As the aviation industry transitions into a world of SMS, the role of Safety Manager is evolving and has been brought into the lime light. Before today’s safety environment, this job may have been in a back office, processing reports and occasionally providing information to upper level management, but in today’s world the job is at the forefront of the larger safety program and all it encompasses. Safety is no longer crunching data from something that has already happened, it is actively pursuing and watching for the next potential risk.
To be a Safety Manager in today’s safety world, a person truly needs to be a Jack of all Trades. They need to know about flight operations, maintenance, dispatch, ground operations, cabin activities, airport operations, security, regulations, process design/improvement, data collection/analysis, report writing, presentation development, auditing, determining and assessing risk, industry happenings, and so the list goes on. The person that takes on the role of safety manager needs to have a grasp and understanding of all those topics and more.
A Safety Manager may be stronger in some fields than others, but that is what the rest of the safety department and subject matter experts are for. I’m bewildered when I see job listings for safety managers that list an ATP, jet time, and thousands of hours of flight time as a job requirement. Am I missing something? Is this person going to be a pilot or a safety manager? Why does the safety manager need to be jet qualified? Does being a pilot automatically give you the skills I mentioned? Being a highly experienced pilot has no correlation to being a successful safety manager. The Safety Manager needs to be able to read, understand, and correlate information on a wide variety of topics in aviation. Can you find someone who has experience/knowledge in all these areas? There may be a few in the industry, but you truly need someone who knows the basics and is willing to learn and isn’t biased based on their individual strengths.
For larger organizations, such as 121 air carriers and large 135 operators, finding and hiring a safety manager would be fairly easy. For small operators such as single aircraft 135s or corporate operations, the resources and finances necessary to hire a safety manager are minimal or nonexistent. The job often gets assigned to someone with an already full time position and safety is a secondary, or backburner, job. This makes it difficult if not impossible to implement and manage a full, functioning SMS. A dedicated safety manager with the appropriate knowledge and experience is necessary to be successful. If you can’t meet your Safety Manager needs, but still want the knowledge and experience, there is always the JDA Virtual Safety Office (VSO) option. Contact us for more information.
Having worked for over twenty-five years in the fields of telecommunications and aviation, I have engaged with many major clients including Bloomberg L.P., Southwest Airlines, Lehman Brothers, MCI International and Republic Airways among others. As a result, I have been afforded countless opportunities to learn about what constitutes a successful project and a positive client-vendor relationship. Over time, these learning experiences have coalesced into a set of key guiding principles that ensure a successful outcome when supporting a client on an important initiative.
First, never lose sight of the fact that you are dealing with people and not just a company. Take the time to find out what the key drivers are for the people you are interacting with, and ensure that their needs are met to the fullest extent possible. A client’s success and your own should never be viewed as mutually exclusive. In fact, it is exactly the opposite - if client people succeed in their roles, then your firm will be successful as well.
Second, part of ascertaining your client counterparts’ key drivers, is being able to glean the business drivers behind a project rather than just focusing on its technical aspects. Regardless of the field or the individual, the higher you go in an organization the more you will find a businessperson rather than a technical subject matter expert. And the views of a businessperson on the degree of project success can be influenced by many non-technical factors.
For example, the timing of an air carrier’s certification package submittal may have huge ramifications on an upcoming stock offering; or may be highly influenced by the delivery date, and ensuing monthly financial obligations, for newly acquired aircraft. JDA has experienced both of these scenarios, and was successful not just because it delivered a high quality manual system but because it did so within the timeframes mandated by these business drivers. Make sure you understand and meet your client’s major timeline events.
Third, resist the temptation to say ‘yes’ to ‘anything and everything’ to win business and [temporarily] please a client. Instead, be realistic and honest with a client when setting expectations. It is far better to jointly figure out how best to achieve a project’s goals via the combined resources and capabilities of the two companies than to set unrealistic expectations that cannot be met and ultimately result in dissatisfaction and consternation.
