MANAGING THE

SMSlec 15.
 Managing the SMS.

• There are several good reasons why we need to strive to achieve safety
(Brauer,2006, p. 21). First and foremost, our society places a high value on
human life, so it is considered humane to attempt to preserve that life. This
humanitarian reason is the moral basis for safety.

• Second, many governments have adopted laws requiring organizations to

identify and manage risks. We readily think of laws and regulations of this
nature applying to transportation systems such as aviation.

• Third, there are financial considerations for safety. Irrespective of which

industry one belongs to, it is simply bad business to be regarded as
“unsafe”. Being unsafe brings with it significant financial costs associated
with accidents, legal fees, replacement of equipment, higher insurance
costs, fewer customers, and so on.
 Management’s responsibility for
safety.
• SMSs are predicated on top management’s strong and visible commitment
to safety. No SMS will be effective without senior management devoting the
attention, time, and resources to safety as a core value of the organization.

• Safety as a core value.

• The core values of an organization are those ideals that form the
foundation on which the organization conducts itself. They are not
transient in nature; rather they are constants that define the
organization and govern its processes, behavior, relationships, and
decision-making. Core values are deeply ingrained in the
organization and are non-negotiable.
• Senior management establishes safety as a core value by making it
an integral part of the organization’s management system.
• Accountability versus blame.

• After the safety goals and objectives are established, management must
establish plan for accountability. Many people confuse the terms
accountability and blame; these terms have substantively different
meanings.

• Plans for accountability should be formal, specific, and comprehensive. All

significant safety activities should be clearly assigned to someone who is
responsible and accountable.

• Blame goes further. Blame is accountability deserving of censure, discipline,

or other penalty. Brenner (2005) suggests that blame and accountability
differ in at least four dimensions;
• Learning vs. punishment—As stated earlier, an accountability culture seeks
to learn from the situation so that it is not repeated. Blame simply seeks to
identify the culprit, and the process often goes no further.
• Incidence of fear—If someone is fearful of being held accountable, blame is
probably involved. There should be no fear in being held to account for
something.
• Organizational chart altitude distribution—Responsibility and accountability
are found at all levels on an organizational chart. When most of the people
we find accountable are concentrated at the bottom of the chart, it is likely
that we are actually assigning blame.
• Acknowledging interdependence—When we seek the learning opportunities
that are afforded by exercising accountability, oftentimes there are
numerous people accountable. When we seek blame, we’re usually
satisfied with finding just one person to punish.
• Recognition of management’s role in systemic failure. Dr. Deming, our well-
known quality guru cited frequently in this text, estimated that 85 per cent of
quality problems are created by management.
• So, if we want to change our circumstances, we must change the system,
not the worker. Who controls the system? Management! Managers must
recognize that the system is the culprit, and that they alone can change the
system. Management plays a vital role in establishing a safety ethos.
Management is vested with the authority and responsibility for managing
safety risks in the company. This is best accomplished through a robust
quality management-based risk management system.
Stakeholder identification and analysis.
• A stakeholder is “any group or individual who can affect or is
affected by the achievement of the organization’s objectives”. The
analysis of stakeholders involves the identification of the
stakeholders and the determination of their needs. This would seem
a rather simple task with respect to aviation safety..
• Some stakeholders are more concerned about some aspects of an aviation
operation than others. The persons responsible for ramp safety have more
immediate concern about a service cart running into the side of the airplane
than does the general public.
• Acknowledging interdependence—When we seek the learning opportunities
that are afforded by exercising accountability, oftentimes there are
numerous people accountable. When we seek blame, we’re usually
satisfied with finding just one person to punish.

• Recognition of management’s role in systemic failure.

• Dr. Deming, our well-known quality guru cited frequently in this text,
estimated that 85 per cent of quality problems are created by management.
So, if we want to change our circumstances, we must change the system,
not the worker. Who controls the system? Management! Managers must
recognize that the system is the culprit, and that they alone can change the
system.
• Management plays a vital role in establishing a safety ethics. Management
is vested with the authority and responsibility for managing safety risks in
the company. This is best accomplished through a robust quality
management-based risk management system.

• Stakeholder identification and analysis.

