The Department of Transportation’s Secretary Foxx, the FAA Administrator Huerta and A4A President and CEO Nicholas E. Calio held a press conference on the issuance of the long-awaited final rules for air carriers to implement Safety Management Systems. The new Part 5 is a much awaited advancement of safety, extending compliance with the FARs to a more systematic, carrier specific process which will expand its perspective to its operations and its unique risks. The 89 page document focuses heavily on data and documents, material with which the FAA is comfortable.
This huge emphasis/focus on collecting and managing data ignores a more important (perhaps the most important) ingredient of SMS—people and a personal commitment to safety. The bigger benefit of an SMS, if the right management is in place, is creating a culture that thrives on SMS as part of its day to day operation.
Collection and management of safety event data will provide the necessary information and trends to manage and mitigate risk. Equally if not more, importantly is creating a strong corporate safety culture, something that may be very esoteric and hard to quantify (i.e. hard for the FAA to surveil). The FAA in overseeing the implementation of the SMS final rule must develop ways to assess and gauge the safety culture of the certificate holders it oversees, something that has not been discussed, publicly yet, on how it plans to do that important task.
A program, such as data-based safety program, has a start and end date. At the end of the year, the carrier reviews how it is done. In contrast, safety culture is an environment based on a philosophy that permeates the daily activities of the organization. Safety does not exist in a vacuum; while numbers can be portrayed on a dashboard, the constant attention/awareness of what is being done cannot be so represented. Safety culture is something that is top-of-mind of everyone (CEO to baggage handler and everyone in between).
Other elements of the organization, including people and financial management, impact safety and they must be involved in and committed to achieving belter and better safety performance in their job functions, no matter how peripheral they may appear. Therefore, a safety culture must be a part of the overall corporate culture to be understood and accepted as a high priority, every single day, not just when an event takes place.
Why is having a safety culture important? Every year, more than 4.1 million suffer serious job-related injury or illness. Such numbers may not seem relevant. But if you are working in a risk, safety or HR office, think of how much time and how many resources you and your organization spend on workers’ compensation claims. Just think how stressful it is on you and your team when a colleague is suddenly away from work for an undetermined period of time.
A safety culture is not a collection of policies and programs. Things like an Accident Prevention Program (APP), ASAP (Aviation Safety Action Plan) injury prevention programs, Personal Protective Equipment programs (PPE) and ergonomic programs can be components of a safety culture and may even be a regulatory necessity. Those are tools, but in order for these utilities to be optimized for safety, everyone has to develop and exercise a safety attitude.
These are tools that can help reduce risk and ensure regulatory compliance and can be vital in building and sustaining a safety culture. But these tools alone do not make a safety culture.
The key elements of a safety culture which are commonly recognized and necessary to create and nurture a safety culture include:
- Commitment (buy-in) at all levels
- Treatment as an investment, not a cost
- Integration into continuous process improvement
- Training and information for all
- System for hazard prevention and control
- Blame-free work environment
The FAA and air carriers alike must not be so focused on just collecting and managing data. Do not forget that the overall goal of SMS is building an organization that focuses on safety by every employee and as part of its company business plan and process every day. If the culture is strong, then the incident and accident rates will be driven down – data alone won’t be the answer- and the FAA needs to develop metrics (which maybe more visible secondary impacts) to assess and measure the safety attitudes of the organization!
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