Thursday, March 23, 2017

A Qualified Person Runs The SMS

When an airport operator or an air operator appoints a qualified person as the Accountable Executive, the options are wide open to appoint anyone in the organization who they see qualified to be responsible for operations or activities authorized under the certificate and to be accountable on
The AE is a position without performance requirements.
behalf of the operator for meeting the requirements of the regulations. The requirement to qualify as the AE is a person who has demonstrated control of the financial and human resources that are necessary for the activities and operations authorized under the certificate. This is a broad description of qualifications, but becomes limited to organizational structure of authority.

The appointment of an airport AE compared to an air operator AE is slightly different, since an airport certificate is issued to a land-surveyed area, while an air operator certificate is issued to an individual or a corporate body. An AE for an airport is responsible to the land-surveyed area, while the AE for an air operator is responsible to the board of directors. However, as operators both AEs are responsible on behalf of the certificate holder for meeting the requirements of the regulations, which one of them are the Safety Management System regulations.

An Accountable Executive requirement could also be a matter of identifying a person who leads the necessary cultural change of Just Culture and Quality Assurance Culture and how services are provided with safety assurance to the general public. Without an SMS there is no safety assurance.

Run the SMS as a businesslike approach to safety.
Aviation Safety Management System is the NextGen of aviation safety, where a cultural change is inevitable for an SMS leader to be successful. Culture change does not happen overnight, but over a lengthy period of time. For a Just Culture to develop, each individual in an organization must be acceptable to these changes. The Just Culture and Quality Assurance Cutlers are developed within an organization by personnel consuming data, applied learning to data for processing into information, engage their information in operational processes with an output of knowledge and by assessing this output and comprehend the systems involved in a change of culture. This change is culture is the Return on Investment (ROI)

SMS is a businesslike approach to safety, where ROI is vital to success. When a certificate holder is applying this businesslike approach to safety and appoints a qualified person as the Accountable Executive, the requirement of demonstrating control over human and financial resources is incidental to the ROI. When applying this concept the NextGen of Accountable Executive Leaders in Aviation SMS are born.  


Saturday, March 11, 2017

AE Demonstrating Control Of Financial And Human Resources

In an SMS world the leader of the SMS program is the Accountable Executive, or the AE, who is playing the role as a sponsor of a specific project. A sponsor is a person who provides funding necessary, or a percentage of a project or activity carried out by someone else. A sponsor does not have direct inputs on the activities in the project, but can affect management decisions by withdrawing the sponsorship or increase their funding of both financial and human resources. Upon
Comprehension of the SMS is what defines human and financial resources.
the completion of the project there is no impact on the sponsor, other than the reputation of the project, or activity that was sponsored. It works the same way in aviation, being an airline or an airport, as long as the Accountable Executive can document their role as the sponsor of the project by the control of financial and human resources; the only repercussion to the operations is their pride and reputation from devastating audit findings.
It is assumed that the more funding and personnel that is assigned to a project, the more successful and safe the project will be. This wrongful assumption is supported by a requirement that a person, or position, is not designated as the role of the AE unless they have control of the financial and human resources that are necessary for the activities and operations authorized under the aviation certificate. With this requirement, an operator may be hesitant to restrict, or reject funding or personnel to the operations when the safety–card is applied.

There is no enforcement available when the AE restricts, reject or withdraw funding from an SMS program. The regulatory requirements is not directly linked to the funding itself, but to the result, or output of the Safety Management System. If an increase in funding from the sponsor, or AE, of an airline or airport as the only means to safety solutions would reduce the risk level, then it would be redundant, excessive, or even an injustice to the public to operate with a Safety Management System.

Under an SMS there is a requirement that the AE has control of financial and human recourses. Unless the operation is a sole proprietor or a corporation with 51% shares, there is no person who singlehandedly has control over these financial and human resources. With a requirement that the AE
Safety and SMS in aviation is not a contrast in colors, but shades of variables.
must demonstrate control of these resources, this demonstration task becomes to demonstrate by the quality of the safety management system itself. If the AE, as the sponsor of the program, is on a path to success or in a downward losing spiral the resources are available tools, but not the strategic solution to safety. The more resources that are inputted on the controls of an airplane in a spiral do not eliminate the spiral, but is assisting the spiral in an increasingly downward trend. For an airplane to exit a spiral it takes leadership, management, system understanding and application of resources to knowledge from data collected. Financial and human resources in aviation safety, or with an SMS, are not the solutions, but variables within the processes which are harnessed by their role within one system, for the total system to produce the desired, or planned, outcome.

