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WATCH

Six Attributes for Your SMS


By Russ Lawton

D
eveloping the documentation for your • Process Measures—These are means of provid-
Safety Management System (SMS) ing feedback to responsible parties that required
requires considerable sweat equity to actions are taking place, required outputs are
ensure it meets the SMS standard in FAA being produced, and expected outcomes are being
Advisory Circular (AC) 120-92 and that achieved.
the documentation accurately reflects
Next we discuss how each attribute fits into your
your company’s way of doing business. Your SMS
SMS program.
documentation must provide enough detail so ev-
ery employee understands how safety is managed
in your company and what is expected of them. Responsibility and Authority
How much detail should your documentation Management and individual employee accountabil-
include? There are six specific areas, or attributes, ity, responsibility, and authority are fundamental to
that form the basis for the expectations of your safety management. These concepts must be inte-
SMS program. These attributes, which are derived grated into your SMS program. The SMS standard in
from the FAA’s Air Transportation Oversight System AC120-92 establishes expectations for top manage-
(ATOS), should also be applied to your company’s ment, other company managers, and all employees
manuals and other documents. Let’s start by defin- of the organization.
ing the six attributes, and then we’ll briefly discuss The SMS standard requires a person of respon-
their role in your SMS program documentation. sibility to oversee SMS development, implementa-
• Responsibility—Who is accountable for manage- tion, and operation. The following is an example of
ment of the process (planning, organizing, direct- an accountability statement for a senior executive:
ing, controlling) and its ultimate accomplish- “The president/CEO, as the accountable executive,
ment? has the authority and responsibility to ensure the
• Authority—Who can direct, control, or change the development, implementation, and operation of a
process, and who can make key decisions, such as viable safety management program.”
risk acceptance? This attribute also includes the Note that the president does not bear the prin-
concept of empowerment. cipal responsibility for safety management. The
• Procedures—As specified ways to carry out an managers of the line operational functions (e.g.,
activity or a process, procedures translate the top, middle, and frontline managers) are the ones
“what” in goals and objectives into “how” in prac- who actually manage the operations in which risk
tical activities. is incurred. As a result, these managers are the
• Controls—These are elements of the system that “owners” of the SMS.
include hardware, software, special procedures The documentation must specify those people or
or procedural steps, and supervisory practices levels of management that can make safety risk ac-
designed to keep processes on track. ceptance decisions.
• Interfaces—Examples include items such as
lines of authority between departments, lines of Procedures
communication between employees, consistency Procedures are instructions that provide a clear
of procedures, and clear delineation of respon- understanding of how to perform a process or task.
sibility between organizations, work units, and A well-written procedure should include the four
employees. “Ws” (who, what, when, where) plus “H” (how). The

14 Aviation Business Journal | 1st Quarter 2009


following procedure for updating a manual incorpo- Process Measures
rates the four Ws plus H:
“What gets measured gets done” is the favorite ex-
• Each person that has been issued a manual (who)
pression of a long-time colleague of mine in system
shall complete the following steps whenever a
safety. If you don’t track events and activities, how
revision (what) to that manual is issued:
will you know how well things are working? You
• Remove existing pages listed on the revision no-
have financial measures of success in your compa-
tice (how and where).
ny, and similar measures should apply to safety. It’s
• Insert new pages listed on the revision notice
not good enough to say, “We must be safe because
(how and where).
we haven’t had an accident lately.”
• Log the revision on the Record of Revision Page,
An active safety committee and reporting pro-
reflecting the revision number and effective date
gram will help get feedback from employees as to
(how and where).
how they view safety throughout the company.
• Sign and return the revision acknowledgement
Internal and external audits also provide valuable
form to the director of operations (how and
feedback.
where).
While we haven’t been able to go into great detail
• The revision should be made as soon as practical
in each area, you can see how incorporating each
after receipt, but in no case later than the effec-
attribute into your documentation will make it
tive date (when).”
sound like a working document that people actually
use and not a bunch of policy statements that look
Controls impressive but can’t be put into practice.
Organizational process controls usually consist of
special procedures and supervisory and manage-
ment practices and processes. For example, an
FBO might require a line service supervisor to be
present whenever an aircraft above a certain size is
moved, or it might have procedures that designate
specific tug operators who have been trained and
certified to conduct the towing.
In another example, a charter operator uses a risk
assessment tool before each flight. When the risk
exceeds a predetermined value, either the chief
pilot or the director of operations must review and
either accept or mitigate the risk before the flight
is released. This example illustrates a process that
specifies those people or levels of management
that can make safety risk acceptance decisions and
specifies a threshold for when this must be accom-
plished.
Practices such as continuous monitoring, inter-
nal audits, internal evaluations, and management
reviews (which are all parts of the safety assurance
process) are also considered forms of control.

Interfaces
This can be as simple as providing each employee
with an organizational diagram that depicts the
company reporting structure. It should include the
safety manager and safety committee shown as
independent functions that report directly to top
management.

Aviation Business Journal | 1st Quarter 2009 15

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