How to Ensure SMS "Compliance"?
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How to Ensure SMS "Compliance"?
An element of the SMS has long left me unsure about its implementation. This is the need “. . . to develop a procedure to identify and maintain compliance with current safety-related legal, regulatory, and statutory requirements . . .” (FAA AC 120-92A). As expected, this is called “compliance” when the auditors come to visit.
By my reckoning, to implement this SMS compliance element completely, a safety department would have to know whenever rules, regulations and procedures change in regulatory documents from say, for example, ICAO, applicable national regulatory agencies (e.g., FAA, EASA, DGCA, etc.) and federal and local regulatory agencies (e.g., OSHA, state and city laws, others). Even if you didn’t keep up with all regulatory changes, you’d at least have to know about the important, applicable-to-you rules and that, by itself, could be a full-time job.
So how do other companies ensure they “remain compliant” with the latest regulations? Surely, not everyone can hire a full-time aviation lawyer. Is there any electronic, automated way to constantly check applicable regulations for changes? At the very least, what do you have written in your SMSes about “compliance” to keep the auditors happy? Thanks for any advice or inspiration.
By my reckoning, to implement this SMS compliance element completely, a safety department would have to know whenever rules, regulations and procedures change in regulatory documents from say, for example, ICAO, applicable national regulatory agencies (e.g., FAA, EASA, DGCA, etc.) and federal and local regulatory agencies (e.g., OSHA, state and city laws, others). Even if you didn’t keep up with all regulatory changes, you’d at least have to know about the important, applicable-to-you rules and that, by itself, could be a full-time job.
So how do other companies ensure they “remain compliant” with the latest regulations? Surely, not everyone can hire a full-time aviation lawyer. Is there any electronic, automated way to constantly check applicable regulations for changes? At the very least, what do you have written in your SMSes about “compliance” to keep the auditors happy? Thanks for any advice or inspiration.
Last edited by flingwing1; 26th Jan 2016 at 01:23. Reason: notification
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Most authorities these days offer RSS feeds.
Other than that it's mainly ear to the ground, professional associations, bulletin boards, tw@ter, etc...
Other than that it's mainly ear to the ground, professional associations, bulletin boards, tw@ter, etc...
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Duchess D, that RSS bit is a new idea for me. I will investigate it fully, believe me.
Thanks - a good one. And I'll probably use your post almost verbatim to write my own compliance section in the new SMS manual I'm slaving over. Cheers!
Thanks - a good one. And I'll probably use your post almost verbatim to write my own compliance section in the new SMS manual I'm slaving over. Cheers!
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Even if it's not RSS, Twitter, etc., most (democratic) governments will have a website or at least a page in the "flag" newspaper that outlines upcoming regulatory changes. Often this gives far more information about the change than other formats and may also allow you to "prepare" for upcoming changes that have not been made law but are in the process of being written.
Here in Canada it is called the Canada Gazette, just to give you an idea.
Looks like this may be a good start for your neck of the woods.
Anyways, to really keep abreast of changes, my company has our safety guy check the Gazette once a week. He has a list of regulations that he is looking out for which were provided to him by the department heads way back when we first started down the SMS path.
He will then forward any of the regulations that are seen to change back to those department heads for action via the SMS. That allows the company to not only demonstrate they have identified the regulatory change, but to also demonstrate short and long term corrective action plans. Thus, when the regulator shows up we demonstrate regulatory and SMS compliance.
Hope this helps!
Here in Canada it is called the Canada Gazette, just to give you an idea.
Looks like this may be a good start for your neck of the woods.
Anyways, to really keep abreast of changes, my company has our safety guy check the Gazette once a week. He has a list of regulations that he is looking out for which were provided to him by the department heads way back when we first started down the SMS path.
He will then forward any of the regulations that are seen to change back to those department heads for action via the SMS. That allows the company to not only demonstrate they have identified the regulatory change, but to also demonstrate short and long term corrective action plans. Thus, when the regulator shows up we demonstrate regulatory and SMS compliance.
Hope this helps!
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It did help, TSRA. I checked out the CDN Gazette site and, after that, searched for something similar in the USA. I found it: it's called the Federal Register (online). It appears to have a subscription service.
I will include that in putting together some sort of "reading file" of news reports sent to a special email address in my company so that all can be reviewed regularly. I believe that should help prove our SMS' "intent to comply" to any auditor who happens by and who know, the system may actually work (grin).
Thank you for the idea.