A stakeholder is “any group or individual who can affect or is affected by the

achievement of the organization’s objectives”. The analysis of stakeholders
involves the identification of the stakeholders and the determination of their
needs. This would seem a rather simple task with respect to aviation safety, but
it is not always so.
Some stakeholders are more concerned about some aspects of an aviation
operation than others. The persons responsible for ramp safety have more
immediate concern about a service cart running into the side of the
airplanethan does the general public.
• Some stakeholders are more concerned about some aspects of an aviation
operation than others. The persons responsible for ramp safety have more
immediate concern about a service cart running into the side of the airplane
than does the general public.
• Unfortunately, stakeholder identification is often overlooked in the planning
and execution of strategy. According to Bryson (1995), there are a number
of reasons for this omission, including not knowing how to do it, assuming
they already know who the stakeholders are and what their interests are,
lack of time, and concerns about what the analysis might reveal.
• Regulatory oversight.
• ICAO.
• ICAO has the responsibility and the authority to “ensure the safe and orderl
growth of international civil aviation throughout the world. One of the
primary means ICAO uses to achieve its mission is through the
development of Standards and Recommende Practices (SARPs), which
reflect the best operational experience of the states. SARPs are contained
in the annexes to the Chicago Convention.
• Because SMS thinking has grown out of various committees, sectors of th
industry, and even countries, the need to harmonize the global approach to
SMS was recognized by ICAO. ICAO believes that harmonization will lead
to a better and common understanding of SMS, more adaptable regulations,
increased information and data sharing, more rapid expansion of SMS
throughout the industry, and common training and education material.

• FAA.
• In the U.S., the governing authority for aviation is the FAA. At present the
FAA’s approach to SMS implementation is non-regulatory, however, the FAA
opened a Rulemaking Project Record in November 2006 and a Rulemaking
Project Team was assigned a month later.
• Rulemaking aside, the FAA is moving rapidly to introduce SMS, to support
pilot studies to develop and implement these programs, and to develop the
infrastructure to support them.
• Often a first step toward a regulation, the FAA issued an advisory circular,
AC 120- 92 Introduction to Safety Management Systems for Air Operators,
on June 22, 2006.
• The AC introduces the concept of a safety management system (SMS) to
aviation service providers (e.g., airlines, air taxi operators, corporate flight
departments, pilot schools), and provides guidance for SMS development
by these organizations. The AC applies to both certificated and non-
certificated air operators that desire to develop and implement an SMS.
• The order is entitled Safety Management System Doctrine, and is intended
to enable the agency to implement a common SMS in the Aviation Safety
(AVS) organization, standardize SMS terminology, set forth management
principles to guide AVS offices in their safety oversight activities, and explain
SMS principles and requirements.
• The agency also recently commenced a rulemaking project to consider a
formal requirement for SMS at airports certificated under 14 CFR Part 139.
The FAA anticipates issuing a notice of proposed rulemaking (NPRM) for
public comment in 2008. A final rule may be adopted after the agency has
considered all of the public and industry comments received on the NPRM.
The rulemaking process can take anywhere from several months to several
years.
• Oversight systems.

• ICAO distinguishes safety oversight, which is a function of the state, from

safety performance monitoring, which is a responsibility of the operator and
service provider. Oversight, then, is considered a function of the regulatory
authority.
• FAA Rulemaking. The FAA’s rulemaking process is complex and requires
input from the various stakeholders. Generally, the process involves:
• a petition to change a rule,
• publication in the Federal Register,
• FAA considers comments and decides whether or not to proceed with
rulemaking, an aviation rulemaking advisory committee (ARAC) is
sometimes formed to assist in developing the rule,
• departments within FAA review draft rule; FAA assigns a priority number,
• FAA studies economic impact and legality of new rule,
• other agencies (e.g., Office of Management and Budget, DOT) review
proposed rule,
• draft rule is published in Federal Register as Notice of Proposed
Rulemaking (NPRM)
• with comment period,
• comments are reviewed and NPRM is accepted as-is or revised and becomes final
rule,
• or rewritten and prepared as a new NPRM
• final rule is published in Federal Register,
• FAA prepares for rule’s requirements, e.g., training of inspectors.
• 9734-AN/959, ICAO identifies eight critical elements for a state oversight system
• (ICAO, 2006, p. iii). These are;
Primary aviation legislation.
Specific operating regulations.
Civil aviation structure and safety oversight functions.
Technical guidance material.
Qualified technical personnel.
Licensing and certification obligations
Continued surveillance obligations.
Resolution of safety issues.
• The oversight of the nation’s airlines is an important responsibility of the
FAA .In the past, FAA oversight of the airlines (and other operators)
involved an inspector, checklist in hand, watching the work of an employee
at specified intervals to ensure the work was being done properly.

• This method of oversight had serious limitations, including the fact that it
was outcomes-oriented, labor intensive, inefficient, and it didn’t tend to
foster a collaborative approach to safety management.

In 2002 the FAA introduced another component, the Surveillance and

Evaluation Program, to the inspection process. This change incorporates some
of the principles of ATOS into its inspection process of some airlines not yet
under ATOS, adding system safety concepts to inspections.
• Primary aviation legislation.
• Specific operating regulations.
• Civil aviation structure and safety oversight functions.
• Technical guidance material.
• Qualified technical personnel.
• Licensing and certification obligations.
• Continued surveillance obligations.
• Resolution of safety issues.

