Safety Management is a hot topic in aviation. Larger organisations have been required to have a so-called Safety Management System for a long time already, but for smaller organisations new rules apply as of April 2014. Now a Safety Management System is being made obligatory for smaller aviation as well, such as flight schools and flying clubs. Moreover, bigger players must integrate the Safety Management System into their entire organisation. Aviabel News had a conversation about the whys and the wherefores with Luc Michiels, Quality and Safety Manager at BAFA, and with Régine Hamelijnck, Rulemaking Officer and SMS focal point at EASA, the European Aviation Safety Agency.
Are the new obligations causing stress?
After all, safety's hardly something new in aviation, is it?
Luc Michiels: It's certainly not new. Lots of attention was already being paid to quality and compliance. For instance, the procedures imposed in practice and the theory are extensively compared with one another. That leads to certain conclusions, recommendations and a strict monitoring. Bigger players were already required to employ a Safety Management System. The new thing however is that now they have to integrate it into their entire organisation. But the obligatory introduction of a Safety Management System is something new for smaller players.
Régine Hamelijnck: Naturally, safety was in any case already one of the most important points of attention in the aviation sector. And it's not like there was a vacuum on the regulatory level before this. There were already plenty of safety rules and rules requiring some form of management systems. One of the important points of the EASA system is that all Member States have to follow the same rules. It is also the Member States who themselves are responsible for most of the certifications, the follow-up and inspections.
One of EASA's roles is to monitor the uniform implementation of Community rules.
What is the ultimate objective of such a Safety Management System?
Luc Michiels: In the final analysis, the Safety Management System has to result in greater safety. Concretely, in aviation we see that incidents regularly occur which don't produce a major catastrophe or where, except for those directly involved, hardly anyone knows anything about them. The Safety Management System is designed to ensure that there is clear and systematic reporting about such incidents. That makes it possible for us to draw lessons from them. I often compare the current safety situation with an iceberg: only the tip is visible, we never see a great deal of information that's below the surface. The Safety Management System is intended to change all that. This way we can raise most of the iceberg above water level. This doesn't mean that today we're working in structurally unsafe ways or that we should create a panic. It's just a matter of optimising a number of points via a logical and consistent Safety Management System.
Régine Hamelijnck: The Safety Management System will allow us to adopt a more holistic, proactive approach and create a better framework for leveraging all the efforts being made to increase safety, be it at the level of a single organisation, a state or a region. Concretely the SMS must assure a better identification of hazards, greater exchange of information, and thus more knowledge. Then this info can be used to increase safety via collaboration and joint actions.
I assume that people are sometimes afraid of reporting certain incidents because they fear sanctions?
Luc Michiels: That is indeed a real danger. And that's precisely why it's important to couple the right culture to such a Safety Management System. It doesn't serve to punish employees who made a mistake. Instead it's the intention to share information and arrive at better procedures. The entire organisation must learn from the reports, the goal isn't to unleash a witch hunt. And that's why the reports are submitted with a name attached, but beyond that are processed anonymously. Who was involved isn't so important.
We also have to make a number of important distinctions. For example, not every incident is the result of human error. Moreover, we have to distinguish
between so-called ‘errors’ and ‘violations’. An error is acceptable, a violation is not.
Let me give an example: an error
during refuelling is an error. Then we have to explore
what was the cause of the error. Is
it a problem of negligence, an inappropriate
procedure, too much commercial
pressure, a lack of planning, …?
Hence also the importance of
integrating the Safety Management into the entire
organisation. If a pilot takes his
seat in the cockpit dead drunk, it’s a violation. Obviously, something like that is totally unacceptable.
How does the system work in practice?
Luc Michiels: The employee involved completes a report that is recorded in a database. Then this report goes to the Safety Department, which checks whether all necessary information is available to take possible corrective actions. If certain info is still missing, they request it from employees or other involved parties. Finally, possible adaptations are made in the procedures, and naturally this is communicated to all employees and involved parties.
Is there a difference in vision between the different countries?
Régine Hamelijnck: No, I don't think so. The European countries are all on the same line. There is a lot of work being done as part of the European Aviation Safety Programme and European Aviation Safety Plan to promote common views on SMS in Europe. However, you can see a different perception of the workload in larger organisations than in smaller ones. A large aviation organisation has already come a long way with regard to safety policy and so understands the advantages of a structured approach. In smaller organisations one sees these benefits, too, but the focus quickly shifts to all the extra work that e.g. SMS may entail, which sometimes dampens the enthusiasm.
Safety doesn't limit itself to a particular organisation or region. It's an international given.
Luc Michiels: That's right. Both worldwide and on the European (EASA) and Belgian levels, a great deal of attention is devoted to Safety Management. In the field, however, it's crucial that the top of the company stands behind it and that the reporting isn't misused to penalise people. The main objective is to learn from the reports and draw the right lessons from them. So confidentiality is a conditio sine qua non.
Régine Hamelijnck: It's expected that air traffic will double in the coming 15 years. Stricter regulations, monitoring and follow-up is therefore necessary. We're working intensively on this together with other umbrella organisations around the world, such as FAA, TCCA and ICAO. For example, we've set up a joint working group: the Safety Management International Collaboration Group (SMICG). One of its objectives is to promote a common understanding of SMS worldwide.In addition to being a regulator and monitoing the application of rules, EASA is also actively promoting safety through the European Strategic Safety Initiative. ESSI, a partnership between European regulators and the aviation industry, works on a number of safety initiatives, such as joint safety assessments, developing SMS toolkits & cost effective action plans. The ultimate objective is to further enhance safety for citizens in Europe and worldwide.
Suppose that at a given moment within an organisation there are 10 cases that demand attention. It would seem to me impossible to immediately provide an answer to all 10 …
Luc Michiels: All cases are entered into a so-called risk assessment matrix, in which the seriousness of the incident is weighed against its potential frequency. Then work is done first on the cases that score 'high' on both parameters. That seems like a logical approach to me.