An Accountable Executive who is defining the quality of an SMS system by human and financial resources only may not contribute to the safe operations of an airport or aircraft, while an Accountable Executive who is a leader within an SMS system applying strategic safety solutions is on a path of continuous safe operations.


Friday, February 24, 2017

Defined Roles For The Accountable Executive

A system without defined roles has little or no chance to function as intended. Lets for a minute look at a None Destructive Testing system, or NDT. NDT is a system to detect “undetectable” flaws in a material, or if production process produces output of flaws in the material. There are different independent system within an NDT system and none of these systems are compatible to interact with any of the other systems. The major NDT inspection systems are X-ray inspection, ultrasound inspection, magnetic particle Inspection and fluorescent penetrant inspection.

A system of defined roles within a process.
The system of X-ray inspection is applied to inspect for flaws within a material to relatively fine and defined resolutions.  Ultrasound is also applied to inspect for flaws within a material, but to a relatively course and undefined resolutions. Magnetic particle inspection is applied to both internal and external material flaws discovery. The NDT inspection system applied for external inspection of flaws is the fluorescent penetrant inspection. Within an NDT system all these independent systems function to produce an outcome of an effective system that will function as it was designed to function. None of these methods of NDT inspections are inferior to one or the other, they are just a part of one total system to manage, or lead processes to produce a flawless output.

Within an SMS system the functions of each system, or defined roles are hidden within human factors. In contradiction to mechanical systems, human factors include unpredictable variations. These variations are harnessed by defining roles for each person within an SMS system.

The accountable executive has certain defined roles which the AE must perform for the total system to function, without expectations that another person will pick up where the AE did not fulfil the role. The role of an accountable executive is to fuel the SMS system with safety. An effective AE is involved strategically rather than operationally for the SMS system to have an anchor point within the organization.

Without defining the roles or to assume a person should know better is often how unsuccessful businesses are operating. The definition of those systems is for a person to apply variations and pick up the slack as they see fit. Within an NDT world of systems, this would compare to placing an
Fill in the blanc and play that role.
aircraft jet-engine disk in the dark room for fluorescent penetrant inspection and expect an x-ray image to be produced by that process. The only way, and the process of which flaws in the jet-engine disk is discovered is to apply the fluorescent penetrant inspection as the process was intended.

An accountable executive has defined roles for one reason only, and that if for the SMS system to be effective where processes are producing outputs of what the processes were designed for. This does not imply that the processes should not, or does not identify flaws within the activities, but rather confirm that the processes of an effective SMS system identify both normal variations and special cause variations. In an NDT world, a jet-engine disk could be acceptable without flaws, or the process, when applied correctly, could identify an unlikely flaw in the material.


Saturday, February 11, 2017

Safety Burnout

About 4 years ago, the first blog in this post was written and published. Since then safety never got bored, or bunt-out, but became more exiting to work with as time went on. The first story was about the Safety Management System and how aviation has evolved from the “trial and error” method to proactive and no longer accepting that accidents happens. There was never an acceptance of accidents, but the aviation industry did not make necessary changes until it was too late and a catastrophic event had happened. Over the last decade or so, SMS in aviation has been accepted as the New Generation of Aviation Safety. It is widely accepted that there is no profit in operating without documentation of established safety processes.

Safety has become a task to check the job completed box.
There is still an ongoing debate of what SMS actually is with multiple and inconsistent answers given. SMS is simple in concept, but often buried in bureaucratic paperwork and presented to the aviation industry as a system that nobody can understand, except to be able to fill in the check-boxes and comply with opinions.

SMS is about job-performance and a confidence level of how safe the outcomes are of tasks completed. Some believe that it is possible to have a process for everything within an SMS system and a 100% confidence level that they are operating safe, but it isn’t. An organization without an SMS implemented my live by this myth since it is their justification based on opinion and not data.

SMS is a businesslike approach to safety and an additional layer of safety of what the aviation industry already had in place. An effective SMS system parallels the operations. In the pre-SMS days, an operator would call up a friend and ask how they would do certain things and how it works. For other issues, they would call up other friends and get information of the best and safest way to operate. This was not a businesslike approach, but a fly-by-the-seat-of-your-pants approach. Corrective actions were not initiated until the airplane took an unexpected turn.

