SMS Friend of Foe?.
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SMS Friend of Foe?.
This follows on from some very interesting recent discussions related to Safety Management Systems (SMS); thought I'd throw it out here (to the esteemed members) in the forum to see the response.
No one denies, that in theory SMS is a must have tool and in principal should work just fine.
The question is, can it be truly seen as open, honest, just, confidential and not subject to either external or internal 'abuse' ??. (Abuse being manipulation, strangulation, obfuscation, expediency, mendacity; etc).
Honest question.
Selah.
No one denies, that in theory SMS is a must have tool and in principal should work just fine.
The question is, can it be truly seen as open, honest, just, confidential and not subject to either external or internal 'abuse' ??. (Abuse being manipulation, strangulation, obfuscation, expediency, mendacity; etc).
Honest question.
Selah.
It really depends on the quality of the management. They have to believe that SMS is a key component of the business. It also needs to have a genuine Safety Department (even if it's just one person initially) that has the respect of the crew and the management.
Without that it's all just lip service to appease the regulator. And the regulator must still remain involved and engaged. The implementation in Canada has ironically been quite a failure for the non Part 121 crowd. They essentially used it to help deal with a significant manpower shortage in Transport Canada and really dropped the ball so to speak.
I'm a little bit out of touch with the implementation of SMS in New Zealand and Australia. How far down the ranks has it stretched? Do operators like Sun Air, Helipro, Sling Air etc run full-blown SMS?
Without that it's all just lip service to appease the regulator. And the regulator must still remain involved and engaged. The implementation in Canada has ironically been quite a failure for the non Part 121 crowd. They essentially used it to help deal with a significant manpower shortage in Transport Canada and really dropped the ball so to speak.
I'm a little bit out of touch with the implementation of SMS in New Zealand and Australia. How far down the ranks has it stretched? Do operators like Sun Air, Helipro, Sling Air etc run full-blown SMS?
Excellent question K! One that was briefly touched on here:
financial management.
Link: http://www.pprune.org/dg-p-general-a...usiness-2.html
The article in the Flight Safety mag was actually quite good...surprise, surprise!
Like all good ideas there is always a minority that see a way to exploit or abuse a system/law/rules to their own gain. In the case of SMS I have seen both the good and the bad. I feel that a SMS is only as good as the 'culture' within a company.
If an operator is honest, upfront and embraces their employees as their key assets to the business, then the foundations of a good SMS are layed. A good manager will use the SMS to promote the business and actively seek input and ideas to improve the SMS.
Unfortunately a bad operator will only see the SMS as a means of showing compliance to the regulator i.e. "we've got this in place so we must be compliant"!
This says it all I think (from above):
Cheers
Using parts of an SMS without tailoring them to your
own organisation or circumstances is contrary to the
central idea of SMS. Such a box-ticking exercise would
be both dangerous (thinking you are being safe when
you are not) and a waste of time, he says.
Box-ticking is in many ways the opposite of safety
culture. Just as with 'culture', there is no exact definition
of 'safety culture', but a 2006 ICAO document makes
a good stab when it refers to a good safety culture as
a corporate safety culture that fosters safe practices,
encourages safety communications and actively
manages safety with the same attention to results as
own organisation or circumstances is contrary to the
central idea of SMS. Such a box-ticking exercise would
be both dangerous (thinking you are being safe when
you are not) and a waste of time, he says.
Box-ticking is in many ways the opposite of safety
culture. Just as with 'culture', there is no exact definition
of 'safety culture', but a 2006 ICAO document makes
a good stab when it refers to a good safety culture as
a corporate safety culture that fosters safe practices,
encourages safety communications and actively
manages safety with the same attention to results as
financial management.
The article in the Flight Safety mag was actually quite good...surprise, surprise!
Like all good ideas there is always a minority that see a way to exploit or abuse a system/law/rules to their own gain. In the case of SMS I have seen both the good and the bad. I feel that a SMS is only as good as the 'culture' within a company.
If an operator is honest, upfront and embraces their employees as their key assets to the business, then the foundations of a good SMS are layed. A good manager will use the SMS to promote the business and actively seek input and ideas to improve the SMS.
Unfortunately a bad operator will only see the SMS as a means of showing compliance to the regulator i.e. "we've got this in place so we must be compliant"!
This says it all I think (from above):
Such a box-ticking exercise would be both dangerous (thinking you are being safe when you are not) and a waste of time, he says.
Box-ticking is in many ways the opposite of safety
culture.
Box-ticking is in many ways the opposite of safety
culture.
