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CASA discussion paper

CASA – Future of SMS in Small Organisations—Discussion Paper

With the recent removal of the SMS requirement for Part 141 flying training schools and the greater emphasis on deregulation and reducing costs associated with regulatory compliance, questions are being asked about CASA policy on the requirement of SMS in small aviation organisations.

 

It is my view that this issue has too much focused on the ‘burden’ to industry without sufficient understanding of what that burden would be and more importantly, without sufficient focus on the safety benefits and indeed potential financial benefits.

 

Rather than see an SMS as a set of components and elements that all have resource requirements with the resulting system having dubious return on investment either in terms of safety or dollars, I would recommend considering an SMS in the following terms:

 

  1. Simply a systematic approach to managing safety
  • A well run aviation business will already be doing this and the gap between their processes and an SMS will be minor.
  • Stop reinventing the wheel; lessons learnt stay learnt.
  • Raises safety as a priority in the organisation
  • Supports development of a healthy safety culture

 

  1. Switches the focus from purely reactive to proactive safety management
  • Don’t wait for accidents and incidents to happen
  • Safety is considered before and during organisational and operational changes

 

  1. Reduces errors
  • Accidents are usually a result of a complex coming together of various factors many of which involve error. Reducing error reduces the likelihood of accidents.
  • Errors cost money

 

  1. SMS processes can meet other, existing regulatory requirements
    • A systematic approach to managing employee safety is already required by WH&S legislation
      • Hazard identification and risk assessment and management so far as is reasonably practicable is already required by WH&S legislation
    • SMS and QMS use the same processes and can be mapped onto one another

 

  1. SMS brings potential financial benefits
    • Reducing errors reduces costs. Less errors means less injuries to employees, less downtime fixing equipment, legal costs etc.
    • Brings in business. An SMS demonstrates a commitment to safety and a higher level of professionalism. Some industries such as mining require an SMS to do business.
    • An SMS can be used to demonstrate superior risk management to insurers and financial organisations leading to greater leverage a potential cost savings

 

  1. SMS requirements must be outcome based to work in small organisations
    • Safe, well run organisations should be able to map what they are currently doing onto the SMS requirements
    • For safe, well run organisations this should be a matter of documenting good practice
    • Much of the current ICAO guidance is focused on addressing issues in larger organisations that are not issues in smaller organisations.
    • A CEO and safety manager in a small organisation have less need for complex processes and access to data to understand what is happening in their organisation:
      • They can ask ‘all’ the employees what is going on
      • They can observe the ‘whole’ operation
      • They can talk to all employees at break times

 

  1. CASA should provide the guidance and tools
    • Introducing an SMS requirement doesn’t mean the organisation was unsafe the day before the requirement was made
    • Having a compliant SMS manual has not proven to be a good indicator of subsequent safety levels
    • Introducing an SMS should be a building, learning, maturing process
    • CASA should sell the value of an SMS (and keep selling it)
    • SMS is about simple concepts we should provide simple messages and simple guidance—where it gets complex then we should provide the tool

 

In summary, now is not the time to step away from the requirement for SMS. Now is the time to understand how close we are to getting a systematic approach to managing safety across the aviation industry. Much of what needs to be done has been done however, the area of small organisations needs a revitalised approach.

 

Way ahead:

  1. Senior CASA management should re-commit to introducing SMS across the aviation industry.
  2. CASA needs a clear strategy for who will require SMS and who will not and why
  3. Safety promotion have been excellent at delivering simple clear and concise SMS guidance and that needs to continue.
  4. We need an SMS assessor course that works for assessing small organisations as well as larger organisations
  5. Across CASA we need to switch the focus more towards outcome and away from purely process particularly for small organisations
    • This must be clear in the SMS assessor course
    • Assessment needs to move away from ticking boxes towards using judgement on whether something will work for that organisation (or is working)
    • All inspectors should be able to support/assess small organisations when they are; introducing, developing and maturing a simple SMS
  6. Start selling the advantages of SMS and focusing on reducing the perception of a large impost
  7. Keep it simple!

 

 

Ian Banks

 

Manager Safety Management Systems and Human Factors
Standards Division
Ph:131 757
Mbl: 0401 xxx xxxx
Fax: (02) 6217 1302
ian.banks@casa.gov.au