SMS – Friend of Foe?.

[Kharon]

This follows on from some very interesting recent discussions related to Safety Management Systems (SMS); thought I'd throw it out here (to the esteemed members) in the forum to see the response.

No one denies, that in theory SMS is a must have tool and in principal should work just fine.

The question is, can it be truly seen as open, honest, just, confidential and not subject to either external or internal 'abuse' ??. (Abuse being manipulation, strangulation, obfuscation, expediency, mendacity; etc).

Honest question.

Selah.

[Massey058]

It really depends on the quality of the management. They have to believe that SMS is a key component of the business. It also needs to have a genuine Safety Department (even if it's just one person initially) that has the respect of the crew and the management.

Without that it's all just lip service to appease the regulator. And the regulator must still remain involved and engaged. The implementation in Canada has ironically been quite a failure for the non Part 121 crowd. They essentially used it to help deal with a significant manpower shortage in Transport Canada and really dropped the ball so to speak.

I'm a little bit out of touch with the implementation of SMS in New Zealand and Australia. How far down the ranks has it stretched? Do operators like Sun Air, Helipro, Sling Air etc run full-blown SMS?

[Sarcs]

Excellent question K! One that was briefly touched on here:
Using parts of an SMS without tailoring them to your
own organisation or circumstances is contrary to the
central idea of SMS. ‘Such a box-ticking exercise would
be both dangerous (thinking you are being safe when
you are not) and a waste of time,’ he says.
Box-ticking is in many ways the opposite of safety
culture. Just as with 'culture', there is no exact definition
of 'safety culture', but a 2006 ICAO document makes
a good stab when it refers to a good safety culture as
‘a corporate safety culture that fosters safe practices,
encourages safety communications and actively
manages safety with the same attention to results as

financial management.’


Link: http://www.pprune.org/dg-p-general-aviation-questions/474319-casa-spends-millions-chasing-milton-jones-aviation-business-2.html
The article in the Flight Safety mag was actually quite good...surprise, surprise!:D

Like all good ideas there is always a minority that see a way to exploit or abuse a system/law/rules to their own gain. In the case of SMS I have seen both the good and the bad. I feel that a SMS is only as good as the 'culture' within a company.

If an operator is honest, upfront and embraces their employees as their key assets to the business, then the foundations of a good SMS are layed. A good manager will use the SMS to promote the business and actively seek input and ideas to improve the SMS.:ok:

Unfortunately a bad operator will only see the SMS as a means of showing compliance to the regulator i.e. "we've got this in place so we must be compliant"!:= This says it all I think (from above):Such a box-ticking exercise would be both dangerous (thinking you are being safe when you are not) and a waste of time,’ he says.
Box-ticking is in many ways the opposite of safety
culture.

Cheers

[Capt Claret]

‘Such a box-ticking exercise would
be both dangerous (thinking you are being safe when
you are not) and a waste of time,’ he says.

Gee I have a strong sense of de ja vu. I wonder why? :ouch:

[Wally Mk2]

Safety begins the minute you sign on for duty or walk in the crew room door. Disengage the staff (as we have seen a lot of late & safety (apart from self preservation) can get effected.

Like most things in life someone comes up with a new 'in word', SMS is just another one of those. We are ALL responsible for safety in everything we do in life that involves risk & I see little point in reinventing the wheel just to make us all feel warm & fuzzy as well as appeasing the regulators!
The only good part I can see about the SMS is that it entails a dedicated person or persons for the role.

Wmk2

[Jabawocky]

SMS is being forced up on the various aviation orgs as well. Warbirds SAAA RAA (i think) and I must say when the systems are made for airline charter or AOC type groups that works fine but when it is an association of private individuals, it is a waste of resources.

The orgs are getting lumbered with something that meets certain criteria set down from CASA but does not really do anything at the coal face. Pro Active education materials and campaigns are far more effective.

As an example the Human Factors course RAA did a few years back, and new folk have to pass now, is a good thing. Boring topic maybe but a good thing to do. Trying to impliment an SMS and reporting program like IRIS is in my opinion doomed to fail.

Integrated Risk Information System | IRIS (Integrated Risk Information System) (http://www.irisasn.com/index.html)

[gobbledock]

SMS will benefit an individual organisation. It may be a new concept to aviation but it has worked in the oil and mining industries for years.

