ICAO Pushing SMS will send the industry broke

[Dick Smith]

Barry Aylward, the Chairman of Aircraft Electronics Association, has written a very interesting article (see here (http://www.aea.net/AvionicsNews/PointOfCommunication.asp)). Specifically, note the comment regarding the ridiculous extra paperwork that is required.

“It is driven by ICAO and ostensibly focused on the air transport world; however, aviation authorities are zealously applying SMS requirements to all facets of aviation. All major regulatory authorities worldwide are caught up in this panacea. There is absolutely no concern whatsoever for the efficiency and competitiveness of business. Callous disregard would be more accurate!”.
Of course, many posters on this site will know that this is what I have been on about for many years. That is, we have to reduce unnecessary costs, not increase them. We will soon find that even in the major capital cities there won’t be an electronics organisation that can service our equipment. This is because the costs they have to charge to cover the ridiculous ICAO-type paperwork and requirements which Australia seems to be copying means they cannot run a viable industry – in effect, they go broke and provide no service at all.

[Checklist Charlie]

Regulators have realised they can by simply mandating it so, get industry participants to do the regulating for them.

National Regulators seem as though they have lost the genuine aviation knowledge and simply repeat 'parrot' fashion from which ever regulation they deem appropriate.

:=

[Falling Leaf]

The aviation industry is unique in that it is the most exposed industry to high oil prices.

It is the rising price of oil which will send the industry broke, long before any ICAO safety compliance type paperwork.:ok:

We may have affordable safety, but we have run out of affordable oil.

(Regarding safety compliance costs, at least Australia is behind most of the World in introducing SMS - that should save the industry some money).

[Australianguy]

Dick,

The article you have referenced is perhaps one of the most biased articles that I have ever read. The author clearly has little concept of what SMS is all about.

For the record SMS is a positive for the industry, as it ensures operators clearly document their policies, procedures and practices. Basically, SMS is all about ensuring that an operation has in place a system that allows hazards to be identified and risks managed in a structured and consistant manner.

From a regulatory perspective a formally documented SMS ensures that an operator has in place policies that reinforce safety at all levels of an organisaiton, a method for recording hazards and their associated risks, and a strucutred way of reviewing safety (audit processes).

Further a SMS is not a one size fits all approach to safety. Small organisations (with several aircraft) are not required to have a SMS that is as complex as a large operator (as ICAO clearly states). An SMS is not a whole bunch of processes that are new to operators. In the most part just about every airline will already be doing all of what is required under a formally documented SMS. All they need to do is tie their various processes together.

Before launching into an attack on SMS, perhaps some reading on what SMS is all about would be in order. Clearly your understanding is limited on this issue. I would be happy to provide you with further information on the benefits of SMS should you require it.

[flying-spike]

(1) He doesn't understand the economies that can be created by systemised safety management
(2) He is not a professional pilot (not employed to fly) so does not understand first-hand the relationship between a pilot, their employer and their management system.
(3) Recent developments in Safety Maangement Systems started NORTH of the Canadian/U.S. border

[4Greens]

The major benefit of SMS is to transfer the cost of regulation from the regulator to the regulated.

[Massey058]

4 Greens,

Very true in reagrds to the regulator(s) and I think this is one the key dangers. SMS is indeed a very positive thing and something as mentioned that can be tailored to the size of the operation. However, with they way it is being pushed by some regulators it seems as though for them it is a tool to extricate themselves from their own responsibilities.

In Indonesia the DGCA seems very keen for all operators to establish an SMS, the problem is it appears that in doing so they hope for this to address the huge concerns about their oversight of the industry. SMS introduction is this case should not be at the expense of the regulator getting their own house in order.

[Howabout]

Confusion reigns. Does an SMS improve safety levels, or is it just a hollow shell? Is it a positive development that means we are 'ICAO compliant,' with quantifiable benefits, or does it mean, according to Dick, that we are expending additional money for no gain; other than we have an 'ICAO compliant' SMS?

I tend to side with Dick on this. It sounds like bureaucratic wall-paper. The illusion of 'doing something.'

[27/09]

Australianguy

I would be happy to provide you with further information on the benefits of SMS should you require it.

Perhaps you might like to post some of those benefits here.

What does it do that isn't being achieved now. At this point I tend to agree with Dick and Howabout.

It sounds like bureaucratic wall-paper. The illusion of 'doing something.'

Could you mean a bureaucratic mirage? :)

[compressor stall]

People are running scared of the SMS - particularly in North America (and south of that border!) from what I saw there recently.

But really most companies should already have an informal SMS in existance. It's the sensible safe way of doing business.

One poster above has summarised it well - but to shrink that to a paragraph for those with short attention spans (and ironically who are usually the most vocal):

What the SMS is really about is recording the process that you (should) already undertake to stay safe, finding any gaps, and make sure it works and reviewing it. If you think that a SMS will send your company broke, then you should not be in the air.

It is nothing to be scared of Dick, and it will not send the industry broke. Of course there are people around who want to flog different products and have their own money making agendas, but they are not necessary.

[Howabout]

All, I am not a heretic, but would really appreciate knowing what the value is over and above what happens now.

There will always be rogues - check out the taxi industry - but the majority are honest and seek to put airworthy aircraft on the flight-line that fly the travelling public around and get them back safely. Check out the number of tourists that have been accommodated out of DAR in the last 20 years to places like Kakadu, BTI, the SW and beyond. How many fatalaties?

I am willing to be educated, but cannot see what slavish adherence to ICAO is going to do for us. Some African states are 'ICAO members' and the last thing I'd do is set foot in one of their aircraft.

[flying-spike]

Too many operators think that the expectation of the local regulator or ICAO is that an SMS will be a cure all for the organisation. Nothing could be further from the truth because without a cultural shift in the organisation the SMS is nothing but a manual sitting on the shelf.
By formalising an existing system or establishing a new one that embodies the intent of the ICAO structure, the operator lays the groundwork for the things that do make cultural change.
Some of the benefits are:-
(1) a just reporting system that helps to eliminate risk by encouraging reporting and compelling the operator to make positive change therefore demonstrating the value of employee input
(2) Greater safety awareness through ongoing training
(3) The underlying quality system of an SMS also contributes to greater economy in the wider organisation.
(4) Reduced insurance premiums and greater customer acceptance particularly with large companies (especially in the mining sector) that have had their own SMSs for a number of years.
(5) Reduced wear an tear on company assets (aircraft or GSE) as employees demonstrate greater ownership because of the improved culture.(FDAP)
(6) Increased individual performance due to enhanced understanding (both by the employee and and employer) of human factors especially fatigue

The stats are out there on SMS, you only have to look at organisations like Boeing for them. I would urge any of the sceptics to look a bit further afield than just blaming ICAO or CASA because things are changing.

[chimbu warrior]

Actually on this one Dick, I think you might be wrong.

Having done a couple of courses on SMS, I am positive that it will bring benefits to all operators, be they maintainers, airports, airlines or small charter companies.

I liken the benefits of an in-house SMS to those offered by an in-house check and training organisation; it offers a great deal of flexibility to the company, and affords them the opportunity to customize the SMS for their particular operation. More importantly, it offers the chance to integrate the SMS at all levels of the business (not just those that CASA might look at). Furthermore, it requires management (and board) commitment to SMS principles, and holds them directly accountable.

I'm all for it.

[the wizard of auz]

I spend a lot of time in the mining industry, and I can tell you that the mining industry has developed the SMS into a time consuming and expensive effort. Safety is certainly a priority, but it has been developed into a whole industry of its own. You can have systems in place to identify, report and fix safety issues, but given time, interested parties can put more paperwork and non nonsensical rubbish, for little to no benefit,in your way. all for the sake of having an SMS.
I thought we already had an SMS in place. its called an Operations Manual. If you have concerns that some procedures are not as safe as the could be, bring it to attention of your safety officer or chief pilot. The ops manual should then be reviewed and amended. If that does not have the desired results, your local FIO should be the next stop.
Paperwork for the sake of paper work does not make a safer work place, and in fact will on occasion make things less safe. Ask anyone who has worked in the mining industry where safety has become its own industry. I sh!t you not, I have seen written procedures for lifting a bucket and opening a packet of welding rods.

[A37575]

SMS is all about ensuring that an operation has in place a system that allows hazards to be identified and risks managed in a structured and consistant manner

Stripped of the bulls..t SMS is an expensive time consuming way of minimising the risk of litigation both from the "victims" and the regulator.

[Fred Gassit]

God forbid we ever get as safe as the mining industry, can't drive that Ford pickup or 70 series Landcruiser on site, it's got a V8!

PS Don't forget to chock your vehicle in the visitors carpark.

[the wizard of auz]

exactly my point. :ok: From a good thing to a ridicules thing. just add time. :ugh:

[compressor stall]

Wiz, you speak a deal of reality with respect to the mining industry. It has become an industry in itself - but ask yourself why? Who is driving that? There was no regulator doing it....

Also the ops manual and procedures you outline do form a large part of the SMS. But the SMS goes a bit further as outlined in several posts above.

A good safe aviation company will already have most of a SMS in place. It's just not formalised and standardised as such.

It does not have to be time consuming and onerous - or expensive. I set up ours and it's been in place for nearly 2 years now. It does not take much of my time to keep it ticking over and it has seen the scrutiny of several govt departments and industry audits.

