Safety Management Systems (SMS)
Proactively Identifying Risks & Investing in a Solution
Former NTSB Member and Mechanic par excellence, John Goglia, spots an important and subtle change in FAA policy from enforcement to compliance largely based on the regulatory SMS regimen which it adopted. This confluence of a new cooperative, preventative relationship with a less contentious approach to assuring that the safety standards are met was driven by a wide variety of internal rationales.
Given John’s experiential perspective of the professional whose, for example, improperly torqueing bolt might cause her/him to face a civil penalty for such an error, he looks for ways “to insulate themselves from enforcement action and make their operations safer and likely more time and cost effective.” He then explains how SMS might be applied to a small air taxi or repair station.
The ultimate goal of the Safety Management System discipline is to proactively identify risks. That task is assigned to a committee which is a composed of a diagonal slice drawn from all types of positions within the certificate holder’s organization. The process is designed to develop solutions from every perspective within the company and to create a policy/procedure/technique to best respond to the RISK posed within that air carrier or repair station.
In the past, the FAA would become aware of a problem and would attempt to create a rule applicable to every airline. Through the discipline of the NPRM steps, the help from OST/OMB and the difficulty of writing an enforceable rule, the typical gap between initiating a FAR project and a final promulgation was measured in years (i.e. longer than the 5 year term of the Administrator). The new tactic creates a “rule” crafted to that certificate holder and delivers the preventative fix quickly.
There is some magic to the process. It is wise, for example, to include a Human Resource representative on the SMS Committee; for he/she may well recognize that changing hiring criteria may be the long-term solution to QA/QC reoccurring errors. Employing someone better able to examine the part’s history may be the most effective answer.
However, the benefit of such input requires an experienced facilitator to manage the dialogue. It takes time to create a safety culture in this committee and throughout the company. An outside expert must be able to cite past SMS work to convince the SVP of Operations or the CEO to participate in meetings. It’s not just that your presence will assure that all are prepared and participate, but that by taking time from your schedule, the rank and file will have to recognize that safety culture is important.
The significant omission from the article is the importance of data. The most effective SMS regimen begins with data; through ASAP, FOQA and other compendiums of what similarly situated P121, 125, 135 or 145 organizations, hard numbers help identify and prioritize risks. By looking at the universe of A-320s or B-777 reported problems, all experiences are accumulated. As the basket of such issues grows, the prediction of risks becomes more reliable.
Without this objective inception point, the list of “what should be addressed in what order” becomes a debate based on subjective impressions. If the trend lines are clear, both the order in which to review risks and the quantification of the responses are easier to assess. Thus, it is important for the certificate holder identifies someone who can find the relevant numbers and analyze their significance.
Finally, the goal of an outside SMS apostle is to inculcate the processes and values of this state-of-the art discipline within the organization and then to get out of the way. Relying on an SME to do all the work is not the right path to safety culture. The committee and everyone in the organization must be actively involved in being aware of potential risks, identifying them to the committee and investing in the solution selected.