sms implementation lessons learned. 9 - 10 october 200810th steering committee coscap-sea, macau 2...

SMS ImplementationLessons Learned

9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau

2

Sources

ICAO Regional Workshop on Safety Management Systems (SMS) and State Safety Programme (SSP) Implementation

Paris, 5 to 7 February 2008

Transport Canada – Phased SMS Implementation in the Airline sector

2005 to 2008


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ICAO Regional Workshop on SMSObjectives:

To identify potential obstacles on the implementation of Safety Management Systems (SMS)

To discuss possible alternatives to overcome these obstacles

To propose courses of action to ICAO

Any other relevant aspects


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Canadian ImplementationOverview:

4-Phased approach to implementation with milestones

Rules for Airline sector – June 2005

Rules for airports and air navigation system providers – January 2008

SMS in all regulated organizations by 2010


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Lessons LearnedAccountabilitySustainabilityLegislationEnforcementReportingEvaluationComplexity


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Accountability Within Transport Canada (CAA) and within the

aviation industry Certificate Holder must identify Accountable

Executive Accountable Executive (CEO) leads

implementation and enables change (Behaviours = culture)

Line managers responsible for safety performance in their area of responsibility

Safety Managers support and assist


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Accountability LessonsInsufficient independence to manage resources

related to operations and activities (budget for safety)

Difficulty identifying appropriate position within large aerospace organizations

Must be correct at the beginning or SMS Implementation will be compromised

Fear of personal liability for certificate holder performance


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Sustainability Challenges Insufficient management commitment due to

lack of safety (technical) knowledge

Lack of commitment due to belief that SMS implementation will not be cost-effective

Inconsistent utilization by company personnel due to lack of understanding


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Sustainability Aids Viewing SMS approach to risk management as

opportunity to continuously improve rather than a journey with an end point

Incorporating continuous improvement into all aspects of operations

CAA to foster sharing successes of early adopters to demonstrate the benefits

Make clear that SMS is not completely new -- many elements are already in place (e.g. quality system, accident prevention program)

Emphasise business case and business risk


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Legislation

Legal constraints

Accident investigation vs Compliance investigation (i.e., enforcement)

Desire for open reporting vs Obligation to investigate non-compliance

Desire for open reporting vs National Access to Information provisions (i.e., mis-use of shared information)

Need for National legislation to address


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Enforcement The term is ambiguous, contributing to

misunderstanding and compromising effective policy development at State level

State response to non-compliance (Safety Policy) must evolve as SMS implementation progresses

State response to non-compliance (Enforcement Policy) must evolve with SMS implementation

Both aspects are crucial to supporting and promoting voluntary compliance

Guidance for Industry and Training for CAA personnel to enable effective implementation


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Reporting Early involvement of Employees in SMS

development encourages buy-in and fosters collaborative relationships

Effective Non-punitive reporting policy absolutely necessary to support reporting behaviour

SMS will lead to an increase in the number of reports

CAA needs an equivalent internal reporting policy and supporting processes


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Evaluation Data must be interpreted and used properly Within Certificate Holder: non-punitive

reporting policy, which has the sole purpose of creating a blame-free reporting environment to create a reporting culture

Within Industry: SMS enforcement policy applicable to Individuals and Certificate Holders to foster internal investigation, corrective action and transparency

Within CAA: reporting cultures and systems as well as legal protections, where appropriate


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Complexity of Certificate HoldersSignificant implementation differences between large

and small companies (i.e., complex vs less complex)

Differences related to both resources available to implement and systems required

Guidance especially important for both less complex certificate holders and CAA personnel

ICAO might integrate guidance material on the introduction of SMS for small to medium operators or service providers into new editions of DOC 9859

sms implementation lessons learned. 9 - 10 october 200810th steering committee coscap-sea, macau 2...

Documents

steering committee coscapsea

sms implementation lessons

sms approach

sms objectives

business risk slide

lack of understanding

safety performance

safety difficulty