The catch is this - It puts more of an onus back on the airline or operator. I have no problem with that. However, SMS is a tool that the government supports as it can be used against you as it distances the government or regulator and minimises any fallout or any apportioned responsibilty or accountabilty if anything goes tits up, like a smoking hole! That is one sad reality. You can be assured that CASA has embraced SMS and pushed it along not because they think it is a great safety initiative, because as we all know the regulator is in place to protect the government and minister of the day, not to protect industry or passenger. If SMS helps distance the regulator from accountabilty they implement it ASAP. Infact it only took them around 2 years to implemet SMS, compared to 23 yeras and counting for reg reform!!

On a positive note (for some) SMS has in the past few years opened up the opportunity for them to employ a number of 'consultants' including former staff and mates. One earned over $500,000 in 2009/2010 alone just from CASA. And then you have all the CASA staff tripping overseas, off to Montreal etc, so SMS adds an extra layer of depth to the trough for those savvy enough to see the potential. Oh yes, here piggy piggy piggy. Oink oink.

[Sarcs]

gobbledock wrote:
If SMS helps distance the regulator from accountabilty they implement it ASAP
.......and there lies the problem with the SMS, by putting the onus back on the operator to implement and maintain (if you like self regulate) the only thing the regulator checks is if all the right boxes are ticked!:ugh: "Who cares if the SMS isn't actually doing its job...we've done ours!" Click, end of audit." Now where was that latest edition of the piggy digest...."

[neville_nobody]

You can be assured that CASA has embraced SMS and pushed it along not because they think it is a great safety initiative, because as we all know the regulator is in place to protect the government and minister of the day, not to protect industry or passenger.

Yes correct. Same goes for Fatigue Management.

They increase the amount of regulation and cost whilst simultaneously removing their amount of legal liability and responsibility and ultimately shrinking the industry.

[Progressive]

"Who cares if the SMS isn't actually doing its job...we've done ours!" Click, end of audit." Now where was that latest edition of the piggy digest...."

This approach to regulation of SMS was taken by Canada and now forms a pretty well known case of what not to do with SMS. Properly implemented SMS is not full self regulation.
Yes organizations are given the flexibility to conduct their operations in the manner they see fit however this is contingent on proper risk management processes.
The regulators responsibility should be to ensure that risk management processes are being carried out correctly.
Correctly done the SMS should be easy to regulate as each stage has obvious outcomes:
EG: Not many reports generated for company size = faulty reporting system.
No action on reports = lack of commitment from management

SMS is not something new and fancy it has been operating in the mining, rail shipping and nuclear power industries for years.

[Sarcs]

You only need to cherry pick some of the Senate Hansard for the Rural Affairs and Transport Committee's recent inquirys (current and completed) to signs of a SMS being abused/embraced.

This from a current inquiry (no guesses to which one):


Mr Kelly: We have raised it through the reporting system called OSCAR. For five years we have reported fatigue as an issue with the Bali returns. The message that we received from the company was 'Just keep the OSCARs coming.'
Ms Neeteson-Lemkes: If I may elaborate on the OSCAR system within J******. You write an OSCAR, whether you submit it electronically or hand write it, and you send it off to the department. What you receive is a generated or an automated email, saying, 'Thank you very much for your OSCAR.' It ends there; there is no action. We have been waiting for action at domestic for about 3½ years now. OSCARS are unanswered and they remain unanswered.


Whether these statements/facts were true or not is irrelevant. What is true is the perception of the employees on how ineffective the reporting system is.

I also know of crew that have been given letters of warning (first black letter) for submitting company incident reports. An example was where a FO tried to start an APU with the engine bung in, the FO submitted an incident report and was subsequently reprimanded and sent a 'black letter'. There was no serious damage done to the APU and the FO was told by the engineers: " Don't worry about it, it happens all the time!".
This attitude can only instil a culture of non-reporting within an organisation.

Progressive quite rightly points out:

SMS is not something new and fancy it has been operating in the mining, rail shipping and nuclear power industries for years.

However SMS may have been around for "donkeys years", but a SMS is only as good as the management controlling and promoting it.

[Cirronimbus]

I think each organisation was supposed to create their OWN SMS that is tailored to suit their particular operations. If this is done properly, there is no reason why the SMS will not work unless the organisation itself does not operate the SMS correctly.

If your SMS is not working correctly, it is not the regulator's fault. The regulator is there to make sure the SMS is in place, not to operate it for you.

