The optimal implementation of SMS is to use the international industry guidance material outlining the key behaviors and processes needed for an effective SMS. Globally there are variations in cultural interpretations that can create significant differences in the SMS among individual organizations.
FAA Advisory Circular, AC 120-92A, Safety Management Systems for Aviation Service Providers, provides a Framework for Safety Management System (SMS) development. It contains a uniform set of expectations that align with the structure and format of the International Civil Aviation Organization (ICAO) Framework; and Aviation Safety (AVS) policy in Federal Aviation Administration (FAA) Order VS 8000.367, AVS Safety Management System Requirements, Appendix B.
Challenges in SMS Implementation:
Securing leadership commitment in performance metrics
Standardization of processes across the organization
Integrating all components of the SMS into everyday operations
Resistance to change
Middle-level management bottleneck
Influencing people and organizations to accept accountability
Provide a methodology for risk assessment that is both quantitative and qualitative, which increased willingness to approve and acceptance risk
Establishing international standard definitions for Hazards and Severities in the operational areas harmonized with aircraft design definitions.
Establishing international standards of acceptable levels of risk that are harmonized with the aircraft, ATC, and supporting systems design safety acceptance criteria.
Methodology continues to mature
Optimizing the relationship with the regulator
Improving Safety Culture
Providing SRM adaptability
SMS transformations will persist only if top management requires and ultimately institutionalizes an honest organization-wide conversation that surfaces valid data about the quality of safety management in each sub-unit of the firm that may lead to changes in management quality or replacement of managers.
- Failure to align the SMS policy with the working environment and conditions under which it has actually been developed resulting in ineffective SMS implementation.
- Misunderstandings that may result between operational directives and safety policies can diminish the benefits the SMS is expected to generate.
- SMS being implemented solely as a compliance exercise rather than as a genuine safety enhancement (requires management commitment).
- SMS can be considered a compliance check-the-box exercise (if it does not identify and initiate Safety improvements to operations or new changes to operations).
- A potential risk in the implementation of SMS is an inconsistency between current SMS practices. In the future, the safety environment may drift away from the conditions under which the SMS was originally developed and approved.
- The effectiveness of an SMS may be degraded as it depends not only in the content of the SMS policy document itself but how each element gets implemented. An effective SMS must be integrated in an organization’s processes and all its supplier inputs to those processes, fully promoted by the management, and executed by every employee. The safety policy, understood by all stakeholders, will act as a catalyst for positive change.
- Sufficient resources to dedicate continual priority support of SMS. The effectiveness of SMS implementation is heavily dependent on provision of corporate resources for effective training in the use of SMS principles including assuring that there are a sufficient number of personnel with the required commitment and skills to implement an SMS. ICAO hoped to achieve an Initial Operational Capability for worldwide SMA by 2012, but implementing organizations may underestimate the challenges of both changing their safety culture as well as implementing the required safety indicator feedback and analysis systems. Related challenges include identifying the unexpected organizational policy interdependencies between SMS being adopted among government agencies and across regulatory/industry boundaries.
- Managers speak the SMS language, but don’t behave differently – budgets, schedules, and daily routines potentially take precedence over executing the SMA process.