• The oversight of the nation’s airlines is an important responsibility of the

FAA. In the past, FAA oversight of the airlines (and other operators) involved
an inspector, checklist in hand, watching the work of an employee at
specified intervals to ensure the work was being done properly.
• Safety oversight is one of the cornerstones of an effective SMS program.
Safety oversight has several purposes

• Demonstrate compliance with rules, regulations, standards, procedures,

and instructions.
• Provide an additional method for proactively identifying hazards.
• Validate the effectiveness of safety actions taken.
• Evaluate safety performance.

• ICAO and the state share oversight responsibilities. ICAO carries out its
• responsibility via the ICAO Universal Safety Oversight Audit Program
(USOAP).
• Organizations employ numerous methods for monitoring their safety
performance. These methods vary widely based on the size and complexity
of the organizations. Primary means include;

• Quality assurance.
• Vigilance.
• Inspections..
• Surveys..
• Data analysis.
• All aviation organizations can establish methods for collecting data that can
be used by managers to determine the safety performance of the
organization.
• Safety audits. Develop identified safety performance indicators and targets.
• Monitor adherence to safety policy through self-auditing.
• Allocate adequate resources for safety oversight.
• Solicit input through a non-punitive safety reporting system.
• Systematically review all available feedback from daily self-inspections,
• assessments, reports, safety risk analysis, and safety audits.
• Communicate findings to staff and implement agreed-upon mitigation
• strategies (14 CFR Part 139 already requires this for actions covered by
that regulation).
• Promote integration of a systems approach to safety into the overall
operation of the airport.
• Safety studies, and others.
Promote integration of a systems approach to safety into the overall operation
of the airport. Safety studies, and others.

Figure 9.2 represents the FAA’s view of the relationship of system for certificate
operators. On the “protection” side of the model are the FAA’s SMS-O
(oversight),with its objective of public safety, and the operator’s SMS-P
(provider), with its objective of controlling safety risk. These systems interact
with one another through audits and approvals.

On the “production” side of the model are the process activities that produce
products and services, with the objective of serving customer requirements.
These processes interact with the SMS-O through direct sampling such as
surveillance, and with the SMS-P through internal safety assurance, risk
management, and safety promotion (see Figure 9.2).
• Roles, responsibilities and relationships.

• Aviation systems today are highly complex and complicated structures involving
numerous stakeholders, and a high degree of interaction among various
organizations.
• SMS acknowledges this shared responsibility, and specifically describes the
roles, responsibilities, and relationships between all stakeholders involved in
maintaining safe operations. In SMS, each interface between production
and operation on the one hand, and oversight on the other, is clearly
identified, and each subsystem is designed to provide the interfacing
agency or organization everything it needs to perform its role.

• Again, individual operators are responsible for safety risk management.

Since individuals generally do not participate in a formal SMS program, the
FAA’s role is primarily safety oversight of performance and safety promotion
rather than the design and performance of SMS systems.
• The three levels of safety risk management. As we discussed earlier, ICAO
categorizes safety management methods as follows:

• Reactive—incident analysis, determination of contributory factors and

• findings as to risks.
• Proactive—mandatory and voluntary reporting systems, safety audits, and
• surveys.
• Predictive—confidential reporting systems, flight data analysis, normal
• operations monitoring.
• Reactive.
• fly-crash-fix-fly adage. There is an accident or incident, and we use
investigative tools to try to determine what the contributory factors were that
caused the problemReactive safety management is often equated with the
well-known “.
It is forensic in nature; that is, we apply scientific methods to understand the
relevant factors and offer those to the public debate or discussion (the
etymology of the Latin word forensis means public forum). ICAO uses the term
reactive safety management to include “incident analysis, determination of
contributory factors and findings as to risk”
• Proactive.
We have all heard the expression, “don’t go looking for trouble!”. Proactive
safety is exactly that: actively looking for trouble, or more accurately, actively
looking for potential safety problems through trend analysis, hazard analysis,
and other methods of scientific inquiry.

• Predictive.
Predictive safety is more. Today aviation is operating at such a high level of
safety that breakthroughs in safety improvement will be hard-won, and will
require higher levels of analysis and increasingly sophisticated tools and
methods.
• Predictive safety methods will enable us to find those failure points and
eliminate them; in effect, predictive safety will allow us to change the future.
ICAO includes “confidential reporting systems, flight data analysis, and
normal operations monitoring” in its description of predictive safety.
• Actually, we assert that predictive safety must involve more than the routine
analysis of flight data and monitoring of routine operations because those
activities primarily focus on the current state and what that implies about the
future. Predictive safety risk management seeks to understand the existing
system and, through the use of various forms of modeling, determine where
and when the system is likely to fail.

• Models are excellent tools to help us predict the future. They are used in
predicting weather, financial markets, and aviation safety.
• THANK YOU.