[geeup]

Wont work open to abuse :eek:
Cost cost cost :ugh:

[halfmanhalfbiscuit]

If your SMS is not working correctly, it is not the regulator's fault. The regulator is there to make sure the SMS is in place and ensure SMS is effective, not to operate it for you.

This has been one of the problems certain people are happy as long as there is an SMS. It has to be effective and working and the regulator should be monitoring to ensure that. True, they are not going to operate it for you - the organisation must own it and operate it.

[Progressive]

The case of J******'s OSCARS program suggests that they do not have SMS properly established. One of the key component's of SMS is the feedback loop to staff (company mag with selected reports and remedies and individual information back to reporters in a an organization this size).
If the regulators do the job correctly they should pick up on this.

I think one of the key hurdles to implementing SMS is in changing the culture from one of
"the regulator is here to tell me what to do and how to do it - and I am there to do the minimum possible to meet this" to
"it is my job to manage the safety risks in my company just as I manage the financial risk and the regulator is there to monitor my management of risk and suggest improvements"

This change in culture must take place in both operators and CASA and so there are bound to be teething problems.

Someone once said to me "Safety management is only good when it becomes as much part of a company's policy as cash flow management"

[Sarcs]

If your SMS is not working correctly, it is not the regulator's fault. The regulator is there to make sure the SMS is in place, not to operate it for you.

Cirronimbus I don't think you will find many people who will disagree with you, I mean god forbid having the regulator run your SMS!

The issue is the dodgy operator who uses the SMS to their own gain. Then each year when the annual CASA AOC audit comes up all the boxes are properly ticked and "yes the SMS is wonderful" and "works really well!"

The CASA FOIs and AWIs conducting the audit are none the wiser because all areas of compliance seem to be covered. But really the SMS has become a smokescreen to what is really going on.

The bureaucrats back in Canberra don't care because all the 'boxes are ticked', hence 'our area of responsibility and liability' is covered!'

[Cirronimbus]

Geez, I hope our "bureaucrats back in Canberra' do really care, because if they do not, then the whole point of regulating for SMS is a waste of time. Admittedly, there are operators out there who think they can get by just by doing enough to 'tick the boxes'. If that is enough to satisfy the regulator, then we are all stuffed.

In an ideal situation, the regulator should be changing hats (from regulator to educator) and trying to help, educate, or assist, the operator to implement a SMS that works. I thought the whole point of introducing a SMS into an operation was to make it safer (and more profitable) and that would have benefits to the operator and other users of the same airspace?

Anyone who thinks that all they need to do is 'tick boxes' is fooling themselves and letting everyone else down. Does anyone think that making the effort to design and implement a proper SMS is a waste of time? If the SMS ticks the boxes and something still goes wrong; is it the regulator or the operator, who comes off second best?

[Kharon]

The CASA FOIs and AWIs conducting the audit are none the wiser because all areas of compliance seem to be covered. But really the SMS has become a smokescreen to what is really going on.
"But, but it's a no smoking zone". "No worries son, we will just invent some stuff or better yet; 'borrow' some from this little book here (shows copy of SMS reports).

In an ideal situation, the regulator should be changing hats (from regulator to educator) and trying to help, educate, or assist, the operator to implement a SMS that works. I thought the whole point of introducing a SMS into an operation was to make it safer (and more profitable) and that would have benefits to the operator and other users of the same airspace? Don't worry, seems "we" are to have a Task Force to help us out, for we know not what we do. A task force FCS; just about say's it all don't it. We send task forces to Torbuk, Dunkirk, Indonesia, Afghanistan, Somalia, Iran etc. etc. Now to Moorabbin.

At least there will now be help for the front line as they merrily use sacred REPCON and SMS information to pursue their elusive quarry through the legal mires.

May the force be with you. :ugh:

[Selcalmeonly]

Taskforce ... What taskforce? A CASA SMS taskforce? I hope its not a case of the blind leading the blind!

[blackhand]

I hope its not a case of the blind leading the blind!
Won't matter cause they can lip read.:E

[halfmanhalfbiscuit]

Suggested task force can't be out of Moorabbin as now closed. Try Paris end of Collins St. Closer to airline ho. You can see Tulla through a telescope.


The staff in Melbourne don't appear to be where industry would them to be?

[Selcalmeonly]

Huh??? ... Sorry HMHB, I've looked at this post a number of times and just don't get it!

