Most people may be able to imagine how an SMS might
work at a large airline or repair station. They probably
have lots of people, lots of money and most have
InformationTechnology Departments but just how does the
FAA expect a small operator with very few people, may
be surviving month to month and with no computer
network to function in an SMS environment?
Before we start our example, let’s take a look at how a
previous FAA Administrator feels about small operators
and an SMS. In a speech at the Shared Vision Conference,
the Administrated stated that there are those who feel
they are too small or do not have time or mones for SMS.
He disagrees with those sentiments by pointing out that
“no one and no company is too small for SMS”. He further
stated that “Saying that you don’t have time for SMS is
the functional equivalent of saying that you don’t have
time for safety”. This seems to be a fairly clear message.
There are many different ways to implement an SMS.
This presentation shows only one method of how an SMS
might work at a small aviation service provider.
The focus is on the key elements of an SMS, Safety Risk
Management and Safety Assurance. Safety Policy and
Safety Promotion will be discussed near the end of the
presentation. This presentation is NOT the only SMS
method available to aviation service providers.
But should provide you with some ideas.
Lets Look at an example: Alpine Air, is a fictitious
Company, however as you will see the application of SMS
at an Alpine Air sized organization is simple enough as
long as you understand the SRM & SA processes.
Two important points; first is that knowledge of the SRM
and SA processes is what is important – how you document
your SRM and SA is not as critical. This presentation
purposely discusses the need to understand SRM and SA
and illustrates documentation using only hard copy paper
tools. Secondly, remember that there is nothing new in
SRM and SA, it is what you have been doing all your
aviation career; identifying hazards, analyzing risk,
mitigating risk and following up what is new is
organizing what you have been doing for years into a
management system called SMS.
Let’s say that you own a small helicopter operation in
Southern California. Alpine Air, You’re based at
Montgomery Field, San Diego, and have the assets shown
on the screen. You have a functioning SMS. So let’s see
how it works.
One day one of your pilots walks into your office and
says: “Boss, I was flying over Alpine just now and I saw
a new power line across Harbison Canyon. The worst part
is there are no visibility markers on the new line.”
So, what has just happened? You have just started your
SRM process. What can you say about your SMS so far?
You have an effective employee reporting
& feedback system.
Let’s track our example through the SRM and
SA models. Where are you in the SRM process?
That’s right, you are describing the system where
the hazard resides. What’s next?
You need to identify the hazard – what’s wrong?
You ask the questions who, what, when, where and so forth.
Before you forget, you open your simple SRM notebook
and write: System – Operational flying area.
Hazard – Unmarked power line in Harbison Canyon.
Now it is time to analyze the risk this hazard posses. 63 00:04:45,000 --> 00:04:48,000. You need some additional information, some data.
You call the Electric Company and you ask
“How big is this new line?” “½ inch” they reply.
“When will you get visibility markers installed?”
There is silence on the other end of the phone. You call
the FSDO and ask “Are you aware of the new power line?”
“Yes” they say. “Can you do something about
visibility markers?” Again “Yes, but it will take time”.
You are still collecting data at this point.You find the
operators manual for the wire cutters and find the maximum
demonstrated cutting capacity is .419 inch…that is bad!
You think about what happens when a helicopter and power
line interact….that is really bad!
You already know how often you fly around Harbison Canyon
a thats alot! So, what is your severity and likelihood for
this hazard?
Now it is time for risk assessment is the risk acceptable
or unacceptable? Looking at your data this is pretty simple
your risk is unacceptable.
How much time have you invested so far in this SRM process?
5 minutes…10 minutes?
Have you done anything you have never done before?
Something New?
Now that you have assessed your risk…and found it
unacceptable, what can you do to mitigate your risk?
The most obvious is putting mission restrictions on
flights in or near Harbison Canyon, especially during
times of low visibility. You can mark the location of
the new power line on the big area map on the wall of
your lobby to remind everyone. What else can you do?
How about putting reminders everywhere you can think of.