Fourth, communicate frequently with your client - providing too many updates is far better than too few. Make sure that client management has a clear view of project status at all times. Most importantly, if issues arise, address them with the client immediately. Don’t shy away from the ‘tough’ conversations when they become necessary. You need to give client management advance warning of problems so that they have sufficient opportunity to solve them or mitigate their effects. Few things are worse than belatedly telling a client about a problem (e.g., a potential schedule slippage because their personnel missed deliverable dates) when they no longer have a window of opportunity to correct things.
Following these guiding principles for taking care of our clients at JDA has yielded consistently successful project results, and most importantly, has led to many positive personal working relationships that to me constitute ultimate project success.
It seems like there have been a multitude of events in the news lately that would require a company to put its Emergency Response Plan (ERP) into action. Unfortunately, 2 a.m. with an event unfolding is no time to realize that your program is weak and out-of-date or, worse yet, non-existent.
Having an ERP is almost like admitting that you haven’t done everything you can to be accident free or that you can’t manage all your risks. Every business, no matter what risks they incur, should have an ERP. What would you do if you experienced a natural disaster at your work place and had to initiate a recovery plan? Without some kind of plan, you’ll be shooting in the dark on what to do. Whether it’s an airplane crash, toxic waste spill, tornado, or earthquake, an ERP serves the same purpose. If you don’t have one, get busy and start working on one!
For those that already have a plan, when was the last time you reviewed it? One of my roles with JDA is to serve as a tech writer on manual system revision projects. I have reviewed a variety of ERPs in which company contact personnel listed in the ERP were no longer with the company or that the telephone numbers had changed. If it hadn’t been for the manual revision project, the ERP would have been fairly useless and outdated documents that would have been of little value in the event of real disaster event.
A company should review its ERP at least once annually if not twice a year. Also, if conditions dictate a review or revision do it. Events such as headquarters office address change, personnel changes, new phone systems/numbers and new software programs, etc. warrant a review. Having a current ERP is a great first step but you also need to practice to make sure that your program functions according to the plan. A disaster is not the first time you want your response actually “testing” your ERP. At least once a year, perform an unannounced TEST emergency. Initiate the chain and observe. Afterwards, conduct a post ERP test debrief to discuss how things went and any positives or negatives discovered. Take this information into account and update your ERP procedures manual.
No one wants something to happen, but when it does wouldn’t you rather be prepared?
"Safe" Aircraft Parked in the Desert
The Iceland Eyjafjallajokull volcano has caused quite a ruckus within the aviation industry over the past 10 days, but it’s not the volcano or flight safety in ash clouds that I’m writing about. While reading about the grounded flights, I came across a quote from one of the union leaders and a 737 pilot for one of the European airlines. They basically said the only way you are truly safe in aviation is to ground all your aircraft and never fly again. That along with some discussions with co-workers brings me to this blog’s topic, what do we mean by “safe” in aviation?
Every airline and aviation organization will emphasize that safety is their number one priority, which I interpret as the operator will do everything in its power to be as safe as possible. Well I have to agree with the union leader that the best way to be accident free and truly safe is to sell your airplanes, but that business model doesn’t work in commercial aviation. Flying is inherently risky. You’re taking a machine composed of millions of parts, operating and maintaining it with people, and flying it thousands of feet in the air at hundreds of miles per hour through varying meteorological conditions. This sounds perfectly safe, doesn’t it? So how do we explain being safe?
We need to revamp our perception of aviation safety. There is no doubt that every operator strives for a goal of zero accidents. However, we recognize that we operate in an immensely complicated system and sometimes things happen - people make errors or components and systems fail. Aviation in itself is not inherently dangerous but it is terribly unforgiving of any carelessness, incapacity or neglect.
Instead of stating safety is our number one priority, we should clarify the safety objective and state that we always seek to operate in a manner that we deem as an acceptable risk. Flying will always be risky, but if airlines can proactively manage that risk and ensure it is at an acceptable level, we’ll be close to practicing what we preach and being honest with the traveling public. How do you operate with an acceptable risk -with an active and comprehensive Safety Management System (SMS).
