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Preparing for SMS

The purpose of this report is to provide general aviation operators with a starting point for a discussion of elements to be considered when developing a company-specific Safety Management System.


March 26, 2009
By Glen Priestley

Topics

Introduction
The purpose of this report is to provide general aviation operators with a starting point for a discussion of elements to be considered when developing a company-specific Safety Management System. Regardless of when the regulatory deadline is for 406-703 air operators to implement an SMS, the

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Active participation in process documentation is critical to show due diligence and system management.


 

reality of liability requires all operators to do now what is reasonable and be able to demonstrate due diligence in regard to operational risk management. To achieve this there needs to be an understanding by all employees of the system and their roles within that system. For flight schools and general aviation operators, this poses additional challenges as there are a variety of customers, clients, support staff and tenants that will impact upon a company’s safety and security management system integrity.

Preparing to develop a company-specific SMS
For companies to develop a useful system, a thorough gap analysis and needs assessment must be completed. What is important is for the operator to have a clear understanding of what the end result looks like. This is the one major problem all operators expressed when describing their experiences of conducting a gap analysis and not devoting enough resources to establish the appropriate measurement tools for their operation. It is important to budget sufficient time to be able to do a thorough analysis of operational risk so an effective oversight program can be developed with measurable and realistic standards to make sure risk management targets are met. Since all air operators must have an accountable executive, this person should have a direct involvement with the initial analysis as resource allocation needs to be considered.


Tools to establish and maintain SMS

There are a variety of tools, training courses and consultants available that could be helpful for an operator. However, at  the core of SMS design is the importance of the company’s  executives to identify and analyze their operational risk and put procedures in place to manage that risk.
Transport Canada has developed a useful guide that provides a checklist for operators to follow  in deciding how system should be designed and implemented. Called Safety management Systems Development Guide for Small Operators/Organizations, it is available at www.tc.gc.ca/CivilAviation/IMSdoc/ACs/100/107-002.htm.

Developing and Maintaining Reporting Structures
As the concept of SMS developed, it became apparent that there needs to be a method by which the company’s SMS could be audited by the accountable executive to insure the risks the company was exposed to were being adequately managed, and operational and maintenance variances were being rectified, documented and tracked against a standard that was sound, appropriate and effective for that operator’s specific requirements. Richard Pedneault, safety officer for Cégep de Chicoutimi, reports that initial and ongoing interviews with new students and staff have proven effective for all stakeholders to understand what is supposed to be achieved.  Interviews start simply by asking what are the individual’s safety concerns; it is important to listen carefully and take notes.

Documentation, Tracking and Trending
Any good SMS is pure process. The measure of any good process is that it is thoroughly documented to insure repeatability, consistency and a guaranteed outcome. Active participation in process documentation is critical to show due diligence and system management. This is easy to say but it is, as Pat Kennedy, CEO of Pacific Flying Club stated, the follow-through on incidents that will be an administrative challenge in maintaining SMS integrity. There are a variety of documentation systems operators can use.  The challenge to is to find one that is cost-effective for the operation.

Operational Solutions to achieve an effective SMS
SMS will cause a refocus for flight school administration. Historically, a flight school’s training standard was based on the licensing standard as defined in the Canadian Aviation Regulations, with an emphasis on successful completion of written examinations and practical flight tests. For a flight school, the most important process is that of training a pilot. To properly direct and control this process requires documentation. Without a documented syllabus, an operator cannot hope to have the continuous improvement that is needed. The syllabus is not simply a convenience for Transport Canada, something to help it assess operators. It is a specific syllabus that a flight training operator needs to measure productivity, because good training doesn’t just happen. It needs to be planned, directed and controlled. SMS emphasizes that the entire training process is as important as the end result and because of this shift to a quality assurance-based system, the students’ role in the training process also needs to be redefined.

Mike Doiron, CEO  of Moncton Flight College, emphasized that two elements must be considered: One is the syllabus and the standard it is trying to achieve, and the other is the training environment and the operational culture. Are the students not only learning the correct procedures, but daily observing the staff and management conducting themselves in accordance with established procedures? 

There is no national standard for professional pilot screening, selection and training. Therefore, it is important that schools establish a process that passes the test of being sound, appropriate and effective for training students for their specific goals. This process also has to assess the threats regarding operational risk associated with the various student training activities, and put procedures in place to manage this risk. Examples of threat elements to be considered include language comprehension, threshold knowledge levels, and training time limits.

For flight schools, SMS provides an opportunity to identify and reduce repetitive student-related equipment damage. Repetitive accidents and incidents such as hangar rash, fuel spills and errors related to preflight preparation, possibly could be reduced if better explained before the first flight. This is where tracking and documenting of incidents is important. As Cégep-Chicoutimi’s Pedneault reports, instructors are given regular recurrent training including review of past incidents to be impressed upon new students.

Measuring SMS Success
Safety Management Systems cannot be learned just from a book or a generic weekend course.  SMS is an attitude that is best learned through practice, and for flight schools that means the culture of SMS needs to be made obvious to the students as they walk through the door. This will be apparent with the safety policy clearly visible and referred to by the first instructor but more so it will be obvious in the way people behave and the way the equipment is treated.

SMS: Continuous improvement
A documented syllabus of flight training is needed to properly direct the training at a school under Safety Management Systems. A syllabus would be needed for each authority on the Operating Certificate. These would not be approved by Transport Canada; because there will always be variations in the student population, policies are needed to tell staff how to manage these variations within a common syllabus.
The planned in-force date for the application of SMS regulations and standards to holders of flight training unit operator certificates is September 2009. Full implementation will be phased in over a three-year period.

SMS requires the application of quality assurance principles, including continuous improvement and feedback mechanisms.

Continuous improvement means a system of review and change that constantly improves a system or process.

The most important process of a flight training unit is that of training a pilot for a permit, licence or rating. Under SMS, this process will have to be documented (but not approved by Transport Canada) and followed by all staff. Unit policies and procedures would direct how to make allowance for variations among individual students.

Phase 1: Initial Certification
Within three months of the publication of the SMS regulation, initial certification requires that applicants provide Transport Canada:
• The name of the accountable executive;
• The name of the person responsible for implementing the SMS;
• A statement of commitment to the implementation of SMS (signed by the accountable executive);
• Documentation of a gap analysis between the organization’s existing system and the SMS regulatory requirements; and
• The organization’s implementation project plan, based on the requirements of the exemption and the certificate holder’s internal gap analysis.

Phase 2: One-Year Follow-up
After one year, certificate holders will demonstrate that their system includes the following components:
• Documented safety management plan;
• Documented policies and procedures relating to the required SMS components; and
• A process for occurrence reporting with the associated supportive elements such as training, a method of collecting, storing and distributing data, and a risk management process.

Phase 3: Two-Year Follow-up
Two years after initial certification, certificate holders will demonstrate that, in addition to the components already demonstrated during Phase 2, they also have a process for the proactive identification of hazards and associated methods of collecting, storing and distributing data and a risk management process. Required components:
• Documented safety management plan;
• Documented policies and procedures;
• Process for reactive occurrence reporting and training; and
• Process for proactive identification of hazards.

Phase 4: Three-Year Follow-up
One year following phase 3, certificate holders will demonstrate that, in addition to the components already demonstrated during phases two and three, they have also addressed:
• Training;
• Quality Assurance; and
• Emergency preparedness.