Those bleating the loudest about the cost should ask themselves about how serious they currently are about analysing their present operation instead of the, "She'll be right, won't happen to me" approach.

[the wizard of auz]

but ask yourself why? Who is driving that? There was no regulator doing it....
Actually, it is pushed quite hard by the mines department, along with worksafe and unions.

Those bleating the loudest about the cost should ask themselves about how serious they currently are about analysing their present operation instead of the, "She'll be right, won't happen to me" approach.

Certainly nothing wrong with analyzing an operation. and in fact it should be done and reviewed regularly. but after seeing some of the stuff I have seen happen in the mining industry, one does not have to have a "she'll be right" attitude to not want extra paperwork. Safety should be a priority for sure, but a simple and working example of a SMS can, over time, become a complex and time consuming nightmare when it is regulated by a government department. (just look at VFR flight now days). The Ops manual was meant to be a means to keep your checks and risk management in place. why change something that already exists and is meant to be reviewed and amended as the need arises?. A good manual will have all the risk management you will ever require. (just look at mine :ok: )

[flying-spike]

One post to kick things off now we haven't heard dick from er..Dick

[Dick Smith]

No need for me to say anything. Lot's of good posts on this thread.

More money spent on paperwork can make a business less viable and then you really have to worry about safety!

[flying-spike]

"We will soon find that even in the major capital cities there won’t be an electronics organisation that can service our equipment. This is because the costs they have to charge to cover the ridiculous ICAO-type paperwork and requirements which Australia seems to be copying means they cannot run a viable industry – in effect, they go broke and provide no service at all."
http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/statusicon/user_online.gif http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/buttons/report.gif (http://www.pprune.org/report.php?p=5087751)

G'day Dick, I am curious as to how the electronics organisation will be burdoned with "ICAO-type" paperwork when the requirement for SMS only covers low capacity and high capacity RPT AOC holders. As far as I am aware the onus is on the AOC holder to demonstrate how they recognise the safety involvement of third party providers in their service level agreements which I wouldn't think would be too onerous to the service provider.

[Dick Smith]

I will see if I can get one of the Aussie electronic shops to reply. Probably not until Monday.

[triadic]

The industry that requires a SMS more than any else is health. When doctors and health workers start reporting their own errors we will start to see an improvement, however the threat of legal action has them running scared and as a result we get more folk dying in hospitals than on the road and certainly in the air.

I am all for a practical SMS with the appropriate reporting culture that enables us all to learn from others mistakes and workplace errors or deficiencies.

The Aviation industry has been doing it for over 50 years and it is not rocket science. It is more about a culture of reporting and learning than anything else. These days having the appropriate software does help in things like keeping records and especially trend analysis. As for sending the industry broke, I doubt it. Outside of RPT a SMS need not cost much at all, but it is a part of doing business – have an accident and most small operators will be out of business. You just can’t afford not to do it.

One must also remember that ICAO is aimed firstly at RPT carriers and not GA. It is up to the various regulators as to how they apply the ICAO recommendations.

What’s the old saying: “You think safety is expensive, trying having an accident”

[triadic]

Further comment: Mind you if we look at the European example then the way the regulators are acting there is certainly sending GA to the wall in many cases. Look how expensive it is to operate a small GA aircraft in the UK or Europe these days. In many cases the regulator is making no allowance and information to hand suggests that they are applying RPT standards across the board. (eg: escape slides on a DC3....!)

I think we have to be alert to anything similar occurring here and maybe the thin edge of the wedge is already with us with the elimination of such things as Aerialwork and Charter operations... it is all about carrying passengers, but not doing joy-flights as we knew them!

I am of the belief that GA has a big fight around the corner, just for its very survival. Airport charges were the first hit, followed by Airways charging. What will be next?? It does not help to have a government (of either side) that is not aware of the benefits of a strong and viable GA industry.

In that regard, we are are own worst enemy and the day GA speaks with one voice will be the day Canberra stand up and listen! Sadly I wont put money on that occurring anytime soon! (too much self-interest)

What has this got to do with SMS sending the industry broke. It won't because the government will do it first!

:ugh::ugh::ugh:

[OzExpat]

Much has already been said about SMS, some of it from people who have no understanding of what it is, how it works and why it is necessary. Taking the last part first, does anyone seriously doubt that human error is the major cause of all the problems encountered in ANY business? Even Dick Smith should understand that concept from the time when he employed people in his various business ventures.

So what is SMS all about? It's about engaging people to be conscious about hazard identification and risk management. It's about management and staff collaborating to reduce risk to a level that can be tolerated and so that everyone in the company understands the residual risk and the strategies that are in place to manage those risks.

How does it work? As has already been pointed out, this differs between large and small companies but here's some simple examples in every day life, for a starter.

You're driving along the road at whatever is the legal speed limit, when you see that you're approaching a 4-way intersection that isn't controlled by traffic lights. What are you going to do? Setteing the road rules aside, for a moment, you scan for potential hazards to your progress through the intersection. You assess the risk involved in maintaining speed and continuing against the mitigation strategy of reducing speed, even slightly, in order to be ready to stop, to avoid a collision.

As a pedestrian, you might might be using a pedestrian crossing at the same intersection. Do you just walk or run across the road, or do you first look up and down the road and even at the visible section of the intersecting roads? Do you automatically expect all traffic to stop for you, on the crossing? Is there an invisible wall on each side of that crossing to protect you from being hit by a car whose driver either didn't see you in time or maybe is drunk, on drugs or, due to illness, might be in a hurry to get to the doctor?

There's no shortage of reasons for risks and no shortage of risks to be faced. You might think that you are only responsible for yourself in either of those situations, but the driver is as responsible for the pedestrian as the pedestrian is for the driver. It is the recognition of this that drives road rules as much as it drives aviation rules, but we all know that rules can go only so far in risk mitigation - there is no set of rules on earth that will apply to each and every hazard that human beings can face.

We are all well aware that there's plenty of risks in aviation, no matter what part of the industry you're in. SMS is intended to help human beings to identify the hazards and then devise risk mitigation strategies. It doesn't need to be complex, especially for smaller companies though it might well be more complex for a large company.

The devil is in the detail of what can be done to first identify the hazards, then devise the strategies that reduce or eliminate the hazard, then educate the staff about the risk, what must be done about it and how to avoid or minimise the residual risk. A company will not know its overall level of risk until it starts using SMS to formally document all the hazards and provide on-going corporate knowledge.

In most companies, a chief engineer will know the hazards to himself and his staff and will have devised ways to deal with those risks. The same is true for the chief pilot and, indeed, from the CEO right down to the janitor and caterer. Without a formal SMS in place, what happens when a department manager leaves the company? The simple fact is that all his knowledge of risk goes with him and his replacement has to start all over again. This is why we never seem to learn from history.

You will never know how safe you are until your company completes an overall survey of risks to the business. Once this his been done, there is a benchmark for the starting position which will allow safety management to be improved and constantly assessed. It allows for staff to report on the effectiveness of any risk reduction strategy or to notify new risks.

So, after the SMS has been established, what new risks might arise. How about when a small company wants to upgrade to larger and more sophisticated aircraft? How about when there is a need for a new way to handle a particular aspect of aircraft maintenance? How about when a company changes its flight and duty time scheme? How about when a manager leaves or a particularly valuable staff member leaves?

What can a company learn from an incident or accident that might help it to avoid any recurrence of that incident or accident? In Oz, we used to have a "crash comic" that went some way to educating people in the industry but that often came out a very long time after the event and most people may even have forgotten about it. There is a clear need to keep the human error factor as low as possible in the list of hazards.

As has already been rightly pointed out, there are many companies within the aviation industry that have already embraced SMS. This has, for the most part, been forced on them by a particularly valuable client who is interested in ensuring the safest possible environment for their employees and products, plus the lowest possible insurance premiums that they must pay. In the process, many companies have already reported cost savings from the implementation and active on-going use of SMS in their business.

SMS goes beyond the rules to be a mindset that includes "no blame" reporting of safety violations within a company. This is essential because it is the only way that a company will understand all the hazards that it faces. There is no set of rules that can do that. A company with an active SMS is able to react more rapidly to a safety violation or the identification of a new risk than any rule amendment can ever be.

An SMS is, therefore, not merely a manual that gathers dust on a shelf. Any company that regards it that way is not doing the right thing by its staff or its own bottom line.

[Mach E Avelli]

The concept of SMS is fine, good, makes sense; we love it. If you think safety is costly, try having an accident etc. Most of us are believers; we have seen the light.
The problem as originally raised by Dick Smith is that the small end of town simply can not afford fancy CASA 'approved' systems where they want weekly reports containing pretty pie diagrams and graphs, monthly committee meetings, minutes, in-house safety magazines etc etc. all to present at the annual CASA audit as 'evidence' that their SMS is alive and kicking. CRAP. Utter, utter CRAP. Small companies will fiddle this stuff, or just won't do it.
If CASA would simply accept that a small operator could have a basic reporting system (piece of paper) and follow-up (chief pilot/chief engineer/CEO) and that it was logged, with action - when deemed necessary - or no action (and reason why no action); well, smart small operators would probably support the concept. Especially if they could get reductions in insurance premiums.