The original thread was about SMS - right? :confused:

[Kharon]

Selcal: I guess that I'm one of a number of 'moderates' who think that there is too much CASA emphasis on LAW these days, and not enough on SAFETY. Whilst there may be cross-overs between the two concepts; absolute compliance does not assure safety - is not that SMS lesson 101? Agreed, Oh to be a moderate, now that sanity is here. How I wish. No doubt GA needs good, solid practical safety management systems that work, as writ. The poor crippled thing I see a lot of in operations bears little or no resemblance to the real deal.

Just for starters - the debate over the method to be used needs to be finalised. Some believe the 'big' company approach is the only one. CASA do frequently knock back anything that does not fit 'their' model. You can of course at great expense 'buy' an off the shelf job which will go through like grass through a goose. Hmmm, I wonder; nah couldn't be.


I believe a SMS should be tailor made to each operation, hand crafted with care and grown from within. In a very short period it becomes a natural part of the ethos and operating culture of the company. Sure, a preferred 'standard' frame work of reporting, assessing and managing should be there, but that is where the external interference should stop.

To make the thing rock there are several things which cannot be part of the system. One of these is fear. Fear of prosecution, fear of job loss, fear of ridicule, fear for reputation. The other big bad is ignorance, now here it gets a bit subjective, but if the 'risk' cannot be identified (known) there is little chance of it being reported.

The next trick is classification, assessment, recording, action and education.

$00.20 AUD.

[Selcalmeonly]

K, I fully agree with your comments. Whilst not completely familiar with the latest GA SMS issues, every thing you say makes sense. Have you considered a SMS 'contract' with CASA or better still the next CASA CEO? - JOKING!:):)

[Kharon]

Fox in the chook shed metinks. However, could it be worse, the following springs to mind, seems appropriate.

Mercutio:
Nay, if our wits run the wild-goose chase, I am done; for
thou hast more of the wild goose in one of thy wits than, I am
sure, I have in my whole five.

'the audience must have been familiar with the real game, in which one horseman executed a series of difficult manoeuvres which others had to repeat in close succession'. (Thus Romeo's obscure "swits and spurs"—that is, "switch and spurs," to control one's baffled steed.)

The game was probably named after the flight pattern of a flock of wild geese, which obediently follows the often erratic lead of the head goose. Thus, perhaps, the latter-day sense of the phrase: the pursuit of an evasive leader evolved into the pursuit of an impossible or illusory goal.

Mercutio also refers to his "five wits." He doesn't mean the five senses, but rather the corresponding intellectual faculties: memory, imagination, fancy, common sense, and judgement.
My bold, ( chuckles as Jabba and GDock http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/sowee.gif & http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/pukey.gif) exit stage left http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/tongue.gif

[blackhand]

Well there you go, same wankers ruining this thread as well

[gobbledock]

Blackhand, such an obtuse attitude from an island bush mechanic, you need to go back to doing what you do best - Plane spotting with Ken B and repairing remote control helicopters.

[jas24zzk]

Since this thread started, I decided it was time I maybe did some research on the subject. I have tried to remain uninterested, and what I have been reading just makes me want to :yuk:

This was reinforced today when I visited work to drop off my paperwork ( I am off on workcover atm) and the general manager was spruiking how we needed to investigate means to prevent an injury like mine happening again. My ears pricked up immediatley, this sounds like SMS!!!! Truth be known, if they spent some money in the shop my injury would have never happened. Lets see, buy a NEW $200 tool, or have a tradie repair it? Sure, the skin area will heal, the muscle will heal, the severed vein will heal, then damaged (and currently infected) tendon will heal, but i will never get any feeling back in the damaged area of my hand, eventually the brain will shut off those nerves that send sparks and embers up my arm at any contact.

A case of spend money on SMS or simply spend some money on clear and obvious risks? Maybe a simplistic view, but I am somewhat bitter.

Quoting Kharon

Just for starters - the debate over the method to be used needs to be finalised. Some believe the 'big' company approach is the only one. CASA do frequently knock back anything that does not fit 'their' model. You can of course at great expense 'buy' an off the shelf job which will go through like grass through a goose. Hmmm, I wonder; nah couldn't be.

From my ponderings over large amounts of text, CASA don't want you to buy an 'off the shelf' product and do minor tailoring. They seem to want you to build your own SMS, based upon some 'regulatory????' guidelines. This is how the Quality Assurance (QA) system began. You know the one where you get a fancy sticker with 4 ticks and ISO2012 written on it.


I believe a SMS should be tailor made to each operation, hand crafted with care and grown from within.