Okay, time to bring your documentation up to date. This is
a summarized version what you might have written so far.
With your authoring duties complete, are you finished with
safety risk management process? Not yet, you need to
consider residual and substitute risk; in other words
“is there any risk left over after you apply your controls”
or “have you introduced a new hazard while applying your
controls”. Is the cure worse than the disease?
This can be, and frequently is done while you are
developing your controls in the first place, so just be
aware that you have considered this residual or
substitute risk? So how did you or do you consider
residual and substitute risk? You can talk to your employees
brain storm with them or even populate your calendar
with notes to yourself.
Now are you finished with SRM? Yes so what’s next?
Lets take a look.
You take out your SA notebook and write about
the risk and associated controls.
Now that you have defined your risk it's time to put your
controls in place, to make them operational. What is next?
The next step is to consider how you will assure your
controls worked and continue to be effective.
How do you do that? You have many options, so let’s look
at some of them. Your SMS will help you to consider which
method might be most effective.
You can chose more than one.
Using your background and experience, you decide that
Continuous Monitoring checking the status of the power
line by overflying the canyon during good visibility
missions and becoming a squeaky wheel at the power company
and Internal Audits fit your needs best.
Now that you have made your monitoring decision, break
out the pen and paper and document it.
Okay, you know what you want to do, but exactly how are
you going to do this monitoring and data acquisition?
Overflying the canyon and looking at the power line from
a safe distance is simple enough, how about this fancy
term “data acquisition”? Data acquisition is simply the
information you gather each day while operating your
business. It include mission orders, flight plans, fueling
reports, maintenance reports, safety notices and all the
other bits of data that makeup normal business processes.
Now that we have aquired this data let's analysis it.
Every month, you pay the bills and review the financial,
maintenance, operational and human resource aspects of
your company. Since you have an SMS, you also review your
safety status at the same time. It has become second
nature to thumb through mission sheets, maintenance logs,
account balances and the SRM and SA notebooks.
You look for things that are out of place or dangerous
or trends that go the wrong direction….that is analysis.
Each time you do your reviews, you make an entry in your
notebooks, noting anything found and the dates
thats documentation.
Now, how much time have you invested? What has it
cost you? What has been your resource outlay?
We are still looking for that something New something you
have never done before in your aviation career.
Over a period of time, your analysis of the controls you
have implemented to mitigate the risk of the unmarked
power line justifies your assessment that your controls
continue to work as expected.
You sleep better at night because you know you have
documented evidence that you are identifying hazards,
assessing risk, implementing controls and monitoring
controls to ensure their effectiveness. You are confident
that you are exercising due diligence and have a one of the
safest operations on the airfield. A fact you bring up
to your insurance company at policy renewal time.
Are you finished with the safety assurance process yet?
Not quite. So what’s next? You got it, the happy loop.
Looking at the stystem in operation, aquiring data,
analysing that data, and assessing that the system is
doing what is susposed to do you continue to monitor
your risk controls on a routine basis.
So when does the process end? Will putting visibility
markers on the power line eliminate the hazard or just
further mitigate the risk? Your right, burying the power
line is the only way to remove the risk, in other words,
removing the hazard. Visibility markers are just another
risk control.
You now have SRM and SA well covered, so what about the
other two components of your SMS? Safety Policy and
Promotion. Let's take a quick look…
Safety policy and objectives. You’ve had that in the
front of your reading file since you set up your SMS
and you review it periodically.
How about Management Commitment and Key Personnel?
That’s easy, it’s you.
Emergency Preparedness. You’ve got a company emergency
call roster and everyone has their pocket “In Case of
Emergency” card. Documentation and Records? Got it.
Safety Promotion. You do that.
Remember, that SMS is about the knowledge of safety
management…that is what counts.
Even the Wright brothers recognized the need for risk
management. This quote from Wilbur Wright, written two
years before the famous powered flight on December 17,
1903 exemplifies the Wrights’ attitude. It is clear that
their attitude toward risk management was a key element
in their ultimate success.