When SMS Stays On The Shelf

Products that do not generate revenue greater that the cost of the shelf in a supermarket are removed from the shelf. If a product is required to be carried to conform to regulatory requirements, the product may be sitting on the shelf untouched as a dust collector. SMS is in the same boat since it was introduced as a regulatory requirement. As a regulatory requirement the SMS might just sit on the shelf and collect dust since an enterprise keeps it there without a return on investment. That the SMS is put on the shelf does not imply that the SMS processes are ignored, that hazard and incident reports are not processed, that root cause analysis are not conducted or that personnel are not trained in SMS. All this is happening while the SMS is sitting on the shelf. An enterprise that has placed the SMS on the shelf is an organization that is not able to identify and describe what the SMS does for the operator. SMS is intended to be a program for improved safety in aviation. If the implementation of a safety program does not directly contribute to safety improvement, the program has become nothing else but a paper-shuffling task and labor-intensive ticking checkboxes. The one reason SMS is kept on the shelf is due to regulatory requirement by the Aviation Authority (Government). The SMS stays on the shelf even if it does not serve customer service or produce what the cost of the shelf is. This cos is not to produce a positive return of investment, or cash flow, but also with reference to return of safety-investment or continuous improvements.

SMS is a system where discrepancies are clarified.

The safety management system has been described as an umbrella of the operations. The purpose of an umbrella is to shield, protect, buffer, shelter or safeguard. If an SMS operating as an umbrella the enterprise has a system in place to ensure a safe flight for all passengers and freight. When the SMS is an umbrella, the system functions and protects without any further actions. It’s a wonderful system. Or, maybe not…a system that protects is not a fail-free system and may give a false impression that safety is paramount in existing operations, while the opposite could be the actual fact. If the SMS is controlled by the umbrella, an enterprise, operational systems must unconditionally follow the umbrella wherever it goes. This is the old way of looking at safety, where safety is the “big-bad-wolf” who directs operations in all different safety directions. Or, on the other hand, if operations under the umbrella are in control of where the umbrella travels, then safety decisions rests with the operations, which is the NextGen of aviation safety. The purpose of the umbrella is oversight of safety processes, and not the safety in operations itself. When SMS takes on this role, it becomes the Quality Assurance program.

Generally speaking there are two ways to operate with a safety management system. One way is to apply SMS as a duplicate control system to discover if there are any errors in the first audit. This is a method when the SMS system conducts audit of operations and validates or invalidate the current result. It becomes a control system of the first or prior checks conducted. If both results come up with the same conclusion it is assumed that the first result also was correct. If the second result is different than the first result, it is assumed that the first result was incorrect and a corrective action plan (CAP) must be implemented. This CAP is not a process or system CAP, or a CAP of how the task is performed, but a CAP of the failure itself. If the issue was a light bulb, this CAP would replace the burnt out light bulb, but not address the issue of why a newly replaced light bulb burned out. This is when safety is covered under the umbrella without directions and difficult to define how SMS improves safety.

1)        Time how long it takes to spot the 6 differences;

2)        When differences are spotted, time it again how long it takes to spot the 6 differences;

3)        This is SMS – to spot the differences and it only becomes more effective with training.

The other method of applying SMS within the organization is to apply SMS as the oversight body of safety processes. Operations establish processes for acceptable safety levels, and the SMS assess these processes in an oversight capacity. The SMS process is to audit all operational processes by random sampling of selected operational audits. If there are only a handful of audits conducted the process would audit all the samples. As a system audit of operational safety checks, this audit would establish if the organization is performing safety tasks to acceptable risk levels established by organizational policies. E.g. If there is an annual company flight-check scheduled, the audit would discover if these flight checks were conducted. The flight check result of the audit is irrelevant to a system audit, since this task, or CAP, was already performed by flight operations and based on the flight check result.  If the system audit found that the flight checks were conducted to a 95% confidence level of all operational checks, then the system in in statistical control. Should the process be out of statistical control, then a CAP must be initiated to move the line to an acceptable safety risk level.

As a Quality Assurance system the SMS has an opportunity to change incompetent processes. However, if keeping SMS on the shelf for reasons of regulatory requirement only, the SMS in itself becomes a hazard to aviation by its travel in the wrong direction at the fork in the road.