Yes, I agree to a point. The problem is the time needed to go about implementation in this manner becomes extremely cost prohibitive. I think it is an area where CASA could provide much assistance to operators. I.e provide a one size for THEIR operation that is easily modified for approval.... i.e small operation, as an example YCEM vs YLIL's primary operators.
Both are flight training organisations. CASA could provide them with a template, they could cut out the bits they don't do (one operator doesn't do night or charter) and CASA could sign it off. Or they could delve deeper for changes that better suit them. The crux tho is that most of the work is already done for them. Good use of taxpayer money I reckon.


In a very short period it becomes a natural part of the ethos and operating culture of the company.

Agreed, tho if its anything like the QA system, then changing your staff over is the quickest method of generating the etho's.


To make the thing rock there are several things which cannot be part of the system. One of these is fear. Fear of prosecution, fear of job loss, fear of ridicule, fear for reputation.

Damm skippy!!!! CASA needs to be pro-active here. If it gets stuffed, then the reasons need to be explored, learnt from and then passed on to other operators (shoe ain't that SMS!!!). IF Casa take a regulatory approach to this, then it is clear they only want to regulate, which has no benefit to anyone, and the whole SMS thing will become a muddied mush pit.


The next trick is classification, assessment, recording, action and education.

$00.20 AUD.

20 cents? don't tell me its gone up again!!! no-one tells me anything!


On a lighter note. This whole SMS deal sniffs heavily of the QA system. It was great when it first started. I can only see it getting watered down in the future, and the whole exercise will become pointless.

I'll give you an example from a company I spent enough time with to see thier QA system go squat (and they are all no different now).

I'm in the auto repair industry (body)

Vehicle arrives.
Recieving employee goes over vehicle with owner, noting unrelated damage and full electrical tests are carried out. Owner agree's and signs.

Repair processes completed.
Technician, finalises the job, checks for no extra damage, and that all accident related electricals are fixed, and all other systems that have been handled in the repair work as per factory. If owner has requested other repairs, they are also checked off.

Today,
Car comes in, straight to a technician.
He repairs to the job sheet and signs off.
Owner complains that the L/H front parker WAS working before the car got slammed up the arse.
no recourse, workshop fixes for free. (and thats a CHEAP example)



Sorry but SMS sniffs highly of QA and I see it going the same way

[Kharon]

jas24:
the general manager was spruiking how we needed to investigate means to prevent an injury like mine happening again. 3 good points in 1, (a) The GM was spruiking etc. (b) You did get hurt and (c) how to prevent etc. The case for SMS clear as day.

The way I understand it the SMS aims to provides a method of 'formalising' reporting and recording the things we do almost everyday when 'looking' at the risks involved. Risk assessment is a thing every creature does, almost a reflex; mostly the SMS appears to focus and formalise that analysis, record evidence that we did the analysis and provide the lessons to prevent a repeat.

But, seems it's a tough row to hoe. For instance, crossing the road; when you define the risk level and operational complexity of this seemingly simple task the real beast appears.

Try and draft a SOP to cover it, so that the kids without adult supervision could cross any road anywhere, any time and remain in one piece. If you got a dozen or so people to draft one each the 'bulk' of the thing would be probably contain the same basic stuff, but the value given to each identified risk element would vary and the amount of risk elements would probably be quite different. Bear in mind one man's high level risk is another's stroll in the park. It gets subjective really quickly.

So, it seems to me the problem for any NAA, operator, or individual is how much is too much and how much do we need. For instance, Flight Safety Foundation (bless 'em) offer a free, simple, very effective way to analyse CFIT risk. Last I looked 2 of the three pages allow the operator to develop a CFIT 'rating' for the operations conducted. The third page allows the flight crew to assess their operation against the company number to determine if they at a higher risk value than the 'norm'. Cost nothing takes about 10 minutes to do the first bit and 2 minutes the last. Not too many GA operators bother with it, but they are potentially (theoretically) in the highest risk bracket.

Speedy recovery Jas.
Selah.

[blackhand]

you need to go back to doing what you do best - Plane spotting with Ken B and repairing remote control helicopters.
And you and Kharon need to stop touching each others willies

[thorn bird]

Mr. Blackened hand
Other than singing CASA,s praises, and impertinant vitriol what have you ever contributed of any value the discussion. Given that from your comments you are quite possibly a CASA weany are we to understand that CASA has no particular interest in discussing how to construct an effect Safety Management System?. Says it all I spose, and there I thought CASA was interested in Safety.
With regards to Willies, perhaps if you have a "significant other" they should obtain you some "Viagra Light", that will get it just hard enough so you dont fill your boots when you have a Pee!!

