Establishing Safety Management Systems in Small Operations
With new European regulations on air operations becoming mandatory by October this year the whole of the European Business Aviation community is in a final push to establish compliance with new management system requirements – namely, to establish Safety Management Systems (SMS). This is not a priority specific to Europe, however, as the publication of ICAO Annex 19 on SMS has put pressure on the whole global aviation community to implement SMS.One of the peculiarities of Business Aviation is that it is characterised by the presence of several small operators. “The risk you run with the introduction of SMS,” observes aviation safety consultant Emanuele Ghiroldi, “is to overload small operators - whether they are complex or non-complex - with a structure for safety management that has no justification in the size and complexity of operations.”
The scaling of an SMS to a small operation is indeed a significant issue, so much so that several small European operators have asked for extensions to their local authorities to comply with SMS requirements. The relative complexity of an SMS (and thus the more difficult adaptability to a small operation with relatively few employees) lies in the fact that it has more components in comparison with those of a more traditional air operator (quality) management system.
Much has already been written with regards to defining SMS - literature abounds within the industry – so the following will form the first in a three-part series to provide some guidance to the reader on how to successfully scale an SMS to reach full and practical implementation within a flight department. The functional model that will be followed to guide SMS implementation is the Input-Process-Output (IPO) model.
Top-down management buy-in with regard to SMS implementation is of utmost importance regardless of the size of the operator, but it is even more essential when the organisation is small.
“Think of the fairly wide-spread situation among helicopter and executive operators, where the accountable manager is often also the owner, a pilot, and a technician,” Ghiroldi illustrates. “Although in the company there are other figures dedicated to the management of other sectors (airworthiness, maintenance, etc.), it is evident that the presence of the owner/manager assumes a considerable influence among the staff. How could the company’ SMS unfold if the owner/manager were not fully convinced of the necessity and usefulness of SMS?”
When management is safety-sensitive, buy-in is relatively easily obtained by informing them of their accountabilities. Successful implementation depends on their displayed ownership of an SMS. Infrequently, however, it can also be the case that management is not safety-sensitive, or perhaps considers safety as not being part of its accountability. Under such circumstances safety practitioners have only one way forward to establish proper SMS implementation; instigate ‘fears’ in the minds of management personnel.
Research in behavioural economics (a discipline that considers elements of psychology in the study of economics) has demonstrated that people become more receptive when they are brought into the ‘loss domain’ – e.g. when a loss is prospected. Instead of focussing on the possible benefits of SMS implementation (the ‘gain domain’), here SMS project leaders make their business case for SMS implementation by focussing on all that is wrong within their organizations; the high-risks and operational challenges that are confronted; and the dollar-costs associated to these risks and challenges.
Only once these fears are instilled as reality in the minds of management, and SMS presented as the solution to prevent future losses, can management buy-in be obtained.
One component of an SMS is hazard identification and risk management, the successful functioning of which relies on employees critically observing operations and reporting weaknesses. Small organisations (particularly single-pilot operations) have the peculiarity that much of the information feeding the risk register of an SMS will be based on self-observation. Essentially, much will depend on how well operatives learn to become critical observers of their own practices and behaviours at work.
Just as senior management buy-in is essential with regard to SMS implementation, front-line employees must be motivated to critically observe their performance at work. This occurs when a ‘just’ culture is at work (a culture in which people are incentivised to submit air safety reports without fear of discipline or recrimination when errors are reported in good faith).
Human-factors training – which covers issues of human performance and limitation, and crew resource management (even for single pilot operations) can be valuable tools to increase operatives’ self-awareness at work.
Learning to Manage
It is inevitable that SMS implementation will bring in some additional complexity, and that the management system - which for a small organisation up to now may have been just an informal one – will need to become more structured.
A more defined managerial structure for a small team of people requires a cultural shift of personnel from a business management mind-set (whereby the focus is almost exclusively on actual service delivery) to a mind-set whereby management and planning becomes a part of the duties of personnel. For this shift to happen, people must be willing to develop and use additional project management, along with other soft skills on top of the technical skills which are prerogatives of their actual work.
We have focussed on the main inputs needed for SMS implementation within a small flight department, within this article, but needless to say that on top of the inputs detailed, an absolute pre-requisite is the knowledge of what an SMS is. Next month, we will focus our attention on the peculiarities of SMS implementation within a small team and consider how to effectively blend Management Buy-In, Performance Awareness and Project Management Skills to achieve SMS implementation.