Bottums Up
Such a box-ticking exercise would
be both dangerous (thinking you are being safe when
you are not) and a waste of time, he says.
be both dangerous (thinking you are being safe when
you are not) and a waste of time, he says.
Safety begins the minute you sign on for duty or walk in the crew room door. Disengage the staff (as we have seen a lot of late & safety (apart from self preservation) can get effected.
Like most things in life someone comes up with a new 'in word', SMS is just another one of those. We are ALL responsible for safety in everything we do in life that involves risk & I see little point in reinventing the wheel just to make us all feel warm & fuzzy as well as appeasing the regulators!
The only good part I can see about the SMS is that it entails a dedicated person or persons for the role.
Wmk2
Like most things in life someone comes up with a new 'in word', SMS is just another one of those. We are ALL responsible for safety in everything we do in life that involves risk & I see little point in reinventing the wheel just to make us all feel warm & fuzzy as well as appeasing the regulators!
The only good part I can see about the SMS is that it entails a dedicated person or persons for the role.
Wmk2
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SMS is being forced up on the various aviation orgs as well. Warbirds SAAA RAA (i think) and I must say when the systems are made for airline charter or AOC type groups that works fine but when it is an association of private individuals, it is a waste of resources.
The orgs are getting lumbered with something that meets certain criteria set down from CASA but does not really do anything at the coal face. Pro Active education materials and campaigns are far more effective.
As an example the Human Factors course RAA did a few years back, and new folk have to pass now, is a good thing. Boring topic maybe but a good thing to do. Trying to impliment an SMS and reporting program like IRIS is in my opinion doomed to fail.
Integrated Risk Information System | IRIS (Integrated Risk Information System)
The orgs are getting lumbered with something that meets certain criteria set down from CASA but does not really do anything at the coal face. Pro Active education materials and campaigns are far more effective.
As an example the Human Factors course RAA did a few years back, and new folk have to pass now, is a good thing. Boring topic maybe but a good thing to do. Trying to impliment an SMS and reporting program like IRIS is in my opinion doomed to fail.
Integrated Risk Information System | IRIS (Integrated Risk Information System)
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SMS provided regulatory jaunts!
SMS will benefit an individual organisation. It may be a new concept to aviation but it has worked in the oil and mining industries for years.
The catch is this - It puts more of an onus back on the airline or operator. I have no problem with that. However, SMS is a tool that the government supports as it can be used against you as it distances the government or regulator and minimises any fallout or any apportioned responsibilty or accountabilty if anything goes tits up, like a smoking hole! That is one sad reality. You can be assured that CASA has embraced SMS and pushed it along not because they think it is a great safety initiative, because as we all know the regulator is in place to protect the government and minister of the day, not to protect industry or passenger. If SMS helps distance the regulator from accountabilty they implement it ASAP. Infact it only took them around 2 years to implemet SMS, compared to 23 yeras and counting for reg reform!!
On a positive note (for some) SMS has in the past few years opened up the opportunity for them to employ a number of 'consultants' including former staff and mates. One earned over $500,000 in 2009/2010 alone just from CASA. And then you have all the CASA staff tripping overseas, off to Montreal etc, so SMS adds an extra layer of depth to the trough for those savvy enough to see the potential. Oh yes, here piggy piggy piggy. Oink oink.
The catch is this - It puts more of an onus back on the airline or operator. I have no problem with that. However, SMS is a tool that the government supports as it can be used against you as it distances the government or regulator and minimises any fallout or any apportioned responsibilty or accountabilty if anything goes tits up, like a smoking hole! That is one sad reality. You can be assured that CASA has embraced SMS and pushed it along not because they think it is a great safety initiative, because as we all know the regulator is in place to protect the government and minister of the day, not to protect industry or passenger. If SMS helps distance the regulator from accountabilty they implement it ASAP. Infact it only took them around 2 years to implemet SMS, compared to 23 yeras and counting for reg reform!!
On a positive note (for some) SMS has in the past few years opened up the opportunity for them to employ a number of 'consultants' including former staff and mates. One earned over $500,000 in 2009/2010 alone just from CASA. And then you have all the CASA staff tripping overseas, off to Montreal etc, so SMS adds an extra layer of depth to the trough for those savvy enough to see the potential. Oh yes, here piggy piggy piggy. Oink oink.
Last edited by gobbledock; 20th Jan 2012 at 00:07. Reason: Having a philosophical debate with myself
gobbledock wrote:
.......and there lies the problem with the SMS, by putting the onus back on the operator to implement and maintain (if you like self regulate) the only thing the regulator checks is if all the right boxes are ticked!