[Sarcs]

Spot on TB!:ok::ok: This bloke gives true blackhanders a bum rap, what a git!!

....well back to the SMS, the discussion was just starting to get interesting:D:D

[jas24zzk]

:D

I must head out the club tomorrow and try to find the article I was reading dated circa 2002 about the growth and impending implementation of SMS. Might have to read a few mags to find it again. ah the joy. Mind you it was a casa publication.

[Kharon]

There are some bloody good articles on the net, written by 'experts' which are serious food for thought and good solid theory. CASA articles I leave up to your good judgement.

Once you get away from the grandiose 'statements' and plough your way through the stultifying pages of 'safety speak'; you run screaming out into the daylight and Wallop, there it is; reality.

To get a system working is not too arduous a task, good paper trail, solid support from everyone etc. etc. No cracks so far. Just for fun lets follow young "Spotty" through a day at Dodgy Ops.

Car park ; big puddle in a hole in the car park tarmac. Reportable?.
Front door; handle loose, screws missing, possible accident. Reportable?.
Flight planning, ERSA out date (just). Reportable?.
Hanger; apprentice stood on a milk crate doing engine compression test. Reportable?.
Ramp; new chum driving the tug, no tarmac licence, no training. Reportable?.

Before Spotty gets to the Daily, some one has just picked up half a days work. Fist the 'risk' element has to be assessed, classified, recorded and a return receipt has to be sent to young Spotty (Thanks mate). This before the rest of the requirements of the system are met. But this is not the really fun part.

Oh !, what ?, yeah mate, start her up, be there in a minute.

[Selcalmeonly]

K; you've raised a good point here and one which is dear to my heart. SMS which are overly complex, with unworkable requirements and or not contextual are of doubtful value. Input < output! Junk in = Junk out!

The SMS's that I've had anything to do with are sometimes ineffectual because people DO NOT report the important operational stuff! Reporting a trip hazard may be useful, but reporting a fuel mis-management issue is real important.

[thorn bird]

Selcal, I totally agree with you, we all make mistakes and learn from them.
It is vitally important that those mistakes get shared, that should run to the heart of safety management.
Unfortunately, Australian regulations set as they are in the criminal code, and a reactive regulator,spreads a mantle of fear over the industry.
CASA, I believe are a severe impediment to that sort of reporting. The bigger companies with political clout, large wallets and strong legal departments can perhaps deter the regulator's zeal, but pity the smaller operator or individual. To leave a paper trail of some infraction or perceived infraction is fraught with danger, literally putting your head on the chopping block.
The CASA apologists will no doubt say this could never happen, unfortunately in truth, it can and it does.

[Kharon]

So here's young Spotty contemplating the Daily, the Ops guy shouts over, "2 hour delay Spots, have a coffee mate", so being a good lad he toddles off to the crew room and thinks now would be a good time to put in those reports. Thought to action – and the electrons start to flow. System activated. Next stop the first filter.

Rep. 1 – big puddle. OH&S issue really, surely. Filter by pass open, flick.

Rep. 2, Door knob. – OH&S issue really, surely. Filter by pass open, flick.

Rep 3. ERSA – now who does that ?, scratches in Ops manual (A1.453) Chief Pilot responsible, duty pilot job, Email sent – "company ERSA out of date". CP on leave, duty pilot back from charter Wednesday then rostered for two days off. Filter failure.

Not to labour the point here, but I belive you can see that the 'treatment' received at the first filter is critical. If we gave Spotty a bad day, the reports are potentially endless. Which are operationally urgent, which will keep for a while, which are ATSB issues, which can fry the company, which can kill. The crux, for my two bobs worth rests right here.

If the first filter can be properly rigged, there is a chance that a 'company' SMS can work very well indeed. But the pitfalls are many, the scope for subjective variation of definition infinite and it's a bloody risky adventure for an operator.

The security of the information received is critical, in a perfect world, this should not rate a mention, but operators I have talked to never, ever fail to bring it up as a matter of some concern. Complete internal anonymity is almost impossible to achieve, even in an operation the size of Qantas, but I don't see that as a significant problem. The notion of external anonymity must have some serious 'legal' clout if the system is to work and to me, that seems to lacking.

