A vehicle in a garage is a gathering of inanimate components until the ignition is turned – then it becomes a system.
Identical vehicles can perform entirely differently, depending on who the driver is. All drivers have their own unique style of operating the system.
The same can be said of a Safety Management System. At the beginning of the SMS journey, a collection of people follow guidance set out in the SMS manual. It is not until people start contributing to the processes, policies and procedures described in the manual does the system start to become unique to that set of operators.
In the same way that a car owner learns the nuances of the vehicle system, and develops an individual style of driving, so does the SMS evolve into a unique part of the organisation. When used effectively, the system will become tailored to meet the size and complexity of the organisation it services.
Consider the cogs on the left; one drive source can turn all eight of the cogs. Any turning cog will have resultant movement on the others. If they are separated, or did not work together as a system, or acted independently in turning, they would have no impact on the others. It would take eight drive sources to turn them all. It would use much more energy, be less efficient and less effective.
Understanding and utilising the relationships and interoperability between the components and elements of SMS is when the system becomes usable and beneficial to the organisation.
Compliance and entry control
When a regulator assesses a new SMS, for entry control only, the performance markers of Present and Suitable are assessed.
- Present – Is there a process/procedure/document/policy that supports each element of SMS?
- Suitable – Is that process/procedure/document/policy appropriate for the organisation? It may be to too complex, it may be too simple. This where the organisation needs to consider what is actually required for its own unique operations, and not simply copy a manual from elsewhere.
Considerations to determine what constitutes Present and Suitable may include:
- Has the organisation addressed all elements of the SMS framework in the SMS manual?
- Are all required persons in place to manage safety management and are they appropriately trained?
- Does the organisation appear to have a Safety Culture?
- Is there evidence of commitment, training and communication to all staff?
An immature SMS, one that has not yet evolved effectively for the organisation, may exist because:
- There have not been enough (if any) SAG/SRC meetings to raise safety actions or change procedures
- The management of hazards and risks is still evolving
- There have not been enough staff safety surveys to gain insight into the Safety Culture
- Re-currency training has not yet been conducted
- The cycle of continuous improvement is not yet complete
- And so on…
A compliance assessment may not investigate all workings of a new SMS. It is the post implementation review that really determines if the SMS is actually Operational and Effective.
Evidence of this might include:
- Has the organisation conducted its own internal audit and reviews of the SMS effectiveness?
- What evidence is there of effective management of change?
- Is data being gathered and used to help identify potential hazards?
- Is the safety culture mature and resilient?
- Are documents being amended and controlled?
- What actions and decisions are coming out of the safety meetings?
- Are new hazards and risks being added and managed?
- Have there been training and communication events on a regular basis?
- What evidence is there of safety promotion?
- How many and what are the quality of the hazard reports?
- Does the process of investigation of hazard reports ‘close the loop’ back to the reporter?
The regulator will aim to conduct post implementation surveillance within 18 months of entry control. What is important is that the SMS is becoming unique to that organisation, and that the benefits are being realised in terms of safety and therefore efficiency. It is not just a manual sitting on a shelf.
Your SMS is for your company – not for the regulator
Present and Suitable does not give you return on investment, but Operational and Effective will.
Building a Safety Management System starts with a management decision: ‘We will have a Safety Management System.’ It never really finishes, but it could be said to be in a steady state when the entire workforce understands its importance, recognises its benefits, and willingly contributes to the operational effectiveness of the system.
SMS is a system
‘A system as a whole is more than the sum of its parts.’ (Karl Ludwick von Bertalanffy)
Process vs Procedure
A process is a set of interrelated or interacting activities which transforms inputs into outputs
A procedure is specified way to carry out an activity of a process
- Aircraft maintenance must be carried out in the hanger for Quality Assurance
- attached aircraft to tow motor with approved tow bar
- two wing walkers in position
- brake rider must be in cockpit
- speed for towing not above slow walking pace
- aircraft brakes to be applied and chocks in after aircraft is positioned in hanger