A Discussion Document by Steven Bentley - MD of Sofema Aviation Services

Do we agree on the purpose of an Aviation SMS?

1/ According to ICAO

ICAO Doc9859 para 2.13.2 - ‘A hazard is generically defined by safety practitioners as a condition or an object with the potential to cause death, injuries to personnel, damage to equipment or structures, loss of material, or reduction of the ability to perform a prescribed function.’

ICAO Doc9859 para 2.14.2 - ‘Safety risk is the projected likelihood and severity of the consequence or outcome from an existing hazard or situation.’

2/ The Airline View

We should all essentially agree that the overriding purpose of the Safety Management System is to ensure both the operator and all subcontractors conduct safe and secure operations and minimise exposure to any perceived hazards.

So what is the problem? (If there is one)

Well, maybe the first issue is that the basic terms and concepts are not fully understood. It is the view of the author that an effective SMS is not only the best management tool available to combat the “iceberg of ignorance”. It affords multiple opportunities to improve performance across the business. As well as ensuring that we understand all the safety risks faced by the operation and its subcontractors.

As an SMS trainer who has had 100’s delegates attending Sofema Training courses a consistent lack of comprehension is evident for example how sure you of the meaning and difference of the following:

a) Hazard / Risk

b) Quality Assurance / Safety Assurance

c) Compliance / Performance

Does it matter? Well yes, maybe it does if we want to have a comprehensive understanding of how we can use the SMS to drive performance across the business.

So let’s clear it up now:

a) Hazard / Risk

A Hazard is anything that has the “potential” (It does not mean it will!) to cause harm to the business whether it is related to the safety of the operation, the safety of the person, or the safety of the balance sheet. We are surrounded by hazards, even though we can say that hazards are a normal component of an operation (Here there is a potential element of confusion as we often talk about “The need to report Hazards”) - In fact what we mean is related to “an obligation to report hazards, but only where there is perceived to be an unacceptable level of risk” – which leads to the next comment.

Risk is related to how likely a “particular hazard” can hurt the business – Risk is not real, it is a “tool” to provide a subjective assessment (conversely a hazard is of course real!).

Risk is in the “eye” of the Beholder

The challenge then is to educate our team to understand the nature of risk related to any perceived hazard and to be willing to report hazards where they feel that the risk for any given situation is not acceptable.

b) Quality Assurance / Safety Assurance

Quality Assurance is the independent assessment of compliance both externally with regulatory requirements and internally with the organisations written process and procedures. The key element here is that “independent” QA is NOT part of the Production Delivery Process (This in fact is Quality Control (QC).

Safety Assurance is the Assessment of Risk (or Exposure) to a given real or hypothetical situation for example what is the risk of “Ground Damage to the aircraft”.

To assess the Risk we need to determine the effectiveness of the preventative barriers. Training, Competence, Strength of Procedures, effectiveness of oversight, and management are all examples of barriers.

What Safety Assurance is Not?

Safety Assurance is not carrying out audits against a “Compliance” checklist – this is Quality Assurance of a Safety Objective (Understanding this difference is a big step in the right direction).

So checking Safety Barriers are in place is QA and determining the likelihood that Barriers may not be in place is Safety Assurance.

c) Compliance / Performance

Compliance is related to following the rules whether they are “external” rules or our own “internal” rules. Performance on the other hand is asking the question how well are we doing?

We need to develop organisational tools by which we can measure “Performance“An example would be to develop a range of Key Performance Indicators (KPIs). Which could be based on Service Level Agreements (SLAs) or other agreed measures.

So that covers some of the fundamentals, now where are the challenges?

•       We agree on the principles but how to effectively deliver

•       Policy is relatively easy to document but needs to avoid “copy-paste”

•       Marketing – a challenge to communicate vertically throughout the organisation

•       Assurance and Risk management – difficult to achieve with the need to drive competence within the Safety Expert Group)

•       Introducing a Safety Culture which will not work if it is “enforced” it has to be led from the top and embraced by all otherwise it WILL fall short of expectations

•       Develop a willingness to accept a proactive risk identification and safety management culture

Conclusion

An effective SMS should not be a complicated process, It should be understood by the team (currently this is not the case – there is work to do) and focus on understanding where are the real exposures throughout the organisation.

Remember the 80/20 Rule – 80% of the exposure can be mitigated with 20% of the effort!

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