The introduction of System Safety-based principles to air carrier operations and surveillance in the latter half of the 1990s has led to the safest decade in U.S. aviation history. Not resting on these laurels, aviation regulators and air carriers have now extended System Safety concepts even further via the promotion and implementation of comprehensive Safety Management Systems (SMS) that serve to proactively identify hazards, mitigate risks and promote a positive safety culture.
Part 121 air carriers were the first to embrace SMS in the U.S., but now Part 135 and even Part 91 international operators are getting on the SMS bandwagon. Not stopping there, the FAA has also introduced an Advisory Circular on SMS for Part 139 airports, and is providing funding for SMS pilot programs at several U.S. airports.
It is encouraging to see SMS expanding within aviation to beyond just Part 121 air carriers and into other types of air operators and airports, but these represent only the beginning of new applications for Safety Management Systems.
In particular, the concepts of SMS are hugely applicable to many other fields beyond just aviation, including other modes of transportation (e.g., Washington D.C.’s troubled Metrorail transit system), health care providers (with a staggering number of deaths caused by avoidable medical errors) and the food and mining industries, among others. Indeed, the recent mine tragedy in West Virginia provides a stark example of how the proactive introduction of an SMS could have potentially saved lives.
While JDA was founded and is staffed by aviation-centric safety leaders, we fully recognize how our work within the aviation safety community can benefit other industries as well, and we are actively working to extend the aviation successes of System Safety and Safety Management Systems into these other areas of need. If we are successful in getting others to listen, understand, and act upon the SMS message, the end result will be immensely satisfying - fewer patients dying from medical errors, fewer passengers and track workers dying from rail accidents, fewer miners dying, and fewer deaths from avoidable food borne pathogens. The stakes could not be higher.
CBS recently aired a new show, “Undercover Boss,” just after the Super Bowl. The first episode featured Waste Management President Larry O’Donnell. At the very beginning, Mr. O’Donnell shared a story about how his daughter was permanently injured from a medical error when she was an infant and that event drove home the importance of safety to him. “As a result of what happened to her, I never want to work at a company that I’m responsible for, where people don’t know how to follow the proper procedures.” Many people who have a true dedication to safety have had moments in their life that really hit the safety mark and opened their eyes to the importance of safety. Let’s call these “aha” moments.
My personal journey to safety has been long, bumpy, and slightly painful. I never intended to get into safety. From a young age I worked in industries that lent themselves to injury, and as you can see from my stories in the comment section below, I have had some very close calls. Each of these events resulted in an important safety lesson. People will argue that if we find ourselves in jobs that are unsafe, we should quit. However for one reason or another many of us may not have that option. Even when jobs were plentiful, finding a new job was not always easy. Most of us suck it up and do our job and hope and pray that everything will go well. Usually it does, and even for those of us in safety, we trip up from time to time.
I have experienced enough “aha” moments in my life that I want to do my best to make sure others don’t have to experience them. I hope you don’t wait for an “aha” moment at your company to get serious about safety because by then, it may be too late. The “aha” moment your employees experience may not be so gentle and could end with serious consequences. Let my experiences be lessons for all of us. Get focused and start mitigating all those situations that could result in providing the wrong lesson in your company.
Below are a few of my “aha” moments. Please share your “aha” moments as well. Perhaps we can all learn from each other.
So you’ve jumped on the safety train. Your senior executive has written and signed a statement publically professing the goal of being a safe company. You purchased safety posters and strategically placed them throughout the organization, formed some safety teams to handle the few safety events reported, implemented some policy changes, and started publishing a safety newsletter. All is good. You are well on your way to having a Safety Management System (SMS) in place.
Certainly all those actions are great and a good start to being a safety conscious company embracing SMS, but are there other company actions overshadowing and even negating your safety efforts? Employees see two things in the company that pertain to safety: what is said and what is done and measured. They see you talking about safety, but when it comes down to it they see that nothing has changed. This is especially hammered home when the company releases its monthly/quarterly reports. The number one thing you see on these reports is on-time performance, aircraft availability, and dollars made. Very infrequently, if ever, do you see anything about this new safety goal? So what does the company care about - just moving metal and making money? These items dwarf the safety goal. Safety isn’t measured or touted, so apparently it’s not important.
