SMS Implementation Lessons Learned

2 Sources ICAO Regional Workshop on Safety Management Systems (SMS) and State Safety Programme (SSP) Implementation  Paris, 5 to 7 February 2008 Transport Canada – Phased SMS Implementation in the Airline sector  2005