The fly-by-the-seat-of-your-pants system, which is a follow-me-system, and a Safety Management System which is leadership system are two different system approaches and incompatible systems. However, there are some who insists that these two systems are merged by applying follow-me opinions as requirements and demanding compliance with the leadership and accountability system. With this attempt to merge two incompatible systems, applying failures to each opinion that are not met and continuing to make attempts to merge after the first one failed leads to safety burnout. There are two indicators of safety burnout, or being on a slippery-slope to safety burnout, which are the “check-box” syndrome and the “opinion-syndrome”.

Expectations and process on collision course.
As a businesslike approach to safety SMS becomes simple and enjoyable as safety goals are reached and continuous safety improvements achieved. Without allowing for an SMS to function the task to manage safety is to look backwards and dwell on failures when at the same time attempting to move forward with corrections. It is more convenient for regulators to see SMS in a backwards view, rather than allowing time for SMS to move forward. Without the business knowledge of applying a business-like approach to safety, but demanding immediate return on investment, SMS is viewed as to be in non-compliance. When an SMS is found in an opinion-non-compliance the most convenient process to change is to change the process for compliance with opinions. The regulators are admitting this themselves by referencing to SMS expectations for non-compliance findings, since expectations are nothing else but opinions.  

When these two opposing forces of a follow-me system and leadership system are colliding, it is creating a dysfunctional operating environment identified by SMS. As often, the messenger is being blamed and findings are given to the SMS system, when it should be given to the opinion that changed the performance of operations. When an SMS functions as it was indented, there will never be burn-outs, since there will always be another and new safety challenge to take on and move forward with excitement. Safety burnout is the result of check-box and opinion-based SMS compliance.


Saturday, January 28, 2017

How Does One Know If An Organization Is Applying The Non-Punitive Policy

That an organization has a non-punitive policy is an organizational and senior management statement
of accountability and a commitment of support for improved job-performance. In many
With the stroke of a pen the reactions to future events are set.
organizations, personnel job-performance has reached its limits with little, or no room for improvements, until there are unexpected and major quality flaws or improper customer services discovered. Sometime these events are named “mistakes” which initiate the process of learning-stagnation and there is no further action to learn from this “mistake”. Applying the non-punitive reporting policy is a policy to learn from mistakes and train for improvements.

A safety management system should include any requirements for an effective and continuous improvement of the SMS system. A non-punitive policy is a system-design regiment to be included as any additional requirements for the safety management system. This requirement is not a specific non-punitive policy design requirement, but it becomes an operational performance criteria for the SMS to function effectively.  When assessing the performance of an SMS, there is a requirement to apply a policy for the internal reporting of hazards, incidents and accidents, including the conditions under which immunity from disciplinary action will be granted. Immunity is for a person to be protected, or exempted from something, especially an obligation or penalty.

Data is formatted to comprehensive information.
This requirement to include a policy where there is immunity from disciplinary actions is applicable to the organization itself, or to the senior management team and is not applicable to employees of the organization. However, the non-punitive policy the organization develops becomes applicable to their employees in just-culture environment as an occurrence reporting tool, and applicable to the management to ensure this policy is applied as intended.   

There  are several tools available to analyze operational data either to confirm that the policy is applied as intended or to discredit opinions of an effective policy. One of these tools is to analyze identified training and training records for the person who submitted a report. After the airport, or airline received the report they applied their non-punitive policy to the contributor's behavior. An organization may have a check-box marked on the paper-format report form, or in electronic format that the non-punitive policy was applied, but these check-box tasks does not qualify as data to confirm, or discredit that the policy is applied. Check boxes are not direct-data, but indirect-data as triggers for further actions. The confirmation of applying the non-punitive policy is found in the training records.        


Saturday, January 14, 2017

Understanding the Non-Punitive Policy

A non-punitive policy is not a “get-out-of jail free card”, but a policy for continuous, or continual safety improvements within an SMS system. When a non-punitive policy is understood within an
Writing a non-punitive policy is a skill of quality assurance.
organization all personnel have an opportunity to raise safety concerns and report hazards as their contribution to safety improvement. When hazards are not identified, they are latent and unknown risk factors with a potential to cause an incident or accident. In organizations where there is no training provided for understanding the non-punitive policy, the doors are left wide open to apply the policy to any non-job performance activities. When a non-punitive policy is applied as a “get-out-of-jail” free card it could be applied to report excuses for inferior job performance rather than reporting specific to the hazard, or incident itself.

Applying a non-punitive policy as a safety-excuse tool is when contributors reports on themselves to avoid being questioned about their job-performance. This type of report may take form in of projecting a less desired outcome to a mistake with the assumption that others in the organization have had similar thoughts and experiences as oneself and therefore accept the report without further investigation. Where mistakes are widely accepted in an organization to be non-punitive policy applicable, the door to learning is forever closed.