I once had a professor tell a story about a CEO at a company and how he showed his commitment to safety.
A new CEO had been hired at a company and was attending his first monthly/quarterly company meeting. All the department heads were nervous about what this new executive would say. The CEO walks in right on time and sits down in front and starts the meeting. He welcomes everyone and thanks them for being there and for their hard work. In typical fashion he wants to hear department reports. The first department he calls on is Safety. Shocked, having never been called on to report before yet alone the first one, the Safety Manager stands up and makes his report. The CEO asks some pertinent questions and thanks him. At this point the CEO gathers up his material and begins to leave the meeting. Everyone is confused. Did Safety say something wrong? Was he mad? One Vice President asks the CEO if there is a problem. The CEO replies, “No. All the production and financial matters I can read in reports. What I can’t do is be responsible for injured or lost employees. Safety is important to me and it should be to you, too.” With that the CEO left the room.
Now whether this is a true story or a fabricated teaching tool, I don’t know, but the point strikes home. What do your actions say about your company’s stance towards safety?
Are the number of accidents a good measure of safety?
For years, the benchmark for measuring aviation safety has been accident and incident statistics. Is this approach antiquated? As we move towards Safety Management Systems (SMS) and adopt proactive safety practices and programs, should new criteria for measuring safety be developed and adopted? Should operators and regulators identify the key safety elements that should be collected, measured and managed to assess the safety of an organization? Following are three areas that should be considered for measuring the safety of an organization:
Safety Fundamentals - Compliance with regulations pertaining to safety such as training requirements, manuals and procedures, equipment maintenance, and the coordination of activities within and between teams/units.
Safety Values/Culture - Safety attitudes and values expressed in words and actions by leadership, regarding safety. This reflects the commitment to safety at the top levels of the organization.
Going Beyond Compliance - What is the priority given to safety in the allocation of company resources (e.g., equipment, personnel time), even though they are not required by regulations? This may be reflected in areas such as employee rosters, scheduling of shift work and rest time, providing advanced technology when essential, fatigue and human factors programs, and other risk-based management systems.
Aviation organizations must find and utilize safety data that is statistically valid and pertinent for measuring the success of a safety program. Accidents and incidents happen far too infrequently to be an adequate measurement of the effectiveness of a safety program. The ultimate irony of such current industry practice is the use of negative outcomes to measure safety program success.
Safety in the workplace is a top priority for nearly every company. Each company has their own reasons that they focus on safety, i.e., it’s the right thing to do, eliminating unnecessary costs, etc. Depending on your industry, the risks of injury at work are wide ranging. While a logger has a much higher chance of injury than say an administrative assistant , each has a common injury potential - their home and personal life.
It has been said the employees of a company are its number one asset. All the machinery, computers, and automation can only do so much without the human counterpart. Imagine one of your best and most highly trained employees - chances are they are nearly irreplaceable, at least on a short-term basis. The time and training cost to get someone to their experience level is more than you want to imagine. Now, imagine this: It’s Fall and that employee is at home cleaning out their gutters. They have a ladder that is almost tall enough, but not quite. No problem, they’ll just stand on the top step and reach a little. Next thing you know you’re getting a call from the hospital. This valued employee has broken their arm and sustained a severe concussion. They’ll be out of work for at least two weeks. Normally you could probably manage to struggle for a couple weeks, but not now. This is the same employee that is the project manager for the largest, most valuable project you’ve had in nearly a decade. Now what?
See where I’m going with this? Employers need to expand their horizons on safety awareness. A person’s home poses the same, if not higher, risks as the workplace. There are things you can do to help raise a person’s safety awareness at home. When you put out your monthly safety bulletins (you do this right?), include safety tips for the home. Look at the current season and consider the activities that may be going on around home. Look at safety items that cross over, like ladder use or lifting. Be sure to mention work and home when discussing them. If your employees are issued safety gear, encourage them to take it home and use it. When I worked for the railroad, we were issued nearly every piece of safety gear you can imagine: hard hats, leather gloves, steel-toe boots, reflective safety vests, safety glasses, ear plugs, and much more. We were highly encouraged to take these things home and use them. While I’m no longer with that company, to this day I still use those items every single week. Sure the items may wear out a bit quicker, but balance the costs of a little extra equipment versus the cost of a lost employee due to injury.
