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Safety Management Systems work on the premise that the organizations that design, build, maintain and operate an aircraft are responsible for its safety. Regulators write and enforce laws and designate themselves as responsible for aviation safety. These two models are then at odds with regulators producing more regulations and oversight to improve safety and operators and manufactures taking responsibility to implement proactive safety.
In general, safety managers are lower on the corporate ladder than department heads, who may resist changes in implementation due to being accustomed to older systems. There tends to be an adversarial culture between regulators and manufacturers, a culture perpetuated by both sides. Clear responsibilities, new infrastructure, and trust among parties are crucial for the successful implementation of Safety Management Systems. This issue is present in multiple industries, including aviation.
In the event there is a discrepancy in corrective actions issued by a manufacturer and the regulator, the regulator will consider this a noncompliance. Therefore, the safest course of action for an operator is waiting for the Airworthiness Directive and complying, rather than taking the risk of implementing the Manufacturers Service Bulletin that may not be exactly the same as the AD with certain authorities. However, this can lead to an overdependence on safety management systems and regulations for decision-making, slowing response times.

Potential hazard

  1. Delays in implementing needed safety enhancements and/or mitigations indicated by in-service data trends due to fear of non-compliance with regulations and the resulting financial penalties.
  2. The reluctance by organizations to share data in a common platform is a major impediment in the implementation of SMS.
  3. Operators may ignore Service Bulletins from manufacturers unless backed by a requirement from the authority. Service Bulletins are often modified multiple times prior to the release of an Airworthiness Directive resulting in delays compromising safety.

Corroborating sources and comments

The same issue of reluctance to voluntary proactive safety implementation manifests itself because increasingly so, equivalent safety findings are found not acceptable after which literal compliance is mandated. This is due to decreasing expertise at the authorities where know-how, know-why – why are the rules as they are and know where is it written down – is slowly fading away.

Some non-U.S. regulators simply cite and do not modify the language of the Service Bulletin when issuing Airworthiness Directive. The FAA rewrites the manufacturer’s Service Bulletin when drafting the AD to make it legal in the U.S.

ICAO Accident Prevention Programme, 2005

Shift in the demographics of newly-hired air traffic controllers compared with retiree skills and interests

“Effective accident prevention is not a single function carried out by a designated organizational element. It needs to be a “way of thinking”, shared by all elements of the organization. The safest organizations take a systemic approach to accident prevention, organizing and managing their operations such that they experience proportionally fewer serious occurrences. Safety management considerations are thus integrated into the organization in the same way that financial considerations are.”

“…manufacturers are the best source for the overall safety record of a particular aircraft type or the in-service record of a component.”

“…the major aircraft manufacturers have active safety departments whose roles include, monitoring in-service experience, providing feedback to the manufacturing process and disseminating safety information to customer airlines.”

Problems and Solutions in the Implementation of Safety Management Systems;, November 2010 (Industry tips for locating and dealing with SMS resistance. Note in particular that safety managers may face opposition from higher up on the corporate ladder. Department heads may resist changes or tell employees to bring complaints directly to them, rather than through safety management, creating an adversarial culture on both sides that this piece seems to perpetuate. Dated 2016.) (General things to watch out for when trying to implement a corporate safety culture. Positive attitude, clear responsibilities, training, and new infrastructure are essential to successful implementation of safety measures, including SMSs. Dated 2013.)

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