Establishing Safety Management Systems in Small Operations
Last month we focussed on the input needed for proper SMS implementation within a small company, outlining Senior Management Buy-In; Performance Awareness; and project management attitude, on top of the prerequisite SMS ‘technical’ know how.
Continuing our series on SMS scaling for small operators, our focus moves to the process of SMS implementation in small organisations - in other words, blending last month’s input into output (a functional and properly scaled SMS).
The International Civil Aviation Organization (ICAO) in its Safety Management Manual (Doc. 9859) recommends a phased approach to SMS implementation, whereby policies and accountabilities are first defined; the system is described; gaps are identified; and documentation is produced. ICAO’s phased approach continues with the actual implementation of those components of SMS that are new compared to the traditional – quality-based – practice of safety management, risk management and personnel training.
ICAO’s approach to implementation is applicable regardless of the size of the operator and as such is suitable to be followed by small operators. The availability of content for the phased approach to SMS implementation is not in short supply, so the focus of this article centers on SMS implementation peculiarities for small flight departments.
Need for Independent Input
The key to a successful phased SMS implementation process in small companies is in partnering with an independent third party, which needs to be assigned a project leadership function. Even established Airlines hire third parties for implementing major safety initiatives, so within small organisations it is all the more necessary to turn to external service providers because the expertise is unlikely to be available in-house and personnel already have a large variety of tasks to manage. Further, only an independent third party can properly capitalise on senior management buy-in, performance awareness and the project management attitude in a way that is accepted by all internal stakeholders. Simply put, prior to actual SMS implementation, no internal stakeholder can reasonably claim to be experienced enough with regard to SMS in a way that she or he can guarantee the buy-in and the cooperation of his/her peers, and thus proper SMS implementation. The third party should ideally be an independent safety management consultant, but may also be a subject matter expert “seconded” from an organisation where an SMS has already been implemented.
External Authoring and Editing
It is not uncommon when a new regulatory requirement needs to be met for the focus to be placed almost exclusively on documentation (e.g. on “paper compliance”), and under such circumstances the external contractor is hired for documentation authoring and editing purposes only.
The third party should not limit themselves to write or revise existing company manuals but should actually lead the implementation process. The only way to ensure adequate project leadership from the third party is that a socially competent one be hired. In addition to having the necessary SMS know-how, it is important that the third party SMS project leader’s skillset includes the ability to capitalise on, and blend senior management buy-in, performance awareness and the team’s project management attitude (e.g. input that at this stage should already have been obtained).
The ultimate responsibility with regard to SMS implementation does not belong to the third party, but of the organisation itself. Therefore the organisation needs to quality-control the contracted third party to ensure the implementation process runs smoothly and on time.
Monitoring of the third party’s overall performance should be based around agreed, and measureable objectives that are established before SMS implementation begins, and progress should then be measured recurrently in view of the pre-determined objectives.
Measurable objectives include - first and foremost - deadlines for production of the ‘gap analyses’ versus the ‘SMS framework’. Implementation risks running into considerable delays if the project is not managed from the starting point of an adequate definition of what actually needs to be done and instead a more “adventurous” path to implementation is followed.
Another important objective is tied in with the development of a cooperative and mutually respectful relationship between the third party under contract and the organisation itself. This can only be achieved if definition of the respective accountabilities of internal stakeholders and the third party are clearly established and agreed, as well as the timing and the content of follow up meetings.
Finally, the organisation should require the third party to temporarily act as a liaison with the regulatory authority and ensure that communications occur between the authority and the third party representing the organisation. This is not only important because there is a need to demonstrate progress made to the authority, but also because showing the authority the organisation’s commitment to safety by going the extra mile of hiring a third party for SMS implementation could possibly reduce the ‘burden’ of regulatory oversight, because the organization clearly demonstrates a high degree of professionalism with regard to safety management.
A properly overseen implementation should confidently lead to a functional SMS being installed through to the actual output being available. At this stage the challenge will be that of managing the output (namely ensuring the continuing functionality of the SMS through the safety assurance function). With that in mind, safety assurance will be the focus of the concluding part of this series next month.