Tuesday, December 10, 2013

SMS And Small Operators – Like Driftwood

Small, medium or large – any air operator has to conform to regulatory requirements, no matter what size and complexity they are. A small operator may be a one person operation or having 2-3 employees where everyone is involved in the day to day operation. Planning to ensure regulatory conformance becomes an after hours job for the owner, and often goes into the late night hours.

Certified Airports of any size and complexity are required to operate with a Quality Assurance Program and Safety Management System. Airlines are required to operate in a just culture with an SMS, but airtaxi operators are not regulatory required to implement SMS today. However, airtaxi operators are still required to conform to regulatory requirements, and without a documented system in place it becomes a convoluted task to ensure all requirements are complied with. It is just as simple for an airtaxi operator to implement SMS as it is to re-invent the wheel and apply another non-documented system to ensure regulatory compliance.  A non-documented system to ensure regulatory compliance could be as ineffective as driftwood washed ashore and waiting for the next flood to arrive.  

Unless a system is maintained, no matter how well the system has performed in the past
there will be a time when it becomes beyond repair.
As a concept the Safety Management System is simple that one must plan, do, check and act.  However, it may become a complex task to identify how to implement processes to conform to regulatory requirements. The six components of an SMS plan are Safety Management Plan, Document Management, Safety Oversight, Training, Quality Assurance and Emergency Preparedness.  How to implement these components could be written on a six page document, or in a 60 page document for a complex organization.

Safety Management Plan is to have an idea how to operate safe, write this on a document and call it a Safety Policy. It is to accept that when an incident happen, the organization will find out why it happen and make changes to avoid it next time. Some operators call this the non-punitive policy. If the person who had an incident gets fired, hiring a new person could quadruple the work load. The organization has to advertise for new person, interview new person, paperwork for new person and then train the new person, just so this person can repeat the same mistake.

Some say that training is too expensive and affects the bottom line.
Then, how many employees must they hire to find one who is already trained?
The other five components of an SMS could also be simplified and implemented. In a day to day operation, an airtaxi operator has most of these items are already covered, but possible not documented, filed or placed in an organized “to do list”.

Document Management is to know what documents are required and where to find them. It is also to have a process in place to know what the regulatory requirements are.
Safety Oversight is to document hazards, incidents, accidents, investigate analyze and make changes to give higher quality of customer service.  
Training is to document training requirements, set date when training is due, use of checklist what to include and do the training as required by regulations.
Quality Assurance is simplified to check if the organization has established processes to be regulatory compliant and that all processes conform to the regulatory requirements. 
Emergency Preparedness is to have a plan should an emergency occur.

Enter it all on an electronic checklist and you are ready to go. When the requirement comes for implementation of SMS, several of the requirements are already documented and the organization has learned to understand a safety management system. SMS is simple in concept where human factors, organizational factors and environmental factors are triggers to success.