Safety Management Systems: The Future of Air Safety – Part II

SMS Forces Changes for Regulators Just as operators are being asked to incorporate safety management systems (SMS), so too are regulators with Transport Canada at the leading edge of not only helping operators incorporate such systems but in reorganizing itself to a new oversight methodology that...

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SMS Forces Changes for Regulators
Just as operators are being asked to incorporate safety management systems (SMS), so too are regulators with Transport Canada at the leading edge of not only helping operators incorporate such systems but in reorganizing itself to a new oversight methodology that accommodates SMS. During the recent Air Charter Safety Foundation forum, Transport Canada’s Technical and National Programs Chief Jacqueline Booth-Bourdeau recounted the Canadian experience while Don Arendt of the FAA’s Flight Standards Certification and Surveillance Division outlined similar efforts in the U.S. Related Story
Transport Canada has a decade of experience in developing and implementing safety management systems which, said Booth-Bourdeau, is intended to help companies understand their flight safety risks and deal with those risks through an integrated management system.” She described an SMS as “a documented process for managing risks that integrates operations and technical systems to ensure aviation safety and the safety of the public. The SMS process is the infrastructure and the safety culture is making it all work effectively. Everyone has a safety culture – good bad or indifferent.”
A good system, she said, includes several principal components including a safety management plan, document management, training, quality assurance and emergency preparedness. The first outlines company safety policies and assigns the roles and responsibilities for those held accountable for the implementation and enforcement those policies. Such a document describes the SMS process, safety performance targets and how they will be measured and reviewed.
“You can have a system that is compliant but that doesn’t mean it is measurably effective,” she said.
As for documentation, which includes all printed materials pertaining to the safety of flight, the first step is to identify the applicable regulations, including standards and exemptions, and where required, procedures for demonstrating compliance. There must also be a system for changing documentation as federal or manufacturer bulletins, airworthiness directives and advisory circulars are issued.
“Safety oversight now is a reactive process of hazard reporting,” she said. “What we are doing is proactive safety assessments and combining them with the reactive process. SMS is about anticipating, understanding and managing the risk.”
The pro-active process includes hazard identification, a hazard register, safety risk profiles, which prioritizes those hazards and helps establish a battle plan not only in dealing with those hazards but with changes in the operating environment such as annual growth, new aircraft, or loss of personnel. In other words, she said, managing them in a way that minimizes risk.
Booth-Bourdeau emphasized that training should include investigation and analysis techniques, human and organizational factors, business processes, reporting techniques, and auditing techniques. It could also include line oriented safety analysis (LOSA) and Flight Operations Quality Assurance techniques and give everyone an awareness of how each system works, not just the regulated areas.
“They must understand how all parts of the company impact risks,” she said. “That includes how marketing impacts safety and making a safety case for choosing a new route, for example. Everyone has to be trained to participate in that system. The role of the operator is to understand and mitigate the risk. Regulators should not be doing the quality assurance for the operator.
Transport Canada will no longer conduct compliance audits. Instead, the agency is looking at whether or not an operator understands and manages risks as well as the processes in place to accomplish this.”
She also outlined the importance of emergency preparedness. “This preparation should, through good planning, reduce, control and mitigate the effects of the emergency,” said Booth-Bourdeau. The Emergency Response Plan should also be monitored and changed as the operation changes, be subject to regular exercises, and address all interested parties including the public, families, regulators and investigators.”
Booth-Bourdeau outline lessons learned, including how important it is to have industry involvement from the outset. “We also learned that the regulations and standards had to be the same for all operators,” she said. “We also focused on training regulators and inspectors for this new environment.” In addition to training for inspectors, Transport Canada has also conducted quality assurance – more familiar in the maintenance arena – for flight operations offices.
A new regulatory mindset is required for SMS which replaces the old records review approach, she said, adding that Canadian operators also developed SMS training for inspectors on what knowledge they needed to do their jobs. The inspector training also includes interview skills and what questions to ask in order to properly assess an SMS program. Instead of a records review, inspectors will be measuring where a company is with its safety culture.
She described the executive accountability, saying responsibility lies with the person responsible for the financial and executive control over all certificates. In addition, internal oversight committees should include designated representatives from the board of directors as well as local airport councils and municipalities. The infrastructure should also include a safety services office including the directors of operations and maintenance as well as a flight safety officer and a maintenance safety officer.
The agency has already issued guidance materials for the interpretation of regulations on the implementation of SMS which is available on the Transport Canada web site. The guidance for small aviation operations resulted from the creation of a Small Operators Working Group. The agency also developed a company complexity scale to illustrate what is expected of a small entity versus a large one.
The agency not only conducted a regulatory review to ensure they can accommodate SMS but a legislative review as well, both in an effort to make revisions to reflect the SMS methodology. “You have to determine if your existing oversight framework is adequate to asses SMS,” she said. “The same is true of the legislative framework. Can it manage the transition and reallocate resources to accommodate the changes to SMS from a more traditional oversight program.” As for regulators, the agency must now have a risk assessment attached to all new regulatory activity.
Transport Canada has identified and used industry champions, who speak on SMS, including the good and bad parts as well as the learning experience which has helped with industry acceptance and the relationship between industry and regulators.
“Future assessments will be on the processes used and will balance manual review with on-site interviews and observations,” she said. “The aim is to reward companies that have gone beyond compliance and incorporated best practices. We have to see a change in the safety culture.”
As FAA moves towards an SMS system, FAA’s Don Arendt said, it, too, will be focusing on processes, systems, conditions and confidence as it seeks to understand how an operator does business and whether or not its methods lead to an effective safety culture.
“We want to understand the processes; what people do,” he said. “We also need to understand the systems – the way people do the processes. We are also trying to understand the company’s appreciation of hazards such as terrain and the workplace and how they threaten safety. Finally, we are looking at not only the objectives of safety assurance but how a company audits itself to ensure its processes and systems are effective. With that comes the confidence that you are doing all you can to identify and control the hazards throughout the life cycle of a program or a flight.”
Arendt said such a system contains four pillars on which to build a safety management infrastructure – the policy and management commitment, risk management, safety assurance and safety promotion.
Arendt pointed to the importance of data collection and trend analysis as key to understanding how the organization thinks about safety and whether or not, it follows through with corrective action when it finds a problem.
Plans for rulemaking efforts covering for Parts 135 and 145, following on the Part 121 effort have been replaced by a rulemaking effort for all CFR parts. The effort will likely results from an as-yet-to-be-formed Aviation Rulemaking Committee. It is also working toward harmonization with ICAO standards.