For example I have seen two letters and discussed another couple of anecdotal reports of CASA instructing a CP to 'cc' them in on any report to the ATSB. Not only is this naughty, but it's counterproductive if you want a genuine, real life SMS that prevents incidents, helps pass good information to the troops and is to be genuinely worth the trouble and expense.

Selcal - Reporting a trip hazard may be useful, but reporting a fuel mis-management issue is real important.
Yup, but is it (a) helpful information, (b) a signed confession or (c) a back road to hammer the operator fuel policy (legal like).

TB - Unfortunately, Australian regulations set as they are in the criminal code, and a reactive regulator, spreads a mantle of fear over the industry.
Agreed – so do you become as crafty as the enemy and make it pointless, or offer your testicles to Gods of fate ??.

Definitely need a coffee NOW.

[LeadSled]

From my ponderings over large amounts of text, CASA don't want you to buy an 'off the shelf' product and do minor tailoring. They seem to want you to build your own SMS, based upon some 'regulatory????' guidelines.

Folks,
Wonderful theory, all the right politically correct sentiment emanates from CASA PR , but absolutely no relation to what happens in practice, which is:

------ Go to a CASA preferred SMS "preferred supplier", who will run you off a cut and paste from his ( no her's of whom I am aware) CD, topped and tailed with your company name, and an eye watering invoice,:D and CASA will give it the nod, as it "must comply".

One wonderful example of real world aviation, Australian style: A very credible tailored SMS, all developed from the CASA CD etc, and ticked off by a real ( recognized internationally) expert, an ICAO auditor, who actually teaches SMS to NAAs, as well as advising operators.

Unsurprisingly, this was summarily rejected by "the" CASA "expert", whose training and experience in the field was ( as established in the AAT) to say the least, embarrassingly limited ---- but, he was the CASA "decision maker".

Tootle pip!!

[Selcalmeonly]

There are very few SMS experts who have actually implemented the system from scratch and understand the challenges that exercise presents. To do it properly takes time and its actually not easy. There's plenty of guys who write tomes and throw them over the fence at the customer.

I'd hazard a guess that there are even fewer CASA inspectors who have implemented a SMS and have a corresponding pragmatic approach! :hmm:

[Kharon]

Selcal - I'd hazard a guess that there are even fewer CASA inspectors who have implemented a SMS and have a corresponding pragmatic approach!

From my research, discussions etc. this subject provides one of the best 'over a beer' topics ever. The subject matter cannot be summarised easily : but the 'cure' can be.

Part of the qualification regime to be an FOI should be a critically examined version of "their" operations manual, including a SMS section. I have now for many years kept a collection of the written requests made by various FOI for changes, amendments and alterations of Company documents, many of which have delayed the 'acceptance' of variations to or the issue of Air Operator privileges. Some are hilarious, others dumb, some are dangerous and border on illegal; if it were not so expensive, time wasting and bloody tragic I could probably have a laugh. Started the collection because I honestly believed one FOI letter was a joke, it wasn't.

We could spend some of the newly minted 89 million and hire one or two real experts and do a 10 day course, you know a training course of some value which would provide a measurable safety outcome.


Selah.

[gobbledock]

Funny that, FOI's love the flying aspect of the regulatory life (don't forget it is the blokes up the pointy end that count, nobody else in aviation is important!) and most of those blokes are crusty old has-beens who spend their day wishing they were still flying those shiny 707's and Connies!! They wouldn't know a SMS if it bit them on their weenies. In my dealings I have actually had FOI's say to me that SMS is 'just some modern crap system' and they have no interest in learning it so close to retirement!

We could spend some of the newly minted 89 million and hire one or two real experts and do a 10 day course, you know a training course of some value which would provide a measurable safety outcome. Kharon Kharon Kharon - That money has likely been allocated to employ additional executive managers, bigger bonuses, payrises, gold pass tickets to every ICAO Montreal event, maybe even executive membership to cigar lounges where they can all sit around hypothesizing about safety, discuss international voodoo practises and measure each others weenies (Blackhand does that regularly) in the leather sofa clad library!!

Selcal - I'd hazard a guess that there are even fewer CASA inspectors who have implemented a SMS and have a corresponding pragmatic approach! I agree. If CASA can't implement its reg reform program in 23 years, how can we believe that any of them can or could implement an SMS or any other system for that matter!!
Mind you, the North Queensland CASA regionals are good at implementing bullying, intimidation, thinly veiled threats and other such methods of burning industry trust and respect, they are very skilled indeed.