"Who cares if the SMS isn't actually doing its job...we've done ours!" Click, end of audit." Now where was that latest edition of the piggy digest...."
If SMS helps distance the regulator from accountabilty they implement it ASAP
"Who cares if the SMS isn't actually doing its job...we've done ours!" Click, end of audit." Now where was that latest edition of the piggy digest...."
You can be assured that CASA has embraced SMS and pushed it along not because they think it is a great safety initiative, because as we all know the regulator is in place to protect the government and minister of the day, not to protect industry or passenger.
They increase the amount of regulation and cost whilst simultaneously removing their amount of legal liability and responsibility and ultimately shrinking the industry.
"Who cares if the SMS isn't actually doing its job...we've done ours!" Click, end of audit." Now where was that latest edition of the piggy digest...."
This approach to regulation of SMS was taken by Canada and now forms a pretty well known case of what not to do with SMS. Properly implemented SMS is not full self regulation.
Yes organizations are given the flexibility to conduct their operations in the manner they see fit however this is contingent on proper risk management processes.
The regulators responsibility should be to ensure that risk management processes are being carried out correctly.
Correctly done the SMS should be easy to regulate as each stage has obvious outcomes:
EG: Not many reports generated for company size = faulty reporting system.
No action on reports = lack of commitment from management
SMS is not something new and fancy it has been operating in the mining, rail shipping and nuclear power industries for years.
This approach to regulation of SMS was taken by Canada and now forms a pretty well known case of what not to do with SMS. Properly implemented SMS is not full self regulation.
Yes organizations are given the flexibility to conduct their operations in the manner they see fit however this is contingent on proper risk management processes.
The regulators responsibility should be to ensure that risk management processes are being carried out correctly.
Correctly done the SMS should be easy to regulate as each stage has obvious outcomes:
EG: Not many reports generated for company size = faulty reporting system.
No action on reports = lack of commitment from management
SMS is not something new and fancy it has been operating in the mining, rail shipping and nuclear power industries for years.
You only need to cherry pick some of the Senate Hansard for the Rural Affairs and Transport Committee's recent inquirys (current and completed) to signs of a SMS being abused/embraced.
This from a current inquiry (no guesses to which one):
Whether these statements/facts were true or not is irrelevant. What is true is the perception of the employees on how ineffective the reporting system is.
I also know of crew that have been given letters of warning (first black letter) for submitting company incident reports. An example was where a FO tried to start an APU with the engine bung in, the FO submitted an incident report and was subsequently reprimanded and sent a 'black letter'. There was no serious damage done to the APU and the FO was told by the engineers: " Don't worry about it, it happens all the time!".
This attitude can only instil a culture of non-reporting within an organisation.
Progressive quite rightly points out:
However SMS may have been around for "donkeys years", but a SMS is only as good as the management controlling and promoting it.
This from a current inquiry (no guesses to which one):
Mr Kelly: We have raised it through the reporting system called OSCAR. For five years we have reported fatigue as an issue with the Bali returns. The message that we received from the company was 'Just keep the OSCARs coming.'
Ms Neeteson-Lemkes: If I may elaborate on the OSCAR system within J******. You write an OSCAR, whether you submit it electronically or hand write it, and you send it off to the department. What you receive is a generated or an automated email, saying, 'Thank you very much for your OSCAR.' It ends there; there is no action. We have been waiting for action at domestic for about 3½ years now. OSCARS are unanswered and they remain unanswered.
Ms Neeteson-Lemkes: If I may elaborate on the OSCAR system within J******. You write an OSCAR, whether you submit it electronically or hand write it, and you send it off to the department. What you receive is a generated or an automated email, saying, 'Thank you very much for your OSCAR.' It ends there; there is no action. We have been waiting for action at domestic for about 3½ years now. OSCARS are unanswered and they remain unanswered.
I also know of crew that have been given letters of warning (first black letter) for submitting company incident reports. An example was where a FO tried to start an APU with the engine bung in, the FO submitted an incident report and was subsequently reprimanded and sent a 'black letter'. There was no serious damage done to the APU and the FO was told by the engineers: " Don't worry about it, it happens all the time!".
This attitude can only instil a culture of non-reporting within an organisation.
Progressive quite rightly points out:
SMS is not something new and fancy it has been operating in the mining, rail shipping and nuclear power industries for years.
Last edited by Sarcs; 20th Jan 2012 at 20:43.