In organizations where the door to learning is closed, another door opens wide to report on others of their job-performance mistakes. These types of reports may take form of projecting a less desired job quality onto safety. Since learning already is inhibited by organizational acceptance of mistakes the safety-card becomes the “straight-flush” to generate a hazardous working environment.

When these types of reports are accepted as a replacement for learning the organization is undermining the concept of learning and the promotion of continuous, or continual safety improvements.

Understanding the message of a non-punitive policy is a learning process.
Contributors of hazard reports may expect that hazards reported are eliminated immediately even if the hazard reported is a low impact hazard. This expectation comes from the fact that a hazard stated is assumed to have a safety impact and that someone else has an obligation eliminate the hazard immediately. That someone has an opinion of a hazard being a safety concern does not automatically make this hazard a safety risk. It takes an analytic process to identify the risk factor of a hazard including collection of more data. An identified hazard accompanied by an opinion of being a safety risk, is only an opinion of a hazard. An identified hazard does not automatically become a risk, even if accompanied by that opinion.

When the non-punitive policy is understood in an organization and applied within a Just Culture, opportunities of options becomes available to improve safety. The key to success of a non-punitive policy is to build a bridge between an organizational culture where learning is promoted and mistakes are accepted as a learning tool but not accepted as an excuse. This bridge is called the bridge of accountability.

These options to improve safety are available since learning is acceptable, reporting has become fact-finding mission and the organization is prepared to learn from the expert. The experts being someone who just learned the hard way by making an error in job performance. Understanding the non-punitive policy is to feel the contribution of productivity when performing job-tasked responsibilities of high quality. A non-punitive policy can only be understood in an environment where “the boss” accepts to hear “bad news”.


Saturday, December 31, 2016

New Year Resolution: Non-Punitive Actions

New year is the time of the year when most of us make promises to ourselves to live a different lifestyle or take on challenges that have been out of reach before. These promises are often made in the spur of the moment and without consequences if not kept. Often, when a new-year resolution is made, it becomes a game to see if anyone can make it last past the first month of the year.

Illegal activity of the SMS.
This year a new-year’s resolution could be to implement a non-punitive policy in the organization. When a safety management system in aviation is required by the regulations a non-punitive policy must be in place to conform to regulatory requirements. This policy is written and implemented, but there are several options to find an “out” when there are issues that goes against operational practices. Unless there is a total commitment to safety in aviation, where information and data is critical to improve safety, the expectations for a non-punitive policy is that it is not applicable to: illegal activity, negligence or willful misconduct. These conditions make fully sense not to include as a “get out of jail free” card to personnel. However, when organizations are unable to pre-qualify and define what actions are included in illegal activity, negligence or willful misconduct, decisions are made in the spur of the moment and after the fact.

Illegal activity must be pre-defined in a job description, or for a job performance evaluation and based of decisions made by the courts. Illegal activity cannot be applied as punishment by a private individual, or an organization, to any person for a job description violation, or lack of job performance. When integrating illegal activity into SMS the management has an obligation to determine if there was an act of illegal activity to any and all incidents or accidents.
Negligence becomes a challenge to defined in a job-description or apply to a job-performance evaluation since this would involve the organization’s effectiveness of training. When an error, mistake, on unplanned event happen to someone the organization has an obligation to determine if the action must be classified as negligence. For a safety management system to identify negligence data must be collected, analyzed and investigated. Within the SMS system there are no regulatory requirement, or standard to assess, or audit a job performance against negligence as this also would jeopardize the just-culture of the SMS system.

Willful misconduct is a human behavior action and the violation is enforceable by a regulation, standard or policy. An organization that includes willful misconduct in their job description, or as a standard for an on-the-job evaluation, have an obligation to assume that every incident, or
Without data, it’s just some person’s opinion.
accident are the result of willful misconduct. When willful misconduct is applied in the SMS investigation processes the organization has developed a culture where job-performance reviews are elevated to a level beyond a functional SMS.

The Safety Management System is a system that can only operate within a just-culture, or a culture where learning is accepted and encouraged. When applying illegal activity, negligence or willful misconduct opportunities for learning are eliminated since these activities are only intended as enforceable policies. When applying these criteria, an organization is moving outside the scope of operational activities and job-performance standards. In addition, these policies are contradictory to a functional Safety Management System and an operational safety culture within a just-culture. Illegal activity, negligence or willful misconduct are the new-year resolutions of aviation safety.