It's right for ICAO to mandate SMS and for CASA to follow. It's wrong to expect some little outfit with a couple of bugsmashers to have the same system as Big Sky Airlines. Also, if it is mandated, there should be no charge to 'approve'. If there is no charge, CASA won't allocate too much time to the smaller companies with very basic SMS.

[OzExpat]

You'll get no argument from me Mach. I think it's pretty clear to everyone that CASA got it wrong when they required all operators to use a common SMS "template", regardless of the size of the operation. At the time they did that, the whole concept was pretty new to aviation regulators and there wasn't a lot of information about it.

Times have changed and most regulators now understand that there isn't a "1 size fits all" solution. It is also generally recognised now that the KIS principle is as necessary to SMS as to every other aspect of work within the industry, no matter what part of the industry we can think about.

Yes, there IS a need to benchmark the starting point. Yes there is a need to monitor and improve where necessary to the safety of employees as well as to reduce overall company risk. But, no, it certainly doesn't need to be rocket science for operators.

It can even be argued that the smaller operators are actually in a better position to implement SMS than the bigger ones, because all the staff know each other, including the boss, usually by given name. Such a structure is much more conducive to SMS than in "Big Sky Airlines" because there's a fundamental friendship among the company personnel which can be encouraged to participate in SMS and report potential, perceived or actual hazards to the company's operation (which, of course, includes the staff).

In smaller companies, it's actually easier to keep SMS going with regular reviews, for the same reason as noted above. And it can often be quite effectively done at the end of the day, over a beer or 6. Just as long as there's a record so that the company knows what needs to be addressed.

Once your system is in place and working for the benefit of the company and its staff, reporting to "Big Brother" will be simpler and compliance with the legislated requirement will be easy to demonstrate. As I said in my previous post, most (if not all) companies already have knowledge of the risks in each part of their operation - all that needs to happen is to tie them all together so that everyone understand the hazards, understands the risk reduction strategy and, equally importantly, understands how to manage the residual risk.

It might sound complicated but it really isn't complex at all and can be readily and simply managed, just as Stallie has said.

[compressor stall]

Mach - I have heard CASA say in seminars that an SMS size and complexity must be tailored to suit the company.

I think one of the problems / misunderstandings with the early stages of the SMS concept was that it was new and operators were looking for a template to use to make it easy as they did not understand what they were doing....

[max1]

In a perfect world, SMS would be perfect.
Being able to show CASA that you have an SMS is relatively easy.
What is important is that CASA inspectors have the ability to get 'inside' the SMS and ensure that the system is being applied correctly, and that the users are comfortable and confident that their companies' SMS is being applied as advertised to CASA.

Inspections should be treated like a DAMP. After the bookwork is done the inspectors should take a random sample of people in safety critical areas and ask them a few questions about the companies SMS. This will allow the inspectors to see what the SMS culture inside the company is really about and whether the employees are trained to apply the system and also if there are issues inside the organisation.

As has been stated, for most, it doesn't need to be rocket science.
However, if the people who are supposed to be involved in it aren't aware of what their responsibilities are or believe that it is all just 'window dressing' for CASA inspections, then it doesn't matter how good that SMS seems on the surface it is just a waste of time.

[lowerlobe]

The aviation industry is unique in that it is the most exposed industry to high oil prices.
Falling Leaf....Would you care to rethink that line?

[spirax]

Being able to show CASA that you have an SMS is relatively easy.
What is important is that CASA inspectors have the ability to get 'inside' the SMS and ensure that the system is being applied correctly, and that the users are comfortable and confident that their companies' SMS is being applied as advertised to CASA.

No way does anyone from CASA get "inside" the SMS I manage. They can see the front-end, results and reports etc. They don't get to see anything with names or ID. To do so would destroy the system you are working so hard to build.

[flying-spike]

"and that the users are comfortable and confident that their companies' SMS is being applied as advertised to CASA. "

So do you think asking those who's safety you are managing is inappropriate?

Let's hope that the paranoia doesn't affect your reporting culture. After all, if there was anything worth CASA's interest in your reports that could possibly attract any punitive action, you would have reported already, wouldn't you?

[max1]

Sorry spirax and flying spike, I am not sure we are reading from the same page.
By getting 'inside' the SMS I am not talking about individuals being identified. However if someone in an organisation has gone to the trouble to put in a report to their own organisation I would think that CASA knowing the individuals identity would be the least of their concern if they were in a company that preferred not to hear unpleasant news.

Flying spike what do you mean by this

'So do you think asking those who's safety you are managing is inappropriate?'

I might be a bit dim, but I can't make head nor tail of it.

My point is, is it alright for those who are managing/running the system to sit down with the CASA inspectors and answer CASAs questions, show them how it works in theory and for the CASA inspectors to go away believing that it is a robust and well implemented system without talking to the staff who are supposed to avail themselves of the system. What is CASAs responsibility and duty of care in all this.

Why do we have DAMP testing? Is it good enough for CASA to say do you have a drug and alcohol management plan, have your staff completed the requisite training or education. Is this good enough? No CASA still check, and good on them.

What I am alluding to, is that this should also be done for the SMS. It is alright to show CASA what your SMS is but CASA should also go further into and demonstrate to themselves that the system is working INTERNALLY as advertised.

Is it okay for ASIC or the prudential authorities to ask banks/ insurance companies if they are doing the right thing, or should they be required to actually dive in and have a bit of a poke around to make sure what they are being told is actually what is occuring?

Unfortunately what tends to happen is that those doing the right thing are loaded up with further reporting costs because those that were able to hoodwink the regulators have caused a knee-jerk reaction from said regulators who are then embarrassed to add further reporting requirements.

If the regulators had been more diligent in acquitting THEIR responsibilities this may not have happened.

[tipsy2]

Many valid posts about this important subject

However:

Dick's thread heading

ICAO Pushing SMS will send the industry broke

should be challenged.

If any industry (in our case, aviation) does not manage all the threats to its viability and ultimate existence, then it will go broke. Safety is just one of those threats that must be managed, not just for safety's sake but for the reputation and future viability of the business.

Mention has been made of the mining industry, if a business cannot demonstrate a robust SMS to a mining company then there is a snowballs hope in hell of getting any work (contract) from that miner. They cannot 'risk' their own staff being carried by an aviation business that does not manage safety to a minimum level(OH&S requirement as well).

Dick, I must disagree with your "ICAO Pushing SMS will send the industry broke", if the industry doesn't manage safety, it will go broke.

Keep this good dicussion going.

tipsy

[flying-spike]

I have been audited in the past and I think it is appropriate to ask those involved in and using the system what they think. That is one way for the auditors to "get into" the system to see if it is actually process in practice or just a fancy manual. Naturally when you talk to the troops you will know their names. I also believe that confidentiality has to be respected

[Carrier]

Quote: “For the record SMS is a positive for the industry, as it ensures operators clearly document their policies, procedures and practices. Basically, SMS is all about ensuring that an operation has in place a system that allows hazards to be identified and risks managed in a structured and consistant manner.” Huh?

Quote: “The major benefit of SMS is to transfer the cost of regulation from the regulator to the regulated.” As in put the fox in charge of the chicken hut?

SMS is useless. It is not needed for the competent and ethical operators because they are already doing what they should be doing.
The bottom-feeder operators will put some paper in place but will still operate as before. SMS will be ineffective for dealing with such operators. Further, be warned that anyone who uses the SMS in such situations will find that it is held against them and they are soon terminated. The only answer to lax operators is increased supervision with surprise inspections, followed up by enforcement action of sufficient severity to either remove them or force them to reform.
Seeing as SMS will not solve the problems it was brought in for, it just becomes another massive bureaucratic cost for legitimate operators.

[Pacific Pete]

I believe a lot of you have missed the point of the article. This artical was written for GA/Corporate Avionics Workshops. This article was not directed at Airlines and big operators.

An SMS system will be a definite advantage to large operators in helping them create a more aware safety culture.

However for small maintenance organisations it will be a nightmare. We recently introduced our Drug And Alchol Management Plan (DAMP). The process of writting the manual, implementing it and training all of the staff as required cost the company $20,000. For a samll compnay of less than 20 staff that is a ridiculously expensive excercise for no safety benefit as there has never been one incident (according to CASA) of drugs or alchohol causing a maintenance issue. So here we go with an SMS requirement that is going to cost considerably more than the DAMP. It will have on going costs, it is difficult to manage in the small environment.:ugh:

[Pacific Pete]

Post #22 Says that SMS is only for High capacity RPT etc. That is incorrect. SMS is being implemented with them first and then being implemented with everyone else at later dates.

Dick's point about it being onerous is spot on for the GA MRO's. The gradual increase in regualtory burden has seen an gradual decrease in the amount of MRO's available. As an example when I first came to Bankstown 15 years ago there were 12 Avionics shops. Now there are 3. The majority of those that I had personal contact with all said that regulatory burden was one of the main reasons for closing their business. BAL was next on the list.

In small organisations the ability to meet all of the criterior dreamed up by public servants who have too much time on their hands is costing Australia dearly by the loss of small business's that just cant cope. Most people in small business work rediculously long hours already, how are they to cope with the ever increasing burden. Small MRO's aleady deal with Federal Gov regs, State Gove regs, ASIC Reg's, OHS, Accounting Regs, DAMP, SMS, Company Law.........how is anyone already working a 60 hour week ever supposed to keep up with it all already, let alone what ever they "dream up" in the future. It is difficult enough to keep a business viable just with the day to day let alone the reg burden. Where does it all end?:ugh:

[flying-spike]

"Post #22 Says that SMS is only for High capacity RPT etc. That is incorrect. SMS is being implemented with them first and then being implemented with everyone else at later dates."

