A Safety Management System Builds Healthy Airlines

It’s not another name for a safety department. Traditional airline safety departments, while well-intentioned, have suffered from being viewed as a by-product of managing flight operations, managed by directors of safety fairly low down in the management pecking order and reporting to the director or vice-president of flight operations.

This management structure continued the perception that managing safety was not the purview of airline presidents and CEOs.

As a result, directors of safety and their programs were not necessarily in the thinking of the top decision-maker. Safety programs were viewed as an "overhead" cost. And the safety department, although it was responsible for the airline’s safety program, did not have the means to carry out this responsibility.

By the mid-1990s, with ALPA’s urging through its "One Level of Safety" campaign, the FAA finally made the position of director of safety a regulatory requirement for U.S. airlines. However, the rule did not necessarily enhance the position: accountability and responsibility have not been balanced by authority.

SMS resolves that problem.

SMS is an operator-based system that combines the efforts of the operator, the employees, and the regulator. A regulator will always need to be involved, because it has legal oversight responsibilities, but the operator is the party that acts to achieve and maintain a safe operating environment. The operator manages its system to control hazards and uses information that its employees provide.

Employees are a key part of an SMS because they are out on the line every day. The operator needs to obtain information from employees to learn of hazards before the hazards create losses, and to verify that hazard controls are working as planned. Aviation Safety Action Partnerships (ASAPs) are important sources of such operationally important feedback.

Under the Canadian version of SMS—which will become mandatory for Canadian airlines over the next few years—the operator must have an "accountable executive." Here’s where authority and responsibility coincide—at the top. A proper SMS program will have formal management policies, programs, and practices that flow from the accountable executive and that he or she implements. In most cases, the accountable executive would be the airline CEO.

In plain language, the CEO is the safety officer, and the airline’s safety program is the ultimate responsibility of the CEO, not of the safety department. Company officers owe the CEO safety performance, tracking, and achievement. They owe the CEO effective loss control.

That’s part of being efficient.

The safety department in an SMS is the CEO’s band of experts who can help company management regarding safety. The safety department analyzes and troubleshoots. It can audit when requested. It can provide technical knowledge. The safety department can even promote communication within the corporation. The safety department can do much to aid the CEO’s safety program, but the department cannot on its own make the airline "safe." That comes from full and effective application of all the resources of the company—the safety culture.

Here’s what ALPA is doing as it works to get SMS implemented:

• training ALPA pilot representatives so they can train representatives from their airlines’ managements;

• working with aviation regulatory authorities and the International Civil Aviation Organization to develop a regulatory requirement for SMS (regulators can implement SMS internally by themselves, and ICAO recently drafted an SMS process for air traffic control);

• applying SMS within ALPA itself to help the Association’s leaders make key decisions;

• continuing to educate pilot safety representatives about SMS through the ALPA Safety Two School; and

• providing 2½-day workshops on SMS for master executive councils and airline managements.

Up to now, the airline industry has been relying mainly on regulation and accident investigation as bases for aviation safety.

Accident investigation as the basis for safety is always reactive, after-the-fact. We break an airplane. We investigate how it happened. We find the problems and fix them—or at least try to do so. Then we wait for the next "shoe" to drop—a slow and painful way to make progress.

Similarly, our culture long ago adopted the notion that safety could be regulated. Regulations are important and necessary, but some real problems arise from depending on regulations to make aviation safe:

• A regulator cannot possibly write regulations to cover all the things that can and do go wrong in our dynamic aviation system.

• Regulations are difficult to keep relevant and up-to-date.

• Regulators’ budgets are now tight —they have to do more with less staff, money, aircraft, and everything else.

• Progress through the typical regulatory approach is susceptible to "tombstone mentality"—i.e., a lot of blood must be spilled before new regulations are enacted.

While accident investigation and regulations are important, neither is the best—or complete—solution for ensuring aviation safety, nor is the combination of the two.

ALPA’s solution is SMS, and we are working to have it be the solution for the rest of the U.S. airline industry and regulators around the world.