early identification of haz- ards and systemic failures of concern to the airport ■■ the airport’s safety review board includes tenant or contractor representation, where appropriate ■■ safety/quality indicators are developed, when appropri- ate, to monitor tenant or contractor performance ■■ the airport’s safety promotion process ensures subcontrac- tor employees are provided with the organization’s appli- cable safety communications several comments on the SMS NPRM, airports worry about exposures to negligence claims as a result of risk evaluation and potential acceptance, especially where sovereign immunity may not apply. At present, SMS data is not protected, as in operational voluntary reporting programs such as those found at airlines. Because of this, airports have expressed con- cern about discoverability. Without minimizing these concerns, the bulk of SMS experience across numer- ous industries has proven these concerns to be largely unwarranted. Nevertheless, ensuring SMS is used to reduce liability effectively will be the result of a collaborative effort. A Focus on Interface Safety management in a flight de- partment relies on interfaces between other organizations, departments, equipment, and personnel to be ef- fective. At an airport, where there are many more dimensions of governance and organizational structure, assur- ing effective interface between the various elements of the system can Aviation Business Journal | 1st Quarter 2017 make or break the SMS. Used here, what we really mean by interface is communication, and as SMS under- standing matures, expect to see more mention of interface. ICAO’s Safety Management Manual (Document 9859) points out that in cases where a service provider—in this case, the airport—has responsibility for the performance of tenants or contrac- tors who are not separately required to have an SMS, the airport also has responsibility for the safety perfor- mance of those entities. The interface between those entities must be a chief management concern because it is the conduit for identifying hazards, assessing risk, and developing and implementing mitigations as needed. Airports should focus on ensuring: ■■ there is a clear policy, establish- ing a safety accountability and authority flow between the air- port and the tenant or contractor ■■ the subcontractor has a safety reporting system com- mensurate with its size and complexity that facilitates the ■■ any subcontractor roles, responsibilities and func- tions—relevant to the airport’s emergency response plan—are developed and tested (adapted from ICAO, 2013, p. 5-9). Innovation, not Imposition One of the biggest challenges to any industry is balancing self- regulation with external regulation. In the airport world, the technical aspects of our operations have been carefully regulated for years. Our safety management efforts, however, have been generally left to industry to sort out. This is well and good, but as the many comments to the original NPRM on Airports SMS reinforce, the success of any SMS efforts in the air- port community rely on minimizing gaps in understanding how airports actually function. For that reason, self-regulation to the extent possible prior to regulation sets a standard for performance, and has the potential to ease the transition to regulate SMS. Continued on page 43 41
