Having spent a great deal of time and effort in establishing your organisation’s Safety Management System (SMS) it is now perhaps worth examining if it is functioning as first envisaged.
There are a number of reasons why a SMS might not deliver exactly what was first hoped for and as part of the ICAO requirement to ensure continuous improvement you should conduct a detailed analysis of your system to determine any potential shortfalls. Furthermore, revision 1 to ICAO Annex 19 is scheduled to become applicable on 7th November 2019 and this latest issue contains further requirements on both State Safety Programs (SSP) and service provider SMSs.
This article will focus on five of the main reasons why a SMS might not perform as expected or meet emerging requirements in the near future:
Limited Management Buy In: The airline industry is fiercely competitive, and many managers are faced with increasing demands from shareholders and senior executives to deliver more with less resource. Their efforts become focused in the wrong areas and the need to generate profit can lead to a complacent attitude towards safety. Quotes such as, “we have had no accidents, so we are safe” and “safety does not contribute directly to the bottom line” must be discouraged although this can be difficult to achieve.
Managers must embrace the SMS as part of their everyday business systems and they must be seen to encourage their employees to accept that safety is everyone’s responsibility. This does not just apply to the flight operation; the entire organisation must be fully engaged in the promotion and conduct of safe practice.
Ask yourself just how well engaged are your employees and are your safety policy and objectives clearly defined and freely available to all?
Poor Reporting Culture: Unless employees are encouraged (or even rewarded) to submit reports, the SMS will never improve. Employees are the front line of the business and they will be the first to note and, hopefully, report hazards or safety issues. A healthy reporting culture will result in an increase in voluntary reports that, in turn, will alert management to potential hazards that can be risk assessed as required. This can only be achieved by the establishment of clear guidelines as to what is acceptable and unacceptable behaviour; sometimes referred to as a “just culture”.
It is very important that the workforce have trust in their management and believe that they can report issues without fear of reprisal. It is not easy to establish a good reporting culture and traditional mistrust between unions and management can influence negatively this important feature of the SMS. Initiatives such as the FAA’s Aviation Safety Action Program (ASAP) are helping to remove these traditional barriers with good effect. Of course, the ability to access and use suitable reporting mechanisms is vital. A well-designed reporting software package that is easy to use and available in both tablet and desktop formats (on and off-line) is considered a primary requirement of any SMS.
Is your culture supporting or hindering your safety management system?
Data Rich Information Poor. Many organisations will experience a sudden surge of voluntary reports from all aspects of the business if the SMS is implemented appropriately. Many of these reports will contain what may appear to be inconsequential information. However, it is only by examining these reports in detail that the safety teams may be able to determine underlying trends that could be indicative of something more sinister. These underlying trends are referred to as ‘Latent Issues’ and by identifying them in advance, it may be that action can be taken before they manifest as a serious incident or accident. It requires a considerable amount of time and resource to complete this type of analysis unless your SMS is supported by a software package designed to meet this need. A well-designed software package will help the safety team to extract the necessary information from the safety database to complete suitable trending and analytical processes. Having extracted the required data, there is then a need to present this information in a suitable format to help the decision makers reach the correct conclusions. This could be in the form of a dashboard or a management presentation/report.
Although your SMS will focus on safety reports, there are many other sources of safety information that need to be considered; these include, Line Operations Safety Audit, Safety Surveys, Internal and external audits. This can result in a huge amount of safety data, hence, the expression, “data rich but information poor”. This large amount of data, gathered from disparate parts of the business, must be classified, stored, retrieved, analysed and then presented to senior management in a format that can be understood.
Does your software package have the ability to store, extract and format the data for suitable analysis?
Poor Decision Making: It is often the case that poor decisions made in higher management can have detrimental effects on the safety performance of an organisation. Indeed, a focus on cost savings and regulatory compliance can result in an oversight or even complacency when it comes to safety. This is not intended to be a swipe at management it is merely an expression of the facts.
Unless management are presented with appropriate safety data that is digestible, accurate and complete it is highly unlikely that their decisions will be sound. This fact is pointed out very clearly in ICAO Document 9859 (4th Edition) which expounds the virtues of data driven decision making (D3M). In effect, when armed with the correct, useable information, managers can make informed safety-based decisions that are aligned to the organisation’s safety policy and desired objectives. D3M can assist with decision making in the following areas:
Changes that can be expected in statutory and regulatory requirements, emerging technologies or resources which may affect the organisation;
Potential changes in the needs and expectations of the aviation community and interested parties;
Various priorities that need to be established and managed (e.g. strategic, operational, resources);
New skills, competencies, tools and even change management processes that may be needed to implement new decision(s);
Risks that need to be assessed, managed or minimised;
Existing services, products and processes that currently provide the most value for interested parties; and
Evolving demands for new services, products and processes.
Unless your software package can present meaningful safety information to higher management, it is unlikely that they will be able to use D3M techniques and the knock-on effect could be an erosion in safety margins that go unnoticed until a serious event takes place.
Is your SMS providing the data in a format to senior management so that important safety decisions can be made?
Establishment of Safety Performance Indicators (SPIs): It is now a requirement for organisations to monitor their own safety performance and to demonstrate that they achieve an acceptable level of safety performance (and continuous improvement of the SMS) to their regulators.
The accepted means of achieving this is to establish and monitor suitable safety performance indicators (SPI) and their associated safety performance targets (SPT) that are aligned to the business safety policy and objectives. SPIs and SPTs should be defined using the SMART criteria i.e. they should be: Specific, Measurable, Achievable, Relevant and Time-Bound.
Whilst it can be relatively easy to define SPIs, it is more problematic to monitor them and then present the information in a useable format for management. Obviously, software can help but this process will require a significant drawdown on safety team resource unless the software is particularly well designed. Due to the work effort required, it is often the case that SPIs are either poorly defined or not monitored sufficiently. Not only will the presentation of SPI data enable better D3M, it will also assist with your regulator’s requirements for performance-based oversight.
Can your safety management system software achieve this requirement?
The above list is far from exhaustive, but it does highlight some of the more common issues that organisations experience when establishing their SMS. A common theme is poorly thought out software support. Unless your chosen provider understands the emerging requirements that will be become extant in November 2019, it is likely that your SMS will fail to meet the standards needed to satisfy your regulator. Furthermore, your management decision-making capability might not be focused in the appropriate areas to result in enterprise wide, improving safety performance.