[Kharon]

GD - Mind you, the North Queensland CASA regionals are good at implementing bullying, intimidation, thinly veiled threats and other such methods of burning industry trust and respect, they are very skilled indeed.Told you, the Sorcery and Law text has been been adopted, it's us, lacking in robust psychic skills who fail to understand this and are out of step with current best practice. http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/thumbs.gif

What, no pig pix, I've grown quite fond of them. :D

[gobbledock]

Sorry Kharon, no pig pics. All the execs are overseas at present and I didn't get invited, funny that? And even if I did get an invite I couldnt afford the business class fares and 5 star accommodation. So I will wait til they all go to another Australian gig (which you, myself and Blackhand pay for) and I will endeavor to snap them lined up at the trough, knee deep in perks, goodies and taxpayer funded luxuries and then I will post the pic. Might even catch them in a conga line makin bacon?
Hell, I had actually staked out the location of their last Regulatory Reform Think Tank but I gave up waiting about 20 years ago, no action whatsoever! Go figure!

[Up-into-the-air]

Have been into the "Books" again.

From the following ICAO report into casa in 2008 [http://www2.icao.int/en/ism/istars/pubfsix/Fina_CSA_AUS_En.pdf ]

The "ICAO Universal Safety Oversight Audit Programme" - FINAL REPORT ON THE SAFETY OVERSIGHT AUDIT OF THE CIVIL AVIATION SYSTEM OF AUSTRALIA

8. FOLLOW-UP ACTION

8.1 In accordance with the MOU agreed to between Australia and ICAO, Australia submitted an action plan on 29 August 2008 as well as comments and updates to the action plan on 28 October, 12 November, and 4 December 2008. The action plan submitted was reviewed by the Safety Oversight Audit (SOA) Section and was found to fully address most of the findings and recommendations contained in this report. The proposed action plan, including comments and clarifications provided by the State, is attached as Appendix 3 to this report. Comments by ICAO on each corrective action are found in Appendix 1 to this report.

Well where is it up too Mr casa????

[Ejector]

Friend for a irresponsible operator.

Foe for a pilot who doesn't get off working exhausted. I feel that CAO 48 is ridiculously restrictive, but now they have gone to the other extreme. :E

[Kharon]

Serious question here, no messing about. I have now had 3 experiences with the BARS audit system and for ease of use, correction and acquittal I have to say it feels to me 'skewed', clumsy and somehow, just not quite right.

There appears to be no flexibility; does anyone else find it's a another one size fits all, blunt instrument and word feast which seems to decide in "Green , Amber or Red" terms if an operation is sound ?.

Definitely not casting nasturtiums on a honest attempt to make thing better, but some of the 'check items' are really fluffy and not remotely related to 'practical' solutions and appear quite esoteric when taken in isolation. (Do East West oriented paper clips relate to CFIT). etc.

If this system which was supposed to be 'the bees knees' for smaller operators is to be adopted by the 'Big end' of the contract world perhaps some considered, sensible industry comment could ease the pain of 'yet another' mindless box ticking exercise and produce some 'real value' measurable safety issues.

Only my (in this case humble) opinion of course, but the question stands none the less for that.

[Kharon]

Sorry - this was supposed to the first post - oh well. :=
Ejector - Foe for a pilot who doesn't get off working exhausted. I feel that CAO 48 is ridiculously restrictive, but now they have gone to the other extreme. It's a tough one, discussed this with lots of folks and almost every man has a different opinion.
Should a FDP system be built into the SMS ?; ignore the CAO for a moment and try to devolve a system which satisfies everyone's agenda.

Individual pilots vary so much in 'what' and 'when' makes them fatigued. The 'job' goes on around the clock so there is little that can be done to effect change in that department.

In defence of CAO 48 when weighed against the FAA/CAA/NZ/PNG rules it's not too bad (as a fatigue management tool). The 'penalty' clauses, particularly for GA charter operations with sensible application from CASA and the company provide a fair compromise between a long hard day and operational requirements.

In 'real' life the most open to abuse system is the FAID, one operator springs to mind where the drivers got a flogging on a regular basis and stayed 'legal', despite being fatigued.

If the 'solution' was built into a SMS on a micro level (per route/ flight/ sector basis) it's doubtful that it would beat human nature and that may well be where the problem lays.

Handing over.