Safety Management Systems 101
The importance of safety at an FBO cannot be understated. A lapse in safety can lead to expensive damage, injury or a loss of life.
To ensure safe practices are being carried out and regularly improved, many aviation companies and FBOs are adopting and implementing a safety management system (SMS).
“SMS is the formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of safety risk controls,” explain NATA COO Keith DeBerry and NATA managing director of safety and training Steve Berry. “It includes systematic procedures, practices and policies for the management of safety risk.”
An SMS offers a structured process designed to elevate safety to the highest concern, Berry and DeBerry note, adding a business must treat safety with the same attention as other business concerns.
An SMS actively looks for safety issues in daily operations and services offered, considers safety objectives and identifies top safety concerns, according to Terry Yeomans, director of the International Standard for Business Aircraft Handling (IS-BAH) program at the International Business Aviation Council (IBAC).
“It’s organized common sense,” he says, adding an SMS develops corrective actions to reduce the risks those safety concerns present and monitors them over time to be sure the risks have been appropriately controlled.
“In layman’s terms, the safety management system is basically a formalized way for the organization to recognize and reduce risk before an event occurs through measurement, evaluation, surveillance and continuous improvement,” say Baldwin Aviation – Safety and Compliance senior manager of standards Todd Thomas and Baldwin Aviation – Safety and Compliance director of standards Jason Starke. “The SMS framework establishes the policy, processes and procedures for people to work together to achieve this aim.”
Starting an SMS
When an organization is ready to implement an SMS, it is vital that everyone involved buys into the concept.
DeBerry and Berry recommend starting at the top, securing CEO buy-in first.
“Without support at the very highest levels of an organization, implementation of a successful SMS is very difficult,” they say.
Both recommend appointing a member of senior leadership to lead the development and implementation of the SMS. Yeomans refers to this person as the accountable executive (AE), adding that person’s commitment to safety culture will drive policy accordingly.
FBOs and ground service providers can also reference existing programs, say Thomas and Starke. For example, the framework for an SMS is included in the International Civil Aviation Organization’s (ICAO) international standards and recommended practices as part of Annex 19 to the Convention on International Civil Aviation. Title 14 of the Code of Federal Regulations (14 CFR) also highlights SMS.
“They can also use a standard such as IBAC IS-BAH or IATA Ground Operations Manual (IGOM) / IATA Safety Audit Ground Operations (ISAGO). If they use either of these, the ground handler can be recognized as meeting the IATA or IS-BAH standards,” they say. “If they use existing regulations such as ICAO Annex 19 or 14 CFR Part 5 for non-ground handlers, they can still create an effective SMS but will not have it recognized by the regulators for acceptance since there is not a current requirement to do so.”
In addition to acquiring leadership support, first steps for beginning an SMS include mapping and analyzing the existing organization; conducting a gap analysis; and preparing an implementation plan.
Thomas and Starke say this method takes the overall complexity of the task and divides it into smaller, more manageable subcomponents.
“The initial mapping and analysis start by describing and documenting your organizational structure, operational environment, and specific functions of each department,” they say.
“A gap analysis involves analyzing and assessing your existing programs, systems, processes and activities with respect to SMS requirements found in the regulations,” Thomas and Starke add.
While a company may use any technique to identify what needs to be done to implement an SMS, Thomas and Starke note completing a gap analysis will provide input for development of an implementation plan.
In addition to an AE or other management-level point of contact, other personnel may be required to assist with implementing an SMS. This varies depending on the size and complexity of an organization, but an SMS is scalable to accommodate any size business.
“The key aim is to make it effective without trying too hard,” says Yeomans.
Resource provision should be looked at from two sides, according to Thomas and Starke.
“First, there are the resources needed to maintain the SMS, such as administrative resources, supporting infrastructure, etc.,” they say. “Second, resources in terms of risk controls also need to be considered. Examples would be training, new equipment or programs that need to be provided to control identified risk.”
The time required to implement an SMS from the ground up can also vary depending on the size of the business. But according to DeBerry and Berry, the Federal Aviation Administration (FAA) has found that it takes about three years in many cases.
Requirements of SMS
There are four key components in an SMS. Commonly referred to as pillars, these components include safety policy and objectives, safety risk management, safety assurance and safety promotion.
“SMS should not be a separate system used on top of or next to other systems and business practices,” DeBerry and Berry advise. “SMS should be integrated into existing systems and practices.”
Within the four main components are 12 elements – each of which is required for effective SMS, Yeomans explains.