I will include that in putting together some sort of "reading file" of news reports sent to a special email address in my company so that all can be reviewed regularly. I believe that should help prove our SMS' "intent to comply" to any auditor who happens by and who know, the system may actually work (grin).
Thank you for the idea.
Last edited by flingwing1; 9th Feb 2016 at 03:28. Reason: typo
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This question got me wondering if the UK Official Gazette would be the definitive single source to monitor for new rules affecting UK aviation at least.
Their website is a typical Civil Service IT lash up; looks quite good until you try to actually use it.
After going down various blind alleys, a search for any documents naming the Civil Aviation Authority, and/or Civil Aviation gave me some links, the latest of which was the news, published on 31 Dec 2015 that one Andrew Haines had been awarded an OBE for services to Civil Aviation.
My Dad got a richly-deserved OBE shortly before he finally died from the aftermath of diseases picked up in SL III and the Long March; he toiled ceaselessly for decades in his own time for the welfare of ex-RAF veterans fallen on bad time, and made a difference for hundreds, perhaps thousands of people.
I wish I had not seen that this pointless, time-serving bureaucrat, presiding ineffectually over the decline of a once-respected and now useless institution, has been awarded the same honour, which is thereby so devalued as too render it worthless.
Sorry, inappropriate drift, back to the thread.
Their website is a typical Civil Service IT lash up; looks quite good until you try to actually use it.
After going down various blind alleys, a search for any documents naming the Civil Aviation Authority, and/or Civil Aviation gave me some links, the latest of which was the news, published on 31 Dec 2015 that one Andrew Haines had been awarded an OBE for services to Civil Aviation.
My Dad got a richly-deserved OBE shortly before he finally died from the aftermath of diseases picked up in SL III and the Long March; he toiled ceaselessly for decades in his own time for the welfare of ex-RAF veterans fallen on bad time, and made a difference for hundreds, perhaps thousands of people.
I wish I had not seen that this pointless, time-serving bureaucrat, presiding ineffectually over the decline of a once-respected and now useless institution, has been awarded the same honour, which is thereby so devalued as too render it worthless.
Sorry, inappropriate drift, back to the thread.
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@Capot: from the "Funny-You-Should-Mention Dept.": I almost made a post here a few days ago that sounded like the beginning of yours. You said the UK Gazette website was a "Civil Service IT lash up". I couldn't have said that any better concerning our friends at the FAA.
I recently went to the FAA's website to figure out how I could make this RSS news feed idea work to help substantiate even in part my "compliance attempts" with a Company SMS. I looked all around the FAA's site and they do have RSS on offer. However, I checked where all the news feeds would come from if you did subscribe. Unfortunately, the FAA will happily send you news about Press Releases, Fact Sheets, Speeches, and even Testimony. However, nothing is mentioned about news for proposed or new regulations, airworthiness issues, NOTAMs, etc. Huh?? Shouldn't the FAA first supply "need to know" info by modern electronic means before all that "nice to know" guff?
Not being dissuaded by this, I wrote the FAA from inside its web site to ask that same question (albeit more politely <grin>). It's been three weeks and I haven't heard a thing from them. Too bad. I wish a government agency I support with my tax money was more responsive.
I still like this idea of using RSS feeds to help substantiate the issue of SMS compliance. I just hope I'm missing something and at least some of the world's major aviation authorities can supply needed regulatory news by RSS feeds. If anyone has a follow-up idea, I'd like to hear it. CU.
I recently went to the FAA's website to figure out how I could make this RSS news feed idea work to help substantiate even in part my "compliance attempts" with a Company SMS. I looked all around the FAA's site and they do have RSS on offer. However, I checked where all the news feeds would come from if you did subscribe. Unfortunately, the FAA will happily send you news about Press Releases, Fact Sheets, Speeches, and even Testimony. However, nothing is mentioned about news for proposed or new regulations, airworthiness issues, NOTAMs, etc. Huh?? Shouldn't the FAA first supply "need to know" info by modern electronic means before all that "nice to know" guff?
Not being dissuaded by this, I wrote the FAA from inside its web site to ask that same question (albeit more politely <grin>). It's been three weeks and I haven't heard a thing from them. Too bad. I wish a government agency I support with my tax money was more responsive.
I still like this idea of using RSS feeds to help substantiate the issue of SMS compliance. I just hope I'm missing something and at least some of the world's major aviation authorities can supply needed regulatory news by RSS feeds. If anyone has a follow-up idea, I'd like to hear it. CU.