As a matter of fact you are incorrect. I said that the requirements cover Low Capacity RPT and High Capacity RPT AOC holders. Please show me in legislation where MROs are covered by the requirements. You would be best served to read the SMS CAAPs and the applicable CAOs.

[OzExpat]

Not being involved in the Oz aviation scene, I can't comment on whatever CASA is pushing these days - or perceived to be pushing. ICAO wants SMS to apply to ALL certificate holders in the aviation industry of each contracting State. In practice, if SMS was restricted to the operators and the cockpit of aircraft, it would not achieve its purpose.

The whole point is that it focusses on human error aspects in EVERY aspect of aviation. It empowers everyone, from the Janitor to the CEO, to report anything that might be perceived as a risk to the business or the staff, so that the workplace - whether a cockpit, a control tower, an airport, a maintenance company or parts manufacturer or whatever - becomes a safer and more profitable part of the company.

I don't believe the adage about "if you think safety is important, try having an accident". The fact is that SMS is aimed at reducing the possibility of the accident and, in so doing, keeps staff happy, productive and safety conscious. In such an environment, even when a staff member made a fairly serious error, the company can learn from the event without punishing the staff member who dobs himself/herself in. That's what a "just" culture is all about and it is the ONLY way that a company finds out about all the risks in its business.

Don't ever lose sight of the fact that SMS is about people more than its about regulation. As I've said before - and will say again - regulations can't possibly cope with all the situations that human beings will confront. We need to keep humans in the loop, but we need to do it with respect for the fact that, as human beings, we are all fallible and that, on occasions, those fallibilities can lead - and have led - to undesireable outcomes.

I refuse to believe that anyone would oppose the aim of reducing the hazard associated with human error.

[grip-pipe]

Well as far as I can tell there are several hundred regs already in existence that are the basis for risk management so now everyone is going to have to sit down and see how the regs fit their operation (big or small) then add layers of nonsense about how to manage those risks. Used to be called an ops manual.

No argument about risk management for mining, manufacturing and petroleum industries they need such a process because they are constantly dealing with unknowns or unknown unknowns associated with the business. Therefore one good stuff up or failure to recognise and plan for risks blows you off the planet or a small part of it and takes a good part of the business or its profits with it (Remember - Exxon Valdez, Ok Tedi, the mud flows in Indonesia, Longford Gas, Gold Mines in Europe with cyanide, etc.).

No argument that a good aviation operation should be thinking about risk, trouble is the major glaring omission is that you cannot be responsible for what you cannot control so how do you manage that type of risk in the aviation environment where there are many other players, ATC, Refuellers, Airport owners, other operators and operations etc. You can have them do the job well but someone will eventually stuff it up.

The issue is this will be applied by our regulators in such a way as to gut any operator or operation that does not manage risk especially with the still-born half-arse egulatory regime change we are stuck with. It is an open invitation to opinionated based oversight by a mob who still believe they are the self appointed PC Plods of aviation and if past form is anything to go by look out the small and struggling operation, were going to get it the neck!

After all did the beloved new leader of our fearsome regulator not say recently they were going to be a capital R regulator? and consensus from consultation was a waste of time? Sounds like lawyers at 50 paces to me!

Looks like another bureaucratic nightmare which will be probably be ditched after everyone has spent mega bucks trying to make it work and then nothing happening for another indeterminate period, then quietly it will be dropped, anyone remember FRMS? There will be no published standards to hold them to account as usual, only the opinions of those who are still living in the past.

[OzExpat]

Ah yes, there's that old chestnut about an Ops Manual. There seems to be some misunderstanding about this - the Ops Manual is there to address operational legislative requirements. Those requirements can't possibly address human error situations in which PEOPLE can get hurt while simply trying to do their jobs - that's where SMS comes in.

As for it fading away... dream on. This one is mandated by ICAO and, whatever you think about that, the world's insurance industry is going to sit up and take notice. Those who have SMS might not see reduced premiums (then again, maybe some of them will), but it's a pretty sure bet that those who don't have it - or have it merely as a book collecting dust on a shelf - will find themselves with higher insurance premiums.

If you took the time to read my previous posts grip-pipe, you would've seen that SMS is being applied across the whole spectrum of aviation, which WILL naturally include ATC, Airports, RFF, maintenance providers, parts manufacturers, fuel product suppliers, etc., and the list goes on.

Nobody is saying that there won't be occasions when, as you term it, "someone will eventually stuff it up", but thank you for helping to make my point about human error! :ok:

I still firmly believe that genuine employers will have an interest in ensuring that their staff are happy, productive and safety conscious.

[my oleo is extended]

I concur with you Spike.

As much as 'Dick' thinks he is 'the font of knowledge' on all matters large and small, he is not.
A mature organisation will :
A) Already have elements of an SMS active in their structure ( often without even realising it),which is a good starting point and
B) Not listen to 'Dicks' ramblings about costs, expenses or basically anything else for that matter.

What industry needs is education,explanation and some measure of assistance with the whole SMS concept. I feel this has been a weakness on CASA`s behalf,to date, but I remain optomistic that things will change. Rumour has it that CASA has enlisted the technical experience of a group of 'SMS Top Guns' who are fixing the debacle and starting to provide clarity,direction and assistance to industry (unlike 'Dick') so I feel we may have turned a corner or are about to, with the actual help of the Regulator ? Now I know, some will be quite upset with me for throwing some support towards CASA but several organisations I have spoken with claim that CASA have been conducting audits using SMS as the foundation, and although the experiences have been painful, the end results are a 'safer system of operation' for the audited organisation.

Are we on the threshold of viewing a miracle, something not seen since Christ walked the earth ??

[Dick Smith]

I can afford it. Suggest you read again what Pacific Pete had to say.

One day it will probably just be me and Jamie in GA so why should we care if you don't even have jobs.

[grip-pipe]

Well we all agree that safety is an outcome of managing risk. We all know that ICAO has agreed and so has CASA and most other regulatory authorities that a SMS should be the basis of operational management of aviation risk - the argument therefore appears to be about form not substance. To my mind it becomes an issue related to complexity, the more complex the operation the more difficult it is to manage, ergo, your SMS becomes more complex, it is the nature of the beast.

Dick's argument if I understand it correctly is that the way current indicators are pointing that operators will have foisted upon them a system of significant complexity based on a one size fits all approach by the regulator which he correctly points out would be a nightmare of paper shuffling for many. There is not a one size fits all approach except to say you need to identify risks and provide a means of managing what you have identified and means of acknowledging the outliers.

The RFDS for example is a high risk operation in terms of; what they do, where they go to and when they go but low risk in terms of aviation complexity, a big airline is low risk as to where and when they go by comparison but high risk as a result of complexity. A flying training school is inherently a high risk environment and can also be very complex because of it being a training environment. Mixed in between are common risks shared by all in the aviation environment; weather, location and level. You can assume the people who maintain the aircraft are managing that risk and have a different set of risk issues to manage to those operating the aircraft, as do those manage traffic or refuelling etc.

What is not required some bureaucrat mandating you will keep these manuals and follow this or that risk management system and forcing different operators and organisations to produce truckloads of risk management manuals of little relevance or applicability. It appears to me what the bureaucrats want is you to manage their risk not let you manage yours.

Lastly want a good assessment of an impartial but rigorous assessment of your risk - look at your insurance policy and its conditions, tells you everything.

[Kangaroo Court]

Dick,

Not really an "Australian" nor humble response. You have come a long way since selling white mice as a small child in your first private enterprise. I remember your interview and that with your mother on "This Is Your Life", in the late '70s.

I think it's really good that you've made it mate, and you know I'm a big admirer, but don't rub it in too hard!

[my oleo is extended]

I must agree with Kangaroo Court.
Regardless of opinion, Dick`s response is a little harsh, and certainly it is out of character for him not to be 'humble'.Perhaps it was just a bad day ?
Besides, selling 'white mice' is no menial task. It is something inspiring to me, and obviously it has impacted and inspired many others to reach greater heights.

[flying-spike]

1st August 2009, 10:07 #23 (http://www.pprune.org/5096386-post23.html) (permalink (http://www.pprune.org/dg-p-reporting-points/382839-icao-pushing-sms-will-send-industry-broke-2.html#post5096386)) Dick Smith (http://www.pprune.org/members/51495-dick-smith)

Join Date: May 2002
Location: Australia
Posts: 1,640


I will see if I can get one of the Aussie electronic shops to reply. Probably not until Monday.


I hope your "Electronics shops" ( I presume you mean avionics maintenance facilities), are a bit faster fixing your USs. Or maybe they gave you an answer and you chose not to post it.

[LeadSled]

Folks,
Few people disagree about what an "appropriate" SMS can do, I have seen it in action long before it became flavour of the month.

The problem is, it is rapidly becoming a new religion, and like all religions, as soon as human (bureaucratic) nature takes over, the original good intentions are soon lost in a storm of paperwork, giant edifices of worship are erected.