So now you must ask yourself, how much risk are you willing to take? Do you think your employees are safe at home? Are you doing all you can to spread safety information? A little bit can go a long way.
Safety Management Systems (SMS) is a hot topic, a buzzword, and soon to be a requirement. The International Civil Aviation Organization (ICAO) has stated that all member countries should have established SMS requirements for operators by Jan 1, 2009. The FAA failed to meet the ICAO deadline. In a way, US companies have been given extra time to sit in their rocking chairs.
Just because the FAA is behind, doesn’t mean you have to wait to implement an SMS. In fact, waiting to develop and implement your own SMS until the FAA sets deadlines could cause more stress down the line. An SMS is not something you do overnight. It takes planning, development, resources, integration, and culture shifts. While it’s true, we don’t know what the FAA is going to require in terms of an SMS, chances are it will closely mirror the ICAO standard.
So the question is, why wait? Start planning now. Save yourself the stress of procrastinating until the last minute to pull your SMS together. Start the legwork required to give your company the proper Safety Management System. By beginning now, you’ll be ahead of your competition. When you come to the stumbling blocks and hurdles you are bound to find, there won’t be a deadline looming that forces you to shortcut the system. When the FAA finally does come up with a rule and required implementation date, you’ll be doing final modifications to your system while easily continuing normal operations. Your competition, on the other hand, will be scrambling to develop and implement their system, hurdles and all, while trying to continue day-to-day operations.
Which do you want to be? The company cruising along performing final modifications or the company scrambling to meet the requirements and cramming things in place that may not work?
Many corporate operators have placed their aircraft on another company’s Part 135 certificate to avoid having to obtain their own, yet at the same time collecting charter revenues. However, operation of passenger-carrying flights for hire requires that the actual provider of the air transportation hold the air carrier certificate.
All Part 135 operators must retain ultimate authority over initiating, conducting and terminating flights and may not surrender its operational control responsibilities to an individual or company that is not a certificate holder. Once an operator surrenders operational control, they open themselves up to some very prickly problems!
In many cases, the FAA has concluded that the arrangement between the corporate aircraft owner and the charter company was no more than a “rent a certificate sham.” As a result, there have been record fines, certificate suspensions and revocations and now the threat of jail time for flying illegal Part 135 flights.
To help eliminate this risk, JDA has developed 135Pro™. 135Pro™ is a simple, inexpensive way for corporate flight departments to gain charter revenues with their own Part 135 certificate. Once you subscribe to 135Pro™, we will be there with you every step of the way. Our service includes mentoring and training of company personnel and coordination and interface with the FAA .
Avoid the prickly risks of renting a 135 certificate and help us understand the needs of Part 91 operators by taking take a quick survey.
DOT data shows more than 600 incidents of passengers stuck on the tarmac 3 hours or more during this year’s first seven months. There are more than 87,000 flights per day in the skies in the United States of which 1/3 or ~29,000 are commercial carriers. Extrapolating that out on a yearly basis is equal to 10,585,000 flights. Six hundred events of tarmac delays in the first 7 months is equal to .00567 %; which may seem like reasonable number considering the limitations of the current Air Traffic Management System as well as weather, gate availability and delays due to mechanical problems.
For the year 2008, DOT data indicated more than 1,400 incidents of passengers stuck on the tarmac for 3 hours or more. That equates to .013%.
The steps that airlines and the government could take to reduce the number of such incidents include:
1. Implement NextGen and associated technologies.
2. Increase the number of air traffic controllers.
3. Create special terminals and gates for delayed flights.
4. Build new gates and expand airports.
5. Establish an event database similar to a SMS risk management model to identify events and hazards; complete risk analysis and assign corrective actions and management responsibility; and tackle repeat events.
6. Establish an industry / government task force to determine the cost impact and develop solutions/recommended actions.
7. Benchmark against other transportation modes or other government regulations.
What is a reasonable amount of delay time before passengers should be allowed to go back to the terminal and get off a plane?
