Safety Management Toolbox Continued from page 81 achieved by monitoring and measuring the outcomes of activities that operational personnel must engage in for the delivery of services by the organization. Management of Change. The aviation service pro- vider organization shall develop and maintain a formal process to identify and manage the changes within the organization which may affect established processes, procedures, products and services. The management of change should ensure that required safety performance is achieved by reducing or eliminating the safety risks resulting from the changes in the organization, the pro- vision of services or in the operational environment. Continuous Improvement of the SMS. The aviation service provider organization shall develop and maintain a formal process to identify causes of the sub-standard performance of the SMS, de- termine the implications of sub-standard perfor- mance in operations, and eliminate such causes. So, for operators engaged in SMS, let’s ask some fun- damental questions about the effectiveness of your SMS: ■ ■ Do you actively verify (by some form of formal- ized observation, assessment, surveillance or audit) that your safety policy and safety per- formance standards are being followed? ■ ■ Do you actively model how a potential change to your organization, for example—aircraft type, facil- ity, airport, GSE, or organizational realignment, will affect your documented policies, processes, procedures, training and safety performance—be- fore the change is accepted and implemented? ■■ Do you utilize personnel trained in evaluating or audit- ing to assess your SMS and operational programs? ■■ Does your organization perform routine in- ternal assessments of your SMS? ■ ■ When was your SMS last assessed by an in- dependent, external third party? I would venture to say, based on experience, that most corporate business and charter organizations be- lieve their programs address these questions, but few can provide evidence to validate their perceptions. One of the contributing factors to this lack of situational awareness is our industry’s over-reliance on the seem- ingly obvious partitions within various regulatory frame- works that govern aviation via internal evaluation. The typical organization addresses this by having the Flight Aviation Business Journal | 3rd Quarter 2016 Department focus mainly on the regulations affecting flight operations, Maintenance focuses on maintenance regula- tions, while other departments, like Facilities, Human Resources (HR) or an actual Environmental Health and Safety department, focuses on ground hazards and risk, or occupational safety and health (and environment) issues. More often than not, many of these internal evalua- tions are, once again, based on the prescriptive require- ments (the regulations), and not on the actual dynamic environment and behaviors that your SMS was intended to capture. They remain within silos (read your op- erational departments) and rarely venture out to as- sess the interface amongst and between departments. Many organizations merely follow the same checklists time and time again, building in complacency, rather than raising the awareness to historical experience (your loss history) and emerging trends. And why is this? Well, we are very good at being reactive (responding to an ac- cident) and even proactive when we see something hap- pening to someone else. But, being predictive takes a lot more effort. Predictive is founded on actively applying the elements within Safety Assurance discussed above. The best way to test your SMS is to perform an inde- pendent evaluation or diagnostic of your program, uti- lizing trained professionals that are not biased to your specific needs or encumbered by commercial pressures. Many corporate or charter operators don’t see the obvi- ous value of having a third party or external standards (IS-BAO for example) audit performed on a routine ba- sis. Many believe, and this is a direct client quote: “We haven’t had an accident in 10 years, and I know what my people are doing…no one comes to work wanting to have an accident.” Clichés aside, aviation is an inher- ently dangerous business. Why wouldn’t you want to know if standards and policies are not being followed? Experience has shown that routine independent exter- nal audits and reviews identify potential weaknesses or, put more simplistically, opportunities to enhance opera- tional integrity and safety performance. Believing in the quality of your flight department and support services is a good thing, but relying on that ‘belief’ without objective evidence, could be a roll of the dice with consequences. On a recent SMS development exercise for a large operator, we were able to encourage the organization to Continued on page 85 83