--- as the mining examples show, it ain't just aviation, and all of a sudden a new "career path" is created by regulation. We already have "SMS Diplomas"

For the "practitioner" in the field, it is becoming a nice little earner.

"Here's a CD with your SMS, all I had to do was (in a suitable automated script) add your company name (in one case a small flying school) to my "standard" (CASA pre-approved) SMS manual, just burn an extra and send it to CASA, that will be AUD $25,000 please" ---- which shouldn't surprise anybody, with simple "Operations Manuals" produced by the same "intensive and tailored development for your specific needs" 2 minute method starts at about AUD $15,000.

On a more practical plane (pun intended), I have already had a "serious discussion" with a particular CASA district office, who's FOIs demanded access to the Safety Committee working paper and employee reports ----for enforcement purposes. They clearly believed their right of access to all company records included all SMS/Safety Committee files.

As a practical legalities situation, it is very uncomfortable, because much of what is discussed at "Monday Morning Prayers" often does involve "technical" breaches of the Ops. Manual, (or less often a CAR or CAO) ---- but the aviation law only recognizes a breach as an offense, and usually a "strict liability offense".

This problem is not confined to Australia, there have been some interesting battles between the FAA and the US Dept. of Justice in recent years, with DOJ moving to the courts for access to such as QAR records, for prosecution purposes. Police/Coroner's Court powers to demand "evidence" is quite wide, maybe Clinton might like to as to this as a legal man.

We have problems here now, with state police increasingly getting involved with aviation matters. In Queensland, the definition of a vehicle has been changed to include aircraft, one pilot has already done jail time in a very contentious case ---- a case in which CASA investigated, and decided there was no case.

The QLD. police and courts saw it quite differently --- 3 years was the result.

Would anybody like to put forward the proposition that SMS records have no/some/absolute legal privilege ??

Tootle pip!!

[D.Lamination]

Dick is right - process and paper work do not necessarily equal results.

The nanny state is out of control (I'm talking to you Kevin).:yuk:

[compressor stall]

On a more practical plane (pun intended), I have already had a "serious discussion" with a particular CASA district office, who's FOIs demanded access to the Safety Committee working paper and employee reports for enforcement purposes

That is a serious issue and something that shows the pigheaded ignorance of those CASA employees. It should be taken up higher up the food chain.

CASA must not (and in my experience don't) expect nor get unfettered access to the SMS accident etc / Safety reports. If it's serious enough, its gone to CASA / ATSB already!

As for the pre-approved manuals - CASA can clearly see when one has been purchased off the shelf and gets dusted off before each audit.

[blackhand]

Here's a CD with your SMS, all I had to do was (in a suitable automated script) add your company name (in one case a small flying school) to my "standard" (CASA pre-approved) SMS manual, just burn an extra and send it to CASA, that will be AUD $25,000 please"Should your SMS consultant present this to you get another consultant.

SMS should be a formalisation of the processes and procedures you are already using.
After all your business is operating successfully prior to the SMS being implemented.

The consultant needs to ask each person how they carry out their particular job and help to identify the risks involved. By doing this every body in the organisation "owns" the SMS as they have contributed to it.

I would not have the temerity to come to your company and tell you how to do business.

The best SMS is one that every one understands and is willing to use.

[LeadSled]

SMS should be a formalisation of the processes and procedures you are already using.
After all your business is operating successfully prior to the SMS being implemented.

Blackhand,
How true --- in theory.

But ITRW (in the real world) (don't you feel a new acronym is somehow "more professional") seriously, what has been going on with manuals of all kinds, for years, is just as I describe, and all too often just catch dust on the shelf between audits.

One of the things that always kills me is the reply:"But that's not what we do" from the CP, when a (usually gross) "discrepancy" between practices in the field (or the hangar) and the Ops. Manual is highlighted.

The relationship between CASA "approval persons" and the "CD providers" is that the CASA person, who may have only the sketchiest idea about SMS, knows that, if he or she "approves" one of these CD manuals, all the CASA required regulatory bases have been covered, and he/she will not get it in the neck, internally. CYA rules in CASA.

That the SMS bares no relation TTRW (you can work that out) of the operator , except by coincidence, not design, is regarded as of little importance ---- because we have a system weighted to "legal compliance", which may, but usually doesn't have anything to do with achieving better air safety and business outcomes.

All the "average" operator wants is CASA off their back, because SMS are being imposed, few smaller operators see it as any more than a "compliance issue". The real value of a decent SMS system will never be achieved, in small organisations, under the present system. The larger companies will get the benefits, mostly they already are, all to often in spite of, not because of CASA.

Tootle pip!!

For HREOC compliance, do you find the FIFO protocol is the preferred process.

[megle2]

Leadsled

Your SMS comments above are well put.
There is value in including it in our SMS preamble, would that be ok?

[blackhand]

Leadsled

One of the things that always kills me is the reply:"But that's not what we do" from the CP,This is the problem with having a "generic" manual.
One should never put in an SMS, or Exposition for that matter, a procedure or process that the client does not use or will not be able to comply with.

There is a need for properly qualified and trained consultants to write these manuals, not some ex CASA person who knows how to satisfy the regulations.

I view the quality system, now called SMS, as a very important business tool, not only in aviation but in most business.

For HREOC compliance, do you find the FIFO protocol is the preferred process. Mi no save tok tok belong yupla.:cool:

decode the acronyms for me please.

Cheers
Blackhand

[Dick Smith]

Flying-Spike

Re. your Post 49 - I did get one of the Australian electronic shops to reply. See Posts 38 and 39 from Pacific Pete. I believe he made some good points.

[my oleo is extended]

Oh dear. It looks like Dick and Flying Spike have started an 'SMS Tango' ??

May I suggest you two gentlemen (??) do the following :
1) Duke it out,not in a Cage Match but perhaps in front of an Electronics Boutique or Tandy store?(great products, great prices and no stickers of Dick on the products) or
2) You two could have a 'Nintendo Playoff' (products supplied by J.B Hifi) or
3) You two could always spar each other in a "Phonetic Code Face Off' in which you both use 'Ground To Air Hand Held Radios or perhaps Scanners' (supplied by WOW Sight And Sound) and compete for the 'most prolific use of an acronym award' ??

[LeadSled]

Blackhand,
I just thought I would throw in a few more acronyms, just for fun, the aviation world is not the only one to have its own language, to confuse and exclude outsiders, and all too often ourselves.

Thread drift, but some time ago, a rather formidable chap was completing documents for an Australian Government tender, and he got to the bit about company policies, procedures, and methods of compliance for the Human Rights and Equal Opportunities Commission, HREOC, rules. (HR now rules in CASA)

He produced a wonderful page of bureaucrat speak, with all the right words, UN, HREOC, ISO, EEO, audit, executive management directly accountable, CEO the accountable manager, all staff subject to induction training, annual refresher, blah blah blah, all built around the "internationally recognised and very effective FIFO protocol for Human Resources Management.

At the session where the short listed tenderers were quizzed on their proposals, not one of the panel of bureaucrats queried FIFO, nobody wanted to admit they had no idea what FIFO was!

FIFO is Fit In of F---k Off , a well enough known HR management technique in business, if not by that acronym.

If you suffer from insomnia, try reading some of the HREOC stuff, it is far more effective than putting your hat on and picking up the Operations Manual, for instant sleep.

Tootle pip!!

[blackhand]

Leadsled
I had managed to decipher HREOC by a quick google search, must admit the FIFO had me trying to fit Fly In Fly Out into equal opportunity legislation. LOL, oops there another one.

Blackhand

[OzExpat]

From the posts that have been made since my last visit, it's clear that CASA hasn't the slightest idea about SMS. The first thing they should've done, which would've been of significant value as a learning tool, was to have rewritten all their own internal manuals with a basis in SMS. That way, they'd have started to understand many of the aspects that they don't currently understand.

Nobody is going to get an integrated SMS off the ground very quickly or easily, unless they've already had some first-hand experience of why it's necessary. However, there should be plenty of evidence in Australian GA of the benefits of SMS - from the mini-airline to the flying school and agricultural operator. There is certainly a great deal of evidence around the world to suggest that ATS providers, airport operators, refuellers, et al, will also see significant benefits in SMS as a way to save money by making the work as safe as can possibly be envisaged.

I believe there are some in CASA who understand the real concept but it seems that few of these are out in the field and that "the good word" is yet to filter down to the rank and file. SMS actually CAN and should be applied to CASA, as much as to the industry and the industry should be vocal enough to bring CASA to task for it.

Then - and only then - will there be a sensible approach to SMS because the CASA enforcement troops will understand that there's no such thing as a "one size fits all" solution. That might be a convenient way to package it for those who have never had to deal with it, but it won't lead to good SMS outcomes for anyone. Of course, it will be harder for CASA staff to evaluate SMS material that is provided in manuals produced by all types of certificate holders and CASA will have to start thinking outside the box.

The same is most certainly true of many other regulators around the world, who have rushed to embrace SMS by virtue of the ICAO-mandated requirement.

It really isn't rocket science, as other posters have agreed. In fact, there are many operators, large and small, who've had SMS in one form or another since well before it was mandated - indeed, well before there was even a formal name for it. The day-to-day safety practices are the important ones because they feed into every aspect of every operation and formalising into a document helps to ensure standardisation and consistency throughout a company, regardless of how often staff changes occur, or what staff are involved in the changes.