That is a difficult question to answer but the elements that must be addressed/researched include:
1. Access to food, water, cabin cooling - the FAA already has an existing Advisory Circular published on this topic.
2. Weather at arrival and departure airports.
3. Policy and procedures have to be consistent for all operators, mainline and regional alike.
4. What happens if there is a medical or other emergency on board; what about disabled passengers?
5. Impact of flight crew rest and duty time; if exceeded what is impact on connecting flights and staffing?
6. What is downstream impact if there is a time limit set and how does that impact security, operations, other flights, ground support/service such as fuel, AC/electrical, ground service personnel gates etc. All will drive up operating costs.
7. What are the airport limitations for apron and taxiways; ability to U turn and be rerouted to the gate?
8. Air Carrier operating costs will go up; how are the costs covered?
The most popular benchmark being floated is a 3-hour delay. For whatever reason passengers are putting the burden on air carriers when it may not be in their control if it is weather or AZTM related.
In determining whether a Passenger Bill of Rights is a good idea, several potential issues need to be considered:
1. Air carrier and passenger contract terms. Does a full price ticket and low fare ticket have the same “rights” re-enplanement and deplaning? How can those terms be dictated by government? An operator that is customer focused will do the right thing and make a bad situation that is mostly out of their control bearable.
2. Should Congress pass a bill requiring airlines to allow passengers off planes after a certain number of hours? If a bill like the Passenger Bill of Rights is pushed thru Congress then DOT should establish the limits not Congress. If there is bill passed then the time limit should be specific enough so the flight is canceled and rescheduled for a later time that day or the next day. Specific guidelines as to what passengers would be entitled to would need to be delineated.
3. In the event that a bill is passed, passengers should not have the option to deplane if the pilot reasonably determines that the aircraft will depart or be unloaded at the terminal not later than 30 minutes after the delay or that permitting a passenger to deplane would jeopardize passenger safety or security. Will it be a passenger option or will all have to deplane?
4. Airport operators would have to submit contingency plans describing how they would handle deplaning passengers following long ground delays, as well as create a telephone complaint hotline for passengers.
Maybe no bill should be enacted as the solution will likely be harder to manage than the problem. Flying like driving your automobile has risks, stuff happens and statistically it is still a small problem. Hopefully, NextGen and other operational improvements will alleviate a good portion of the tarmac delay events.
Flying on a commercial carrier has never been safer simply because the FAA in partnership (no partnership is not a bad word) with U.S. air carriers go beyond simply ensuring regulatory compliance. Yet, there are those who would question the effectiveness of the Air Transportation Oversight System (ATOS) and a number of voluntary safety programs administered by the FAA. Those who question the wisdom of allowing carriers to implement their own safety audits and self-correction systems lose sight of the fact that FAA audits supplement the carrier’s self-audits, to verify that the airline’s practices and procedures reflect an effective approach to system safety. Those who question the benefit of voluntary reporting programs ignore the safety benefits that result from making the operator and its employees responsible for identifying and correcting potential safety problems. It is the combination of ATOS and voluntary safety programs that make flying on a commercial carrier as safe as it is today. The next level of safety will be achieved through establishment of a positive safety culture within the air carrier organization and implementation of a Safety Management System to identify and manage risk, analyze trends, anticipate problems and correct issues before an accident occurs, not after. For safety advocates that remain skeptical, the question of the day is…What is a better alternative?
Recent Congressional and NTSB hearings on the December 2008 Colgan accident have turned up the heat on regional airline safety, and the FAA is moving quickly to enhance existing pilot fatigue regulations. On the other hand, the implementation of a Safety Management System (SMS) regulation is moving very slowly. While the FAA should be commended for taking prompt action on pilot fatigue, they are missing the target!
Because of the Colgan accident, the FAA will implement a new flight time and rest rule. U.S. operators and unions will be tasked to insist that airlines obtain all available FAA pilot records. FAA inspectors will complete a review of airline procedures for identifying and tracking pilots who fail evaluations or demonstrate a need for additional training. Inspectors will validate that the airline’s training and qualification programs meet regulatory standards.
