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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