It is part of the SOPS, but is more than the SOPS. It's a living, breathing document that needs to change, from time to time, to reflect changing ways and means of operation. This applies as much to operators as to every other type of organisation that has any involvement in aviation. That means that it MUST apply equally to CASA and it's own staff.

SMS works through integration with every aspect of every task within every organisation. This is why it is more than SOPS and more even that the Rules that CASA as made to require the industry to adopt SMS. At the end of the day, no matter what line of work you're in, you want some sort of surety that you'll be home for dinner each night - or at the pub, or whatever you normally do after work.

There is as much scope for this within CASA as there is everywhere else - not just in the aviation industry either.

[flying-spike]

"This is because the costs they have to charge to cover the ridiculous ICAO-type paperwork and requirements which Australia seems to be copying means they cannot run a viable industry – in effect, they go broke and provide no service at all."

Neither of you have explained this statement. Just what onerous requirements have been put on "electronics shops" (next thing Dick will be talking about the wireless in his aircraft!). Dick, when you kicked off this scare fest you made this statement and you still have no evidence to support your argument. You trot out somebody you prodded for a response but still you have not supported your own argument. Where is the proof. Tell us what onerous requirement has been put on "electronics shops" and how is going to send them broke?

[Dick Smith]

Spike, you are correct and I am wrong. What would pete know about costs reducing the number of shops as he stated in posts 38 and 39 -he's only a maintenance shop owner.

And what would that dumb american jounalist know in the origional post.

And what would I know about business costs.

Keep increasing the paperwork and denying that safety regulation has to be affordable.

The big "cargo cult" from the sky will solve everything!

[flying-spike]

I have only asked you for proof to support the statement you opened the thread with. It is obvious to me now that you don't have the proof. Neither does Pacific Pete. Remember, I am talking about the thread you started. Yes excessive paperwork does make it harder for businesses.

You have exposed yourself Dick. Usually you do your research, or pay somebody to do it for you. This time you went off half-cocked Dick. Next time do the research. Don't just write the issue off because you don't like the messenger. You will lose even more credibility than you have already lost within professional aviation.

[Dick Smith]

I did my research, - there will be more of these organisations closing down as GA is destroyed.

Making it "harder for business" can and will close down a marginal business which many are.

You really have no idea about business!

[le Pingouin]

How long til "coward" and "traitor" get trotted out? :yuk:

[Dick Smith]

Only when there is evidence!

[fury]

SMS does not have to be an expensive tool. If you are comaring it to an ISO standard then you are barking up the wrong tree. The SMS should be proportional to the size of the organisation. I not trying to flog the CASA line but the CASA web site on SMS does a pretty good job of explaining the concept. How you implement it and how effective it is is up to the ceo.

[my oleo is extended]

I agree entirely with 'Fury' and 'Spike' here :ok:.

I am not a CASA advocate, but they actually have their 'ducks in a row' on the website. Quite obviously myself, Fury and Spike are persons who have a background in Safety Systems and understand it in the full context of costs, benefits and what is actually involved with an SMS. Those who bag it quite simply dont understand it, and those who think it will send industry broke not only dont understand it, but are naieve and out of their league to pass comment on it. I have personal experience with SMS within the Oil and Gas Industry, plus SMS also exists in onshore Petroleum and the Mining Industry, its actually been around for 'eons'.

Again, I respect every persons right to make comments, hey, thats what these forums are for, but the fact is that SMS creates a safer working environment, it creates a cost reduced environment for an operator due to the increases they gain in safety awareness, documentation, reporting, analysis and investigations which all lead to less incidents or accidents.

As for Dick, you may be a small business guru who has made a healthy living, and good for you, but equally, I am an SMS guru who has saved companies a hell of a lot of money by helping them to adopt, implement and effectively manage SMS in to their organisations framework.

I can assure all those operators who dont understand SMS or fear those three letters dont be afraid of the unknown, SMS works and will work for you !!

[flying-spike]

You are on the money my (tall?)Dutch friend. As the odds are against Dick on this thread with a bit of luck we have heard the last of him here.

[OzExpat]

I'd echo all of that! :ok:

[Dick Smith]

my oleo is extended, flying-spike and OzExpat

You don’t put your real names because possibly you are all on the gravy train for SMS. Great little earner, or should I say “great big earner”.

Can you explain how a DAMP (“drug and alcohol management plan”) costing about $20,000 can improve the viability of a small electronics servicing company at Bankstown Airport with about twenty staff?

The owners are not making any money and they have almost a monopoly in their field at Bankstown. The $20,000 a year will quite possibly put them out of business,


“So here we go with an SMS requirement that is going to cost considerably more than the DAMP"

Pacific Pete, the actual owner of a business that has been operating for over twenty years says:


“Dick's point about it being onerous is spot on for the GA MRO's. The gradual increase in regualtory burden has seen an gradual decrease in the amount of MRO's available"

DERR. Doesn’t this mean that some businesses are closing down?

I end by making this comment from Pacific Pete:

“In small organisations the ability to meet all of the criterior dreamed up by public servants who have too much time on their hands is costing Australia dearly by the loss of small business's that just cant cope”.

These are quotes from someone who is being affected. The fact that there were once twelve avionics shops at Bankstown and there are now only three is a fact. I wouldn’t be surprised when one day there isn’t one!

[le Pingouin]

Well that didn't take you long Dick. We'll add "smearing" to the list of obnoxiousness. Run out of arguments have we? Going down.

[OZBUSDRIVER]

Casual observation...wasn't this the reason Ansett got grounded? The CASA relying on a company to self audit?

[blackhand]

Can you explain how a DAMP (“drug and alcohol management plan”) costing about $20,000 The cost of $20K sounds high.

From a site online, for example of costs

The Aviation Industry DAMP Testing Kit * is a great way to get your DAMP started. The kit contains:

Product Value Sale Price
Aviation Industry Education and Awareness Training Free
Record of Training $5
25 x Sure Step Drug Test Cups ** $575
Drug Test Record Book (50 triplicate forms) $65 20 x Specimen Containers $25 Alcosense Precision Workplace Breathalyser *** $395
Alcosense Precision Mouthpieces (100) $60
Alcohol Testing Form $5 Total $1,150

Casual observation...wasn't this the reason Ansett got grounded? The CASA relying on a company to self audit? Is that true?
And how does this relate to SMS?

Cheers
Blackhand

[flying-spike]

May have been the cause, I don't know. But there is a difference between being left to your own devices and what CASA will be doing. From what I understand, an organisation's SMS will still be audited but against what they have had approved and hopefully what they say they are doing. Sounds reasonable.

I won't Dick tease anymore but I would point out that from what I have seen he he may be a voice in the wilderness on this issue. There appears to be a lot of support for better safety management but he is opposed to it, at least in the form of a contemporary SMS, shaped to an operators own requirements. Perhaps he could come up with a better model than ICAO's? Who knows? Probably more to the point who cares?

[my oleo is extended]

The vote is in and the verdict is unanimous - Dick Loses.
Its actually sad that Dick resorts to mud slinging about the possibility that myself, Spike and Expat are on the 'gravy train'. What a weak and shallow response. Spike`s question remains unanswered Dick, show us the proof, evidence and facts about your claims ? Dont just bleat and moan about some companies you know that are going to the wall due to SMS. Easy comments to make, but obviously too hard to back up with PROOF.

1)Dick Says :

You don’t put your real names because possibly you are all on the gravy train for SMS. Great little earner, or should I say “great big earner

My answer: Wrong. I cant speak for Spike or Expat, but as for me, no gravy train, no consultancy work here. My comments are based on expert experience within heavy industry and safety systems, its that simple.I have earned the right to make my accurate statements based on experience, whereas you shoot from the mouth and think you are the epitomy of knowledge and fact, when in reality you are speaking pure crap !
I am proud to make reference to the number of organisations I have assisted, made safer, made more profitable, and made more valuable overall. As for attaching names to my 'postings', why should I ? Have you forgotten its a free country and free speach remember ? I dont have a giant ego that needs feeding like you do, hence I dont feel or crave the urge to publicly dribble endless amounts of ****e in the paper, on tv, wherever I can, with my name and picture attached ! Thats your department and you do it very well I might add !
And as for your comments about gravy trains and money earners, well thats exactly what you are about Dick. Money, not safety. Sounds to me like sour grapes, I think perhaps the new legislation has seen you dig into your grubby little pocket and thats what hurts you the most? Not a surprising show of arrogance or an unexpected display of arrogance from you. Control freaks tend to dislike having to comply with other peoples rules, obviously this is another area of weakness within you.
Again, it seems that Dick is a little jealous that there is a chance that somebody is making a heap of money from a SMS, and perhaps you are envious that you didnt start flogging SMS instead of Mice many years ago ?

2) Dick says :

Can you explain how a DAMP (“drug and alcohol management plan”) costing about $20,000 can improve the viability of a small electronics servicing company at Bankstown Airport with about twenty staff?
My Answer : Paying 20k for DAMP won't improve the viability of the company you mentioned because they have been absolutely and utterly ripped off.This particular company has nobody to blame but themselves, nobody forced them to pay 20k. Again, Dick, if you were less emotional,rational and knowledgeable you would know that 'your friends' were ripped off. Quite simply, buyer beware !! A DAMP can cost less than 2k.

