manager as an external service provider. This practice is common in the Business Aviation community (even with regard to the hiring of flight crews). Hiring a ‘part-time’ safety manager brings a two-fold benefit: the financial output is reduced by not having an additional ‘full-time’ staff member, and the return is maximized because of the experience brought in by a subject matter specialist.
The limited annual scope for data analysis can be overcome via the ever-increasing tendency for aviation safety data sharing. The Commercial Aviation community has a well-established tradition for the sharing of ‘de-identified’ safety information - a trend that has already been undertaken more recently by several proactive players in the Business Aviation community.
The benefit of safety data sharing is that contributors to such industry databases are enabled to access a data set that is more comprehensive to the one they are able to access with focus on their operation only.
If you missed either of the previous two parts to this article outlining the input needed for adequate SMS implementation within a small organization and the process of implementation in small organizations, feel free to contact us and request copies via firstname.lastname@example.org.
Mario Pierobon holds a Master’s Degree in Air Transport Management from City University London and works as a Safety Management Consultant and Content Producer. He regularly writes about aviation safety and is currently involved in a major airside safety research project at Cranfield University in the UK. Contact Mario via email@example.com.