Part 5 requires that an Accountable Executive be named
Accountable for effective SMS implementation
Like Financial Audit, Safety Culture Audit is a BEST PRACTICE
So you are the accountable executive of a Part 121 air carrier, as required by 14 CFR §5.25. That’s a critical safety position with signifcant responsibilities within your company. The FAA looks to you for assuring your certificate meets Part 5 and all of the other applicable FARs.
Under those rules, the accountable executive, must have the following resources under their direct control:
(1) Has the final authority over operations authorized to be conducted under the certificate holder’s certificate(s)
(2) Controls the financial resources required for the operations to be conducted under the certificate holder’s certificate(s).
(3) Controls the human resources required for the operations authorized to be conducted under the certificate holder’s certificate(s).
(4) Retains ultimate responsibility for the safety performance of the operations conducted under the certificate holder’s certificate.
And, the accountable executive, is responsible to:
(1) Ensure that the SMS is properly implemented and performing in all areas of the certificate holder’s organization.
(2) Develop and sign the safety policy of the certificate holder.
(3) Communicate the safety policy throughout the certificate holder’s organization.
(4) Regularly review the certificate holder’s safety policy to ensure it remains relevant and appropriate to the certificate holder.
(5) Regularly review the safety performance of the certificate holder’s organization and direct actions necessary to address substandard safety performance in accordance with §5.75.
And, the accountable executive must have a team to:
(1) Coordinate implementation, maintenance, and integration of the SMS throughout the certificate holder’s organization.
(2) Facilitate hazard identification and safety risk analysis.
(3) Develop and monitor the effectiveness of safety risk controls.
(4) Ensure safety promotion throughout the certificate holder’s organization as required in subpart E of this part.
(5) Regularly report to the accountable executive on the performance of the SMS and on any need for improvement.
As the accountable executive under the company’s SMS written processes, you should attend your airline’s quarterly safety performance review, (14 CFR§5.73). The meeting involves a detailed and comprehensive review of all aspects of operations, maintenance, training, human resources, inventory, fleet management, finance, internal auditing (a skill in your resume) and all related functions. You should have a team of professionals who are highly competent in their disciplines, capable of critical thinking, extraordinarily insightful in their analyses of the SMS data and, most importantly to you, trustworthy.
The next Monday morning, the accountable executive opens the file of articles about your airline that the PR department sends everyone.
In reading these reports, the following statements caught the accountable executive‘s attention and created immediate concern and Excedrin headache:
- “an unusually high number” of its planes, Airline was forced to declare a maintenance “emergency”, demanding all scheduled mechanics and inspectors to show up for work.
- Inaccuracies ranged from a few dozen pounds to more than 1,000 pounds in excess of what the paperwork indicated.
- Systemic and significant mistakes with employee calculations and luggage-loading practices
- “We have been experiencing an unusually high number of out of service aircraft over the last few days. Due to this number of out of service aircraft, our operation requires all of our scheduled aircraft maintenance technicians and inspectors. I am declaring Line Station 1 in a state of Operational Emergency
- I’ve seen people walk off the job, held on suspension for a month or more because they’ve reported problems that supposedly were outside their scope for work.
- The Company continues to insist on massive offsets of foreign outsourcing and elimination of your paid rest. The Company asks for these ‘offsets’ while not increasing the money in any significant fashion from the Tentative Agreement (TA) that you, the membership, rejected by a wide margin.
- “On an average day, the airline plans for as many as 20 aircraft to be unexpectedly out of service for maintenance items. Each day this week, the percentage of out-of-service aircraft in our available fleet, has more than doubled the daily average with no common theme among the reported items,” the spokeswoman explained.
- Disputes arise between the company and some agency inspectors about potential safety consequences,
Clearly there is some cognitive dissonance in the existing system reporting to the accountable executive and that difference between the internal process reports and the external sources cannot remain unresolved. It’s the Accountable Executive’s responsibility to ensure that there is a positive Safety Culture within the airline.
The accountable executive realizes that in order to reassess the existing system it would not be appropriate to repeat the prior-relied upon processes. The accountable executive recognizes that ONLY an external SAFETY CULTURE ASSESSMENT (SCA) would show the FAA, and frankly the Accountable executive, that the external “reports” are not accurate. An SCA will also identify gaps and shortfalls in processes, organization(s), leaders and individuals for which added scrutiny and/or training may be required. It provides an unbiased opinion of the rank and file about the organization.
In many cases the accountable executive will likely opine that conducting an SCA is redundant and a waste of money until the spate of critical articles asserting serious safety deficiencies arise or worse a serious event or accident takes place. Just like an external audit of the airline’s finances duplicates the internal accounting procedures and processes, conducting an annual SCA is an essential part of corporate markers of excellence.
An external SAFETY CULTURE ASSESSMENT unveils existing safety concerns within the company, perceptions that may exist toward the company’s current safety posture, the likely amount of resistance, if any, to any planned operational changes, and how best to build the “human” into the company’s mission, vision, core values and planned objectives.
AN SCA provides enormous benefit in terms of qualitative and quantitative data and hopefully a level of assurance essential to airline safety and a critical reaffirmation of the accountable executive’s best efforts.
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