3) Dick says :

The owners are not making any money and they have almost a monopoly in their field at Bankstown. The $20,000 a year will quite possibly put them out of business,

My Answer: Sounds like they are more the victims of a disasterous global economy and poor business skills for shelling out 20k in the first place.Thats why they are in a hole. You say they have an almost monopoly in their area but yet are in financial peril due to SMS?? Typical response, people are always looking to blame others for their own mistakes.

Morale of this thread --- Dick, you know nothing about SMS.

[Dick Smith]

GOTCHA! You do make money from SMS!

The article I quoted in post 1 was actually not written by me. If SMS is effecting the viability of small maintenance companies in the USA we can only imagine what is happening here where the market is so much smaller.

I don't have to be an expert on SMS to understand what extra costs that do not increase income can do to a business.

Get your charges in quick!

Before even more go broke.

More " unafordable safety" is on the way!

[my oleo is extended]

Foolish Man.

If you think that working for a Mining Organisation or working for an Oil and Gas Organisation in a salaried safety role is 'making money from SMS' then you got me Dick !!
My friend, you are more stupid than you look on television.
You see, and for the benefit of those who dont understand safety(Dick), my experience I mentioned incorporated a host of safety requirements rolled into the one PD such as - SMS AND Compliance, Accident Investigations, Safety Implementation programs, Industry Advisery Boards and the list goes on.Yes,SMS was a component,I have no problems with that.Hell, I have even had the priveledge of leading investigations into workers that have been killed,afterall 'Investigations' is part of an SMS,but i am sure you think still that I was benefiting from this somehow. What a joyful task to perform, pity you werent there to share the moment with me.

As for your explanation -' it wasnt me who wrote the statement', who cares. You are a supporter of the statement simply by supporting it. Thats what you do best though, you copy or latch on to others comments or statements, you dont actually have a first hand knowledge or understanding personally. Jeez, what a surprise !

But I will say this - Aviation is the last 'heavy industry' basically, to adapt SMS. If through the implementation of SMS the airline industry in Australia becomes half as safe as oil,petroleum and mining,then its safer skies ahead.But of course Dick, you would no doubt think you know everything about safety in those industries as well wouldnt you ??
Either way, whether you are a fan of SMS or not, its here to stay. And no matter how loud you squeal Dick, you wont stop it !!!

Will we ever have an accident free industry regardless of what safety sytem is in play, of course not. Can we improve the system with SMS, you bet.

Now I suggest you get back to your little helicopter, cup of green tea and dry cruskets and leave the job of managing safety to the experts. I am sure you need to order some soldering irons or lightbulbs for your stores !!

[megle2]

Oleo - you have shot yourself in the foot by loosing your professionalism and slanging off at the man rather than staying on topic.
You are contributing nothing to the safety cause now.

I am familiar with all this.
The DAMP I fall under cost about $100 in materials. Casa supplied the template which you can change around to suit. The programe we have has passed its first official Casa audit.

The SMS I have been involved in cost about $200 in materials.
Once again there is a lot on offer free on the net with Casa and others.
The system has passed many audits over the past 8 years ( both Casa and outside auditors ). We are better for having the SMS.

Where the real cost to GA is the time consumed to put it all together.
It takes out key productive staff for an immense amount of time but still better than spending on a off the shelf manual.
And then continues to take considerable productive time from there on.

Much of this time is at the cost of running the business.
You can loose your productive edge and if your not carefull reduce the standards you have maintained in the past.

When you join together all the other Casa requirements / Casa FOI's personal opinions, other departmental red tape ect, QA, anti aviation airport landlords, equipment / parts escalations, security, user pays, staff training, old age, eventually it will get you. The young guys are not going take over, there too busy chasing the airlines / casa jobs ect and are not going to put up with all the frustration we go through.

So Dick is sort of correct, rather its for all these reasons not just the SMS.
Get your eye back on the ball guys and contribute to safety.

[trashie]

Dick,

I have been following this thread for some time and I am concerned at the total unwarranted alarm that you are attempting to create within the industry. In the first place, I have implemented a DAMP into a multi site 1000+ aviation organisation and to date it has cost me the time to draft a manual and under $1,500 in costs. I've told you a million times not to exaggerate!!

In regard to an SMS we are making it out to be a complicated all consuming distraction to the core aviation business. When in fact as many have stated one size does not fit all and the cost of implementation is relative to the size of the operation.

I admit that those businesses who go through the motions of implementing the documented requirements of an SMS and nothing more will be pouring good money after bad. But those organisations where the managers, chief pilots fully support the concept and walk the talk will find the costs are far out-weighed by the benefits that are achieved. I believe the safety gurus who espouse the theory that for an SMS to live it has to be supported throughout the organisation – top down and bottom up. It is the culture that drives a safety management system, and a great safety culture will provide reduced safety risks and greater efficiencies and operational effectiveness through employee engagement that far outweigh the financial and time costs of the SMS -not to mention the adverse costs involved in actually having an accident. How many Australian RPT/Charter operations that have had a fatal accident are still in business. Sorry Dick!!! I cannot hear you.

[OzExpat]

With just a tiny bit of research - which is a mere click or 2 of the mouse away - you'd find that I'm anything BUT anonymous within this forum. You think that you cut me to the quick, Dick, in mentioning me by my username.

Guess what... it hasn't worked - as all the other responses have proved. The only thing it has proved is that you can make irrational assumptions as a deflection tactic. Is this the REAL Dick Smith talking - the formerly professional businessman and high profile amateur aviator?

I feel no need to justify myself to you, of all people and I will not respond in kind to your pointed barb, simply because I prefer to act professionally. You continue to avoid the fundamental issue of proof of the things you espouse.

We have all provided you with proof that the system is workable, cheap, user-friendly and, above all, encourages and improves safety - the latter being the very goal that it was designed to achieve! What a surprise, eh?

[Dick Smith]

So what was Pacific Pete talking about?

Then again he actually owns a business in Australia that is being effected.

What would he know?

Keep shooting the messenger.

[OZBUSDRIVER]

Dick.....I have to ask.....did you get another huge bill for servicing your Caravan?

[trashie]

I hope Pacific Pete learns a lesson and gets three quotes in future. Anyone want a DAMP or SMS implemented, I am a starter if these are indicative of the the going rates

[blackhand]

Pacific Pete
One would assume that "Pacific Pete" is Pete F from Pacific Avionics at Bankstown Airport.
Their lists of clients is impressive, I dare say that their clients are the entities demanding SMS to enable third party audits, and perhaps is the reason that they are able to attract high end users.

From Pacific Avionics Website
Major clients include TV station ENG - Electronic News Gathering
Operators requiring video and voice intergrated services:
> Channel 2
> Channel 7
> Channel 9
> Channel 10
> ATN (Australian Traffic Network)
EMS operators requiring coordinated control
with emergency services/ambulance/RFS operators:
> SLSA - Surf Life-Saving (http://www.lifesaver.org.au/index2.html)
> Child-Flight (http://www.childflight.org.au/)
> Care-Flight (http://www.careflight.org/site/index.cfm)
> NPWS (National Parks & Wildlife Service) (http://www.nationalparks.nsw.gov.au/)
> State Forests (http://www.dpi.nsw.gov.au/)
> NSW Police Air-wing (http://www.policensw.com/info/gen/u6.html)
> Private operators under contract to RF

Alsame trashie, if you need a quote for SMS or DAMP for a small organisation I can do it for a lot less than $20K

Cheers
Blackhand

[flying-spike]

Pot this is Kettle, over. Pot this is kettle, over...........oh bugger! Radio is stuffed......Dodgy electronics shop....must have a bloody SMS!

Perhaps if they didn't have to have an SMS they wouldn't have to charge me so much to fix the wireless on my helicopter/caravan/whatever.
( I wonder if they will will take a warehouse full of fake Vegemite and Tim Tams as payment)..or maybe I could take one of my photos of me off the wall and give them that. ( I've got a few of those spare)

Surely that would pay for the new crystal set!

Can't wait for the next aircraft accident so I can get trotted out as an aviation expert. With this bloody SMS thing that could slow down things for me. I've got it! I'll sort out the airspace. That should boost things along!

[Cactusjack]

People People.May I be permitted to enter this little foray into SMS ??

1) Blackhand - Surely the details you quoted about Pacific Pete must be wrong ??? All those big name clients,yet poor Pete may go broke ??
My goodness,I didnt realize SMS could be so harsh,so evil,so deceptive !!! Blackhand,perhaps we could organise a 'spare parts drop' from an old Caravan or in this little rotary gem to help Pete out financially -----
http://www.tvtonight.com.au/wp-content/uploads/tonybonner1.jpg (http://www.tvtonight.com.au/2009/07/t-t-t-whats-up-skip-t-t-t-no-residuals.html)

Skippy:Tkt Tkt Tkt
Captain Jerry : Whats that Skip ? You want an SMS to ensure maximum safety ?
Skippy : Tkt tkt.... Tkt tkt tkt
Captain Jerry : I know Skip, its ok. Even without an SMS we can still do circuits of Lake Eyre. CASA have put some restrcitions and rules in place so that a 'Hudson River' wont happen out West. Dick has been in the ear of the new CASA CEO.You know how Dick gets, always complaining, always grandstanding, always bugging The Grand Poobah of the day at CASA.But The Screaming Skull has been ok, he is used to being surrounded by 'special people' !!
Dont panic skip, I have filled in my log book and our DAMP prgram has been approved. Its not as if I am flying an Embraer. Lets go look at some Pelicans !!
Skippy: Tkt Tkt
Captain Jerry : I dont know why Mark Hammond is fondling your furry back Skip,I think Mark is nervous about being wedged in a bubble with a Marsupial and another grown man wearing Eric Estrada sunglasses ! Dont panic, the Chopper is compliant, plus I bought my new Headset from Tandys Electronics, Sonny said they look 'neato', although Mr Hammond said that my shirt makes me look like a young Ritchie Benaud !

