Friday, December 13, 2013

Size, Complexity And SMS

It has been said that size and complexity is not taken into consideration for an Enterprise required to conform to regulatory compliance. Often this implies that regulations are targeted to fit large organizations and does not accommodate smaller Enterprises.

Both small and large organizations must conform to regulatory requirements to be regulatory compliant. A small organization should apply less complex systems to meet these requirements than what is expected from a large organization. 

On a foggy morning, size and complexity might not be obvious.
The issue is not that expectations are the same for both large and small, but rather that the small Operators are adapting processes to identify how a large organization conforms to regulatory compliance. Small Operators do not have manpower to operate in the same manner as large Organizations.

An SMS Enterprise has a system in place for the capture of information of hazards, incidents and accidents. In a small organization this may be done by submitting paper records direct to the SMS Manager. This report is hand delivery directly by the contributor and noted in the records. In a large organization a paper form submitted may be required to be scanned into an electronic database, entered in a database and submitted to a pre-scan manager for assessment, entered to the Hazard Register and then to the SMS Manager who delegates investigation. After risks have been investigated the report may be submitted for Corrective Action Plan through a committee or safety group. When a form is electronically submitted, several administrative tasks may be automated and the contributor may receive an electronic receipt with a generated tracking number.   

Apply the right tool and don’t use a broken jar as filing cabinet.
In large organizations there are often several individual involved prior to the hazard is risk-assessed. Should a small Operator attempt to follow the same complexity as a large Operator, they may be taking on a much greater task than what the organization is designed to manage.
Both small and large must conform to Regulatory Requirements for Regulatory Compliance. This is achieved by managing processes differently to conform to documented SMS processes. Regulatory Compliance is not achieved by conforming to systems which are not designed for the Enterprise.