“Scalability does not mean you can eliminate any of the components or elements,” he adds.
Within the safety policy and objectives component, elements include management commitment; safety accountability and responsibilities; appointment of key safety personnel; coordination of emergency response planning; and SMS documentation.
The safety risk management component includes two elements – hazard identification as well as safety risk assessment and mitigation.
The three elements within the safety assurance component are safety performance monitoring and measurement; the management of change; and continuous improvement of the SMS.
Within the safety promotion component, elements include training and education as well as safety communication.
“The appeal of SMS is that the basic components and elements are universal,” say Thomas and Starke.
“Consideration should be given to alternative reporting sources including customers and workers who interface within your operational sphere,” DeBerry and Berry add.
While there are no specific requirements designed for an SMS at an FBO or ground handling company, Yeomans suggests concentrating on the FBO activities that the organization’s scope of services cover.
“As the SMS matures over time, you start to bring in the interfaces, such as the aerodromes you are based at and the aircraft operators you handle, constantly evolving and improving,” he says.
The Importance of SMS
An SMS is not just about safety, DeBerry and Berry say. It is equally about business process efficiency.
“The more efficient a business can become, the more successful it will be,” they say.
What’s more, Thomas and Starke note SMS is becoming a standard throughout the global aviation industry, adding it is recognized by the Joint Planning and Development Office (JPDO), ICAO and civil aviation authorities (CAA) as well as product/service providers as the next step in the evolution of safety in aviation.
By recognizing the organization's role in accident prevention, they say an SMS provides a structured means of safety risk management decision making; a means of demonstrating safety management capability before system failures occur; increased confidence in risk controls though structured safety assurance processes; an effective interface for knowledge sharing between regulator and certificate holder; and a safety promotion framework to support a sound safety culture.
“Also, we have to recognize that an SMS provides the tools to bring more insight into the organizational system,” Thomas and Starke continue. “Before, the system was a mystery until something happened. Through SMS, we are able to better understand the operating environment and the associated complexity. As such, through the insight we gain, we can proactively find ways to stave off harm and increase efficiency.”
There are a several locations around the world where authorities are taking the lead and introducing SMS for ground handling service providers, Yeomans says. In the European Union Aviation Safety Agency (EASA) region in Europe, he says work is progressing on the ground handing regulations and oversight. Within the next few years, the requirement of a management system including safety will be in force.
“Right now, the focus will come from the aerodromes and aircraft operators who, themselves are mandated to have an SMS,” Yeomans says. “As their SMS matures, they will be already starting to look at their suppliers and how these interfaces affect the safety of their own operations. FBOs may already be getting enquiries from Part 135 operations internationally about management of safety, if not they will soon.”
While an SMS offers value to a business, Yeomans points out that it has to be an initiative desired by the company, so that it can be approached positively and with the full commitment.
“Every organization has the choice to decide if now is the time to make the changes to improve the safety of their operations,” Yeomans says. “I would encourage anyone to talk to one of the current IS-BAH registered locations and see what differences they have seen since implementing the SMS.”
The Advantages of SMS
The specific benefits of an SMS may vary from one location to the next. But Yeomans says opportunities exist for everyone to evidence that safety is a core value; foster a better understanding of safety-related interfaces and relationships; evidence enhanced early detection of safety hazards; evidence enhanced safety communication; see a reduction in the direct cost of incidents, aircraft and GSE damage and lost time injuries; and evidence a reduction in indirect costs such as insurance, business reputation, etc.
Yeomans also advises businesses to challenge themselves.
“If you can make any changes to improve the safety of your operations what would they be?” he posits.
A fully functioning SMS fosters proactive and collaborative relationships that greatly enhance organizational management effectiveness, Thomas and Starke add.
“An SMS is essentially a quality management approach to controlling risk. It also provides the organizational framework to support a sound safety culture,” they say. “For general aviation operators, an SMS can form the core of the company’s safety efforts. For certificated operators such as airlines, air taxi operators, aviation training organizations and repair stations, the SMS can also serve as an efficient means of interfacing with FAA certificate oversight offices.
“The SMS provides the company’s management with a detailed roadmap for monitoring safety-related processes and can increase productivity.”
For an organization interested in developing and implementing an SMS, DeBerry and Berry urge industry members to obtain formal training for an implementation team.
“Creating a safe work environment is a goal across all industries and implementing a safety management system is an important step in fostering a culture of workplace safety,” they say. “Adopting a safety management system can not only reduce injuries and manage industry legal requirements, but also cut safety-related costs and improve organizational performance.”
