Knowing what a safety management system (SMS) is does not equate to implementing one. It is an endeavor that takes time, effort, and money. However, it produces a return on investment that can be measured directly and indirectly. These measures of success of the SMS will be discussed later. First we need to know what needs to be considered for a successful implementation.
There is no “one-size-fits-all” when it comes to the implementation of a SMS. Each organization has its own vision, culture, customers, financial constraints, etc., which will influence the way in which they go about developing and implementing the four required mainstays of the SMS. These four “pillars,” as noted in the FAA Advisory Circular No 120-92A are: safety policy, safety risk management, safety assurance, and safety promotion.
The FAA will eventually be providing mandated SMS guidelines for different sections of the industry once having a SMS becomes a rule.
Structure of the toolbox
The most effective way to approach the implementation of a SMS is through a phased approach. A phased approach to a successful SMS allows the operator to plan, develop, prepare their employees for, implement, and conduct appropriate evaluation of the SMS in practical consecutive steps. It also allows for any required adjustments to be made to the process with the minimal possible impact upon resources. This then assists in terms of improved financial management of the process.
The phases of implementing a SMS need to be well documented and clearly understood by those who will be implementing the different phase activities. Even if you are not responsible for the direct implementation of the specific SMS phase, you should be aware of what the implementation process encompasses to ensure you know your part in the process. To better understand the “tools” or activities and steps involved in the different phases of the implementation of a SMS, a phase guide is set out below.
Phase 1
1. Identification of the following:
a. The accountable executive
b. The person (or possibly group) responsible for implementing the SMS
c. Manager safety accountabilities; what managers are responsible for
2. Describe and document the system.
a. SMS components - general and/or specific to divisions
b. Ensure employees are aware of these descriptions
3. Conduct a gap analysis.
a. Obtain an organizational baseline. Include a safety culture survey/assessment
b. Determine how the organization will measure the success of the SMS
4. Develop an SMS implementation plan.
a. Document how is it to be rolled out and the accountable person(s)
b. Develop a realistic timeframe for the overall rollout plan
c. Consider the human resource needs and financial implications of each phase
5. Develop documentation relevant to the company’s safety policies and objectives.
a. What currently exists and what is still needed (e.g., discipline policy, definition of terms, investigation policy, etc.)?
6. Develop and establish ongoing means for safety communication.
NOTE: This step is often overlooked or underestimated and the complete SMS can suffer due to poorly developed - or nonexistent - communication channels.
7. Determine and formalize divisional interfaces to share safety information and learn from experiences.
8. Determine how all the SMS data is to be collected and dealt with.
9. Commence development of safety performance indicators and performance targets. Determine how the SMS will be evaluated, both in terms of process evaluation as well as outcome evaluation.
a. The process of implementation should be continuously evaluated to ensure it is being implemented as planned.
b. Outcome evaluation is the customary evaluation of a program – is it reaching the targets or goals we wanted it to?
Phase 2
1. Implementation of reactive risk management processes.
a. Document (and follow) event investigation processes conducted by formally trained personnel
2. Deliver training relevant to reactive risk management processes.
a. Make all personnel aware of the processes, their own responsibilities, and how these reactive processes work together
3. Document all aspects relevant to reactive risk management tools for trend analysis.
4. Develop formal communication to personnel of findings from reactive safety events.
5. Determine SMS software needs/packages available as well as current and future company needs.
Phase 3
Implementation of proactive and predictive risk management processes such as a confidential/anonymous safety reporting system, hazard identification and tracking system with feedback mechanism, FOQA, regularly scheduled systemic safety audits, and task analyses for all safety-related activities.
1. Set up a risk-management working group to assess acceptable levels of risk.
2. Define the risk assessment tools and risk control mechanisms that will be used when an unacceptable level of risk has been identified.
3. Deliver training on these proactive and predictive safety management processes.
4. Provide formal communication to personnel concerning these proactive and predictive tools including why they are beneficial to all employees.
5. Coordinate and maintain reactive safety data synthesized with proactive and predictive safety data (when this becomes available) from combined analyses tools.
Phase 4
1. Refine the safety performance indicators and performance targets commenced in Phase 1 (Part 9).
2. Develop SMS continuous improvement initiatives.
3. Develop training and documentation relevant to operational safety assurance.
4. Maintain and upgrade as needed the processes put in place for safety communication.
Tools for the toolbox
In implementing a SMS there are many areas within our own organization where we can (and probably will) make mistakes. It may be the right toolbox, but we may not have the right tools or we may not be using them correctly. It helps to have external evaluations conducted to ensure we are not biased in what we see, or fail to see, within our own confines. However, the SMS implementation process needs to be owned by each individual in the organization to ensure its success and sustainability.
To achieve this, each of us can personally have an impact on the SMS implementation process by considering the following:
1. Be aware of what is expected of us - and others - in the new system.
2. Make a conscious effort to educate ourselves about the changes.
3. Don’t be afraid to ask if you don’t understand why you are making the changes.
4. Be prepared to provide constructive feedback on the changes.
5. Try to fight the normal human urge to resist change.
6. The human can be both the strongest tool - as well as the weakest tool - in our toolbox.
7. It is up to you as to what influence you will have on the success of the SMS.
8. This is about making our industry safer and therefore more financially viable.
9. We all win if the SMS is successful.
We need to constantly remind people what is in it for them. It is human nature to for us to ask ourselves this question when confronted with a change in our environment. If we fail to let our people know what is in it for them, they are much less likely to support the initiative.
So we have a toolbox, and we now know the basic structure of the toolbox, and have a few tools that may need to go in that toolbox. Keep in mind, not all tools are needed in all toolboxes, and we may change the look of some of our tools to do the work we want it to do in our organization. However, we must use the tools in the toolbox for this to work. Managing our personnel as individuals, many with a normal fear of change, is the best tool for success in this process. As noted by the title, a SMS is a toolbox, but it is only as good as the tools we have in it, and how those tools are used and maintained.
Ready to throw the tools out with the toolbox yet?
This process may seem a little daunting initially, but many organizations are already actively using parts of a SMS – but maybe not in a systemic, cohesive manner. No matter how many tools you have in use now, remember – it will be a change, it will be somewhat uncomfortable, and it will not happen overnight. But we should not be afraid to embrace this new system as it is about keeping our industry - and each of us - safer.
Majella McDonald is a human factors expert with over 20 years of professional experience in the aviation and health industries. Her areas of expertise include safety management systems (SMS), human factors, accident investigation, instruction, and change management planning and implementation. She currently works as a consultant for Baines Simmons Americas and teaches for Embry-Riddle Aeronautical University (ERAU).