The FAA also expects airlines that have contracts with regional operators to develop programs to share safety data and ensure that their partners mirror their most effective safety practices.
Bill Voss, President of the Flight Safety Foundation, recently stated that the character of accidents is changing. “Accidents resulting from human factors issues and loss of control are becoming more common.” Another big concern is public perception of airline safety. “Not since the summer of 2005, when we crashed an airplane a week, has public perception been as bad as this. Safety of the world’s aviation system relies on sharing information, both among competitors-airlines and other stakeholders-and among regulators. We need to understand why humans and aircraft are getting tied up.”
In almost a third of the accidents last year, deficient airline safety management was a contributing factor. This includes deficiencies in the airline’s safety policies and objectives, risk management, safety assurance and safety promotion. The majority of accidents involving deficiencies in the airline’s safety management also implicated deficient regulatory oversight by the regulatory authorities.
Since accidents are usually the result of many causes, shouldn’t the FAA focus on mandating a system’s approach that will minimize all types of errors? Suppose that an SMS had been in place at Colgan and even Air France? If an SMS was in place, early indicators and factors would have been captured, identified, analyzed and corrective actions put in place. Just maybe the mishaps would have been prevented. It certainly could not have been worse than what happened! There is no better program for collecting safety and event data than an SMS, especially if you have the right tools in place-FOQA and ASAP are components of a good SMS along with a good SMS application.
So why is it taking the FAA so long to mandate Safety Management Systems? A review of all the FAA Advisory Circulars and Orders shows that they are already aligned with ICAO SMS guidance. At the pace the FAA is taking, it will be 3-5 years before there is an SMS regulation, and it will likely take another 1-3 years after that to get SMS operational by the operators. The FAA should rethink their SMS strategy and fast track a rulemaking program so information sharing is bolstered and incidents and events can be addressed sooner, not later.
There has been a great deal of public scrutiny of the Air Transportation Oversight System (ATOS) system. After a 30-year career in safety both at the Federal Aviation Administration (FAA) and as a safety consultant, I am concerned about the tone and direction of the publicity. There seems to be a general assumption that the operators are unable to take on the responsibility of their safety systems and that collaboration and cooperation between the regulator (FAA) and the operator is a bad thing. I disagree.
The only feasible method for the FAA to ensure that a comprehensive safety system exists for the operator is to conduct audits of the system on a periodic basis. These audits are essential as they check the processes and procedures of the safety system to ensure they meet their intended design. On the other hand, when the FAA audits stand alone, they do not provide the data needed to truly improve a safety system. Any suggested changes made to a safety system that are based solely on the data from a single audit, may be invalid. System changes that move a safety system towards the ideal are developed from data gathered, analyzed and trended over time. From this data, controls and corrective actions can then be put into place based on reality rather than an anomaly. Once enacted, more analysis of the corrective actions needs to occur to determine if these actions meet their intended design. This process of analyzing, trending, and making changes is ongoing and needs to utilize data collected by both the operator and the FAA.
To enable the analysis of data collected by both the FAA and operator, the data needs to be shared in a positive working environment that is open and based on trust. When an operator voluntarily shares data with the FAA, the data needs to be protected and used by the FAA to help the operator ensure best practices in the Safety Management System (SMS).
Though the FAA is integral to helping an operator develop a comprehensive SMS, in the end, the responsibility of the SMS rests squarely on the shoulders of the operator. If there is an ineffective SMS, the operator’s customers are at risk, and thus the operator itself is at risk. Operators understand their responsibility, and the FAA provides them with another viewpoint and a second set of eyes to analyze their safety data. When operators are able to take the FAA’s viewpoint and combine it with their own ongoing collection of data and analysis, they have what is needed to create an evolving SMS where changes improve the entire system rather than provide short-term fixes to errors that could well have been anomalies.
So let the scrutiny of ATOS continue. But, as in the development of an SMS, we need to make decisions about any changes to ATOS after a thorough analysis of a complete set of data points. I am encouraged when I see a positive FAA/operator relationship and the sharing of critical safety information. Sharing enhances the operator in part and the aviation industry as a whole.
