Tuesday, April 1, 2014
Essentials of A Good SMS Program
Implementing a Safety Management System into an organization, large or small, will help save lives and resources.
|Embry-Riddle Aeronautical University booth at Heli-Expo 2014.
Photo by Frank Lombardi
FAA Advisory Circular 120-92A provides a framework for SMS development by aviation service providers. It contains a uniform set of expectations that align with the structure and format of the International Civil Aviation Organization (ICAO) SMS Manual and FAA Safety Policy.
SMS is a risk management process that many military services used effectively for years, but may have called it by a different name. There are a few differences with the military program but the basis of indentifying hazards and taking the appropriate action to mitigate these hazards remains the same. SMS is divided into four building blocks or “Pillars” and are essential for a safety-oriented management system. They are Safety Policy, Safety Risk Management, Safety Assurance and Safety Promotion.
First, let’s look at Safety Policy. This establishes senior management’s commitment to continually improve safety, it defines the methods, processes, and organizational structure needed to set standards and meet safety goals. Its design expectations are to continually improve the level of safety, comply with applicable regulatory requirements, establish clear standards for acceptable operational behavior for all employees, identifies responsibility and accountability of management and employees with respect to safety performance. It also requires the appointment of key safety personnel. Finally, it also must include a commitment to encourage employees to report safety issues without reprisal.
Next, Safety Risk Management determines the need for and adequacy of new or revised risk controls based on the assessment of acceptable risk. It’s a formal system of hazard identification and is essential in controlling risk to acceptable levels. It works together with Safety Assurance, which evaluates the continued effectiveness of implemented risk control strategies and supports the identification of new hazards. It strives to continually improve the SMS process.
Finally, Safety Promotion includes training, communication and other actions to create a positive safety culture within all levels of the workforce. It assesses climate, evaluates training and observes communication. It re-emphasizes the “top down bottom up” safety module.
SMS has four levels of implementation. Level One begins when a service provider’s top management commits to providing the resources necessary for full implementation throughout the organization. Level Two specifies that the service provider develop and implement a basic Safety Risk Management (SRM) process and plan, organize and prepare the organization for further SMS development.
Level Three promotes proactive processes and incorporates a fully-functioning SMS component. It involves careful analysis of systems and tasks involved such as identification of potential hazards in these functions, and development of risk controls. Level Four involves continuous improvement and continued assurance. Processes are in place and their performance effectiveness has been verified. This is the final level of SMS maturity.
At the recent HAI Heli-Expo in Anaheim, Calif., SMS was presented in many of the Rotor Safety Challenge sessions and there were several SMS courses conducted by contracted vendors. “The Squadron” was one of these companies teaching applied risk management and facilitation of a safety culture and awareness into various organizations. Other SMS sessions were directed at small fleet or private operators.
The SMS function does not need to be extensive or complex to be effective. Smaller organizations may use a paper log to document safety issues and paper system or simple spreadsheet or to track them to resolution. Also, in smaller organizations the owner and company leadership may elect to conduct internal audits and internal functions themselves in conjunction with the management review function. It is these smaller organizations that I believe the focus needs to be on. A recent HAI survey indicated that 43 percent of small operators or private owners are not using any type of risk assessment tool in their operations. To me, this was quite alarming considering the availability of safety programs in the industry today.
Internal evaluation and management reviews may consist of periodic conferences between business owners or top management and other employees to review information and to track progress toward resolution. An integral part of SMS to identify risks and hazards are gathered by internal or external audits, incident investigations, and employee reporting systems. After this information is gathered it is analyzed and assessed.
A larger organization may need more sophisticated resources such as web-based data systems and trained safety personnel to manage the details and a more formal committee system to accomplish the same functions. Implementing an SMS program from an operator’s perspective involves a commitment from all involved. It involves much work, but it’s necessary to establish a good safety management program. First, a draft SMS implementation plan must be developed then the costs need to be identified, followed by a funding plan and approval by the accountable executive. An SMS organizational structure must also be in place and includes a safety office, safety manager, safety review boards and safety action groups.
Why do some pilots not “buy into” the SMS program? I believe there is no safety culture mentorship practiced when a young student pilot is receiving flight instruction. Mainly because many new flight instructors are conducting the training and they do not have a safety culture established yet. Certified flight instructors (CFIs) are the closest link to the development of pilots in training.
Bringing forward an SMS or Personal Risk Management system will prepare pilots to apply industry best practices in safety throughout a flying career. With all the information about SMS available today, adding SMS instruction to a pilot in training may seem overwhelming – but it doesn’t have to be, and the CFI’s responsibility is to train and produce safe pilots. The U.S. Helicopter Safety Team (USHST) has recently published a document to aid CFIs with SMS. This document explains how to bring SMS Risk Management to the training of all pilots, ab initio to advanced levels.
Another issue is that some smaller operators do not fully understand SMS and how it they can benefit from it. However, I was glad to see Heli-Expo attendees from various aviation organizations such as the oil and gas industry, law enforcement, other government agencies, utility organizations and helicopter operators with less than five aircraft participating in SMS training. Operators face challenges with implementing SMS such as perceived extra work, employee “buy in” and funding, to name a few. It takes time to establish a safety culture and many operators just do not understand this.
As we look at the helicopter industry as a whole, there are many operators that are successfully using SMS in their daily operations. Metro Aviation is one of these companies. Metro initiated its SMS program in 2009 and is now at Level Four. The company is one of the few rotary wing operators who achieved this level. Metro has a safety commitment from leadership that permeates throughout the organization. This is evident as the owner of the company has his cell phone number in every aircraft operator’s manual. This aids in employee involvement and “buy in.” Metro’s employee reporting system is effective and management always responds to the reports. The company also promotes a “just culture” and employee accountability for safety management.
Another commercial operator who has an extensive and effective SMS program Phoenix Heli-Flight, which has been using SMS since 2009. SMS has helped the company gain transparency throughout the company when practicing safety management. Phoenix Heli-Flight has an excellent hazard employee reporting system that covers hazards, occurrences and non-compliance. They too, promote a “just culture” and employee accountability.
Implementing a Safety Management System into an organization, large or small, will help save lives and resources. It will also help pilots, young and old, develop Risk Management skills which are in great demand in the helicopter industry. SMS is not a stand-alone program. It must include many other factors of managing safety, such as flight data monitoring (FDM), crew resource management (CRM), maintenance safety and the most recent initiative from HAI “Land and Live,” among others. SMS is part of a safety culture a company must have. SMS does not have to be complex to be effective. SMS is here to stay and may be mandatory within the rotary wing industry in the near future, so let’s get on board and use it. As always, Take Action to Fly Safe!