Saturday, August 27, 2016

Strategies for SMS Expectations

Expectation 1

A Safety Policy is an organizational guidance principle which describe the operational culture and core purpose for airport or airline operations. Canadian Aviation Regulations (CARs) requires airports and airlines to operate a Safety Management System which is based on this Safety Policy. In addition to the generality of a Safety Policy, this policy requirement is to establish a clear enterprise commitment to safety. The challenge for airports and airlines becomes to define what a clear commitment to safety is. A clear commitment to safety is not just a statement to be safe, but it is to capture defined expectations for operational processes. 


A Safety Policy has the ring of permanent nature.
Expectations are defined by Transport Canada in their SMS Document Review Guide (DRG), which was distributed to airlines and airports during the implementations phases of SMS. An airport, or airline that has not established a link to the expectation of a safety policy is assessed to be in non-compliance with the Canadian Aviation Regulations. Often the findings by Transport Canada states that “There is an expectation that…” 

The comment continues that there is no link between SMS design, or SMS operations and the expectation of a Safety Policy. The expectation is that an airport or airline fully comply with the expectation for complete regulatory compliance. 

The Document Review Guide of a Safety Management System has established an expectation of a Safety Policy that: “The organization has based its safety management system on the safety policy and there is a clear commitment to safety.” Reference to CARs are 107.03, 302.502(a)(i), 705.152(1), where 107.03 and 302.502 are applicable to airports and 107.03 and 705.152 are applicable to airlines. Under CARs 107.03 the requirements are to design a Safety Policy and CARs 302.502 and 705.152 are operational processes which are expected to conform to regulatory requirements.

A clear commitment to safety is blurred by assumptions of safety.
A Safety Policy is expected to have a design with a clear commitment to safety. An overarching safety policy is a commitment of Zero Tolerance To Compromise Aviation Safety and includes all Components of a Safety Management System. The first commitment of a Safety Policy is for an airport or airline to establish and maintain regulatory compliance. Without regulatory compliance there is no authority to establish, or maintain operational processes as airport or airline.  

As a second component to the Safety Policy is the performance requirements. These components are found in CARs 302.202 for airports and 705.152 for airlines. This intent of a Safety Policy is to establish and maintain operational processes which perform to regulatory compliance and that these processes do not in any way compromise aviation safety. There is no guarantee that a regulatory conforming process at all the times promote safety. However, the guarantee to safety is when an airport or airline accepts accountability, establish and follow-up in all aspects of operational processes with a commitment of Zero Tolerance To Compromise Aviation Safety.    


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Tuesday, August 16, 2016

The Building Blocks Of A Safety Management System

SMS regulatory compliance is depending on building block design
A Safety Management System (SMS) for Canadian airports, or airlines are built up by components, elements and expectations. These components, elements and expectations are in reference to the Transport Canada Document Review Guide (DRG), which was made available to all operations for implementation of a Safety Management System.
The 6 Components, 17 Elements and about 95 Expectation SMS building blocks are defined for operators to design a regulatory compliant SMS with performance processes that conform to regulatory requirements.

The components and underlying elements and expectations are defined in the DRG as follows:

Safety Management Plan;

  • Elements
  • Safety Policy;
  • Non Punitive Reporting Policy;
  • Roles and Responsibilities and Employee Involvement;
  • Communication;
  • Safety Planning
  • Performance Measurements; and
  • Management Review.
  • Expectations (multiple)

Document Management;

  • Elements
  • Identification and Maintenance of Applicable Regulations;
  • SMS Documentation; and
  • Records Management.
  • Expectations (multiple)

Safety Oversight;

  • Elements
  • Reactive Processes;
  • Proactive Processes;
  • Investigation and Analysis; and
  • Risk Management.
  • Expectations (multiple)

Training;

  • Elements
  • Training, Awareness and Competence.
  • Expectations (multiple)

Quality Assurance;

  • Elements
  • Quality Assurance.
  • Expectations (multiple)

Emergency Preparedness

  • Elements
  • Emergency Preparedness and Response.
  • Expectations (multiple)

Canadian Aviation Regulations are performance based regulations, where the output of processes becomes the determining factor of operational compliance with regulations. Components, Elements and Expectations are opinions designed by Transport Canada of what to include in a Safety Management System for regulatory compliance. Components and Elements are based on regulatory design requirements and performance requirements for operational processes. Expectations is a list of opinions of what is required within a system for design and for operational performance. Expectations provided in the DRG is a comprehensive list, but is not exhaustive for complete regulatory compliance in either design or performance.  

SMS design and performance must be in harmony.
Let’s take a moment and look at the Components, Elements and Expectations of an SMS and apply these building blocks to the Canadian Aviation Regulations. CARs 107.02 is a design regulation for a certificate holder to maintain an SMS. This regulation is applicable to both airports and airlines.
The component linked to this regulation is a Safety Management Plan. However, for a Safety Management Plan to be designed for regulatory compliance, there are elements of building blocks in support of the component, with one of these building blocks being a Safety Policy. The expectation, or opinion of a safety policy is that the policy exists, is followed and understood.

The making of a safety policy is a design of SMS, while the followed and understood expectations are performance expectations of SMS. SMS performance regulations for a safety policy are found in CARs 302.501 for airports and 705.152 for airlines. With the information provided in the DRG by Transport Canada, all information required for making and designing an SMS are provided to operators. Operational processes for regulatory conforming performance SMS are dependant on operator’s size and complexity. However, all operators must apply both an SMS design solution and process flow strategy for complete regulatory compliance with the CARs.


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