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I think each organisation was supposed to create their OWN SMS that is tailored to suit their particular operations. If this is done properly, there is no reason why the SMS will not work unless the organisation itself does not operate the SMS correctly.
If your SMS is not working correctly, it is not the regulator's fault. The regulator is there to make sure the SMS is in place, not to operate it for you.
If your SMS is not working correctly, it is not the regulator's fault. The regulator is there to make sure the SMS is in place, not to operate it for you.
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If your SMS is not working correctly, it is not the regulator's fault. The regulator is there to make sure the SMS is in place and ensure SMS is effective, not to operate it for you.
The case of J******'s OSCARS program suggests that they do not have SMS properly established. One of the key component's of SMS is the feedback loop to staff (company mag with selected reports and remedies and individual information back to reporters in a an organization this size).
If the regulators do the job correctly they should pick up on this.
I think one of the key hurdles to implementing SMS is in changing the culture from one of
"the regulator is here to tell me what to do and how to do it - and I am there to do the minimum possible to meet this" to
"it is my job to manage the safety risks in my company just as I manage the financial risk and the regulator is there to monitor my management of risk and suggest improvements"
This change in culture must take place in both operators and CASA and so there are bound to be teething problems.
Someone once said to me "Safety management is only good when it becomes as much part of a company's policy as cash flow management"
If the regulators do the job correctly they should pick up on this.
I think one of the key hurdles to implementing SMS is in changing the culture from one of
"the regulator is here to tell me what to do and how to do it - and I am there to do the minimum possible to meet this" to
"it is my job to manage the safety risks in my company just as I manage the financial risk and the regulator is there to monitor my management of risk and suggest improvements"
This change in culture must take place in both operators and CASA and so there are bound to be teething problems.
Someone once said to me "Safety management is only good when it becomes as much part of a company's policy as cash flow management"
If your SMS is not working correctly, it is not the regulator's fault. The regulator is there to make sure the SMS is in place, not to operate it for you.
The issue is the dodgy operator who uses the SMS to their own gain. Then each year when the annual CASA AOC audit comes up all the boxes are properly ticked and "yes the SMS is wonderful" and "works really well!"
The CASA FOIs and AWIs conducting the audit are none the wiser because all areas of compliance seem to be covered. But really the SMS has become a smokescreen to what is really going on.
The bureaucrats back in Canberra don't care because all the 'boxes are ticked', hence 'our area of responsibility and liability' is covered!'
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Geez, I hope our "bureaucrats back in Canberra' do really care, because if they do not, then the whole point of regulating for SMS is a waste of time. Admittedly, there are operators out there who think they can get by just by doing enough to 'tick the boxes'. If that is enough to satisfy the regulator, then we are all stuffed.
In an ideal situation, the regulator should be changing hats (from regulator to educator) and trying to help, educate, or assist, the operator to implement a SMS that works. I thought the whole point of introducing a SMS into an operation was to make it safer (and more profitable) and that would have benefits to the operator and other users of the same airspace?
Anyone who thinks that all they need to do is 'tick boxes' is fooling themselves and letting everyone else down. Does anyone think that making the effort to design and implement a proper SMS is a waste of time? If the SMS ticks the boxes and something still goes wrong; is it the regulator or the operator, who comes off second best?
In an ideal situation, the regulator should be changing hats (from regulator to educator) and trying to help, educate, or assist, the operator to implement a SMS that works. I thought the whole point of introducing a SMS into an operation was to make it safer (and more profitable) and that would have benefits to the operator and other users of the same airspace?
Anyone who thinks that all they need to do is 'tick boxes' is fooling themselves and letting everyone else down. Does anyone think that making the effort to design and implement a proper SMS is a waste of time? If the SMS ticks the boxes and something still goes wrong; is it the regulator or the operator, who comes off second best?
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Don't worry
The CASA FOIs and AWIs conducting the audit are none the wiser because all areas of compliance seem to be covered. But really the SMS has become a smokescreen to what is really going on
"But, but it's a no smoking zone". "No worries son, we will just invent some stuff or better yet; 'borrow' some from this little book here (shows copy of SMS reports).
In an ideal situation, the regulator should be changing hats (from regulator to educator) and trying to help, educate, or assist, the operator to implement a SMS that works. I thought the whole point of introducing a SMS into an operation was to make it safer (and more profitable) and that would have benefits to the operator and other users of the same airspace?
At least there will now be help for the front line as they merrily use sacred REPCON and SMS information to pursue their elusive quarry through the legal mires.
May the force be with you.
Last edited by Kharon; 22nd Jan 2012 at 19:36. Reason: When words fail - use a smiley.