Blackhand, we could even drop ham radio parts,some Commodore 64`s and perhaps some Dick Smith Wafer Crackers and Dick Smith Canola Oil??(I am offering this free plug because Dick may need the money after he finishes paying for his own SMS and DAMP) - Both items taste great with a slice of SMS on the side !!
2) Oleo - Dick says he 'GOTCHA' ?? Please elaborate.Did he catch you out spinning some lies about SMS ? Did he 'GETCHA' by beating you at a game of 'Electronic Battleship',a game of 'Electronic Twister',or did he GETCHA to strip down your SMS and expose your deficient Hazard Indentification Reporting System and Safety Policy ??
3) Spike -Thanks to your last posting and mentioning Tim Tam`s and Dick in the same post,I can no longer eat them ! (Tim Tam`s that is). Thanks a bunch.
4)Trashie - I propose this. If it is true what Dick has pointed out, that gullible businesses befriended by unknowledgeable electronic shop poster boys are paying 20k for DAMP programs, then I am willing to charge half that, 10k, and split it with you ? Interested ? In fact, any other electronic fiirms out there willing to pay that kind of money please let me know, I am happy to assist you with any implementation plan!!
5) Finally, Dick - I have really only one comment for you: 'Have you considered updating the picture of yourself on your company logo ? The picture you use was sketched so so many decades ago, back when the world was simpler, safety didnt need an SMS, the word 'gay' meant to 'be happy', and Mice were the most sort after Pet !!!

FOOTNOTE: Did anybody know the following nugget of information ?
I found this 'word meaning'on Wikipedia. Wikipedia tends to distort a lot of facts and get things wrong ( a bit like a Dick that we know) -
DICK - A Democratic Indira Congress, Karunakaran (DICK) is a defunct political party in Kerala,India. DIC(K) was founded at a meeting in Thrissur by theK.Karunakuran faction of theIndian National Congress on May 1 , 2005. Initially it was called National Congress (Indira), but the name was changed DIC(K) for registration purposes in August of the same year.

[Dick Smith]

You all win- SMS (whatever it means) is fantastic. Just wish it was around when I was in electronics.

Woolies have removed the ******** from the logo a few months back- or didn't anyone notice?

I wanted it removed years ago!

[Dick Smith]

Incredible You can't put Dick and Head as one word on PPrune!

[megle2]

Dick- the edit function forms part of the Pprune SMS!
Makes the site safer against perceived naughty words / comments.
And installed for less than $20,000.

[flying-spike]

Dick's dummy spit:


"Incredible You can't put Dick and Head as one word on PPRuNe!"

Yet you can put Dick and Smith together........go figure?

Childish stuff from a self-made icon. Disappointing really when he sometimes had something to contribute.

[flying-spike]

"Woolies have removed the ******** from the logo a few months back- or didn't anyone notice"


Next thing will be a name change to Woolworths Electronics or similar. Even they have a sense of when a brand is fading.

[blackhand]

Flying Spike

Your vitriol is an embarrassment to your self and your profession.
Mr. Smith is a man held in high regard in Australia and further afield.

Your opinion now has no value at all.

Cheers
Blackhand

[Cactusjack]

Now now Dick, you are being naughty. I have adressed your comments as follows:



You all win- SMS (whatever it means) is fantastic. Just wish it was around when I was in electronics.


Yes, SMS was not really apreciated or as lovingly embraced as it is today, back when you owned your electronics stores, I totally agree. Had it been, you would be worth even more $$$$ than you currently are.
However,I am more than happy to consider a business venture between the two of us.I think your knowledge and business skills with electronics, combined with my knowledge and experience with SMS could pave the way for a new version of Dick Smith Electronics SMS Style ? A whole new beginning !! Worth considering my friend !


Woolies have removed the ******** from the logo a few months back- or didn't anyone notice?

No, I hadnt noticed. Is it a mistake ? A statement ? A lack of respect ? I prefer to shop at IGA however, it is a relaxed atmosphere there, with customers wearing plugga's and Iron maiden T-shirts flanked by a gravy and sauce stained flanalette shirt. I often feel like I am surrounded by passengers travelling to Darwin on an LCC, unbathed, no teeth and using strictly 'Kiwi Samsonites' as luggage !


I wanted it removed years ago!


Why ?? The logo is a symbol of 80`s prosperity, a time when the mullet was fashionable, Depeche Mode made great tunes and taxi fleets were strictly orange XD Falcons !!


Incredible You can't put Dick and Head as one word on PPrune!


Now that is ridiculous. I have seen the words Geoff and Dixon posted together, even John and Howard posted together, and I find them totally offensive.Go figure.
It is likely that prunes SMS has yet to be fully implemented, or perhaps an audit of its effectiveness is required ?

[flying-spike]

Vitriol?
vitriol
Noun
1. language expressing bitterness and hatred (definitely not bitter, why would I be,I have been vindicated and I would say hatred is a bit strong, possibly disdain would be more accurate)
2. sulphuric acid [Latin vitrum glass, referring to the glossy appearance of the sulphates]
Collins Essential English Dictionary (http://www.thefreedictionary.com/_/misc/HarperCollinsProducts.aspx?English) 2nd Edition 2006 © HarperCollins Publishers 2004, 2006

I believe informed contempt would be a better descriptive of my overall attitude toward Dick on this subject and his failure to provide evidence to support his initial inflammitory thread.

As to me my recent posts on this:

Firstly, just responding to Dick's failed attempt to use a derogitory term in response to one of my posts.

Secondly, what do you know of my profession?

Thirdly, No argument Dick is held in high regard both here and further afield. Righly or wrongly, so was Joseph Stalin (Australian Communtist Party).

NB I am by no means putting Dick in the same class, just illustrating the point that being held in high regard by some doesn't mean that everybody has to share your opinion.

The face of Dick? Obvious change brought about by Woolies management. Presumably they are rebranding their outlets ( hardware chain coming up soon)

As for the value of my opinion. People have paid good money for my opinion since I entered the industry over 30 years ago and continue to do so.

I suggest you read the preceding posts

[Frank Burden]

Thank you to everyone for providing such a fun read.

Really sorry to see the dick and head logo removed from electronic stores as it was approaching that status of an iconic marketing symbol and reminded me of the good times many years ago.

Keep it up everyone.:)

[blackhand]

Flying Spike
Your last post leads me to a Latin phrase -
Quad erat demonstratum.

You are indeed a vitriolic old man.
You exist only as a wisp of ether on the internet, neither real or actual, Mr. Smith on the other hand does exist,
Now off you go and play with your imaginary friends.:cool:

[le Pingouin]

Hmmm, another of Dick's cowardice brigade. You're as imaginary as those you condemn, nicely proclaiming your own irrelevancy.

QED

[OzExpat]

Errm, I know you won't excuse me for butting in, blackhand, but I'm going to do it anyway. I thought you were espousing very good SMS up until your latest post today.

We never EVER play the person - we only ever play the ball.

I don't believe for a moment that flying-spike is against the concept of SMS. If you read back in the posts on this topic, I'm sure you'll form an opinion as to where he/she is coming from. I think that the absolute best thing we can do, from Dick's perspective, is fight among ourselves when we all know that voices in the wilderness (such as Dick's) on this issue will fade away, if we ignore them for long enough. :ok:

[blackhand]

Ozexpat
I thought you were espousing very good SMS up until your latest post today.

Yea your right old mate, but I also have a lot of time for Mr. Smith and think it is very poor form to keep banging on like a silly old fart about him.

Are you back in mosbi yet?

Cheers
Blackhand

[blackhand]

Hmmm, another of Dick's cowardice brigade. You're as imaginary as those you condemn, nicely proclaiming your own irrelevancy.or to badly misquote Aristotle:
I blog, therefore I am
or
I SMS, therefore I can

Cheers
Blackhand

[RadioFlyer109]

Trashie:
"I have been following this thread for some time and I am concerned at the total unwarranted alarm that you are attempting to create within the industry. In the first place, I have implemented a DAMP into a multi site 1000+ aviation organisation and to date it has cost me the time to draft a manual and under $1,500 in costs. I've told you a million times not to exaggerate!!"


I'm impressed, only $1500 you say? This included your full day training course? Also the cost of training the 1000+ staff in DAMP awareness? . Or have you simply written a manual that sits on the shelf and stuck a poster in the lunchroom? Please factor in all the Costs then let me know what it REALLY costs for a 12 month period.

[OzExpat]

blackhand

Are you back in mosbi yet?
I'll be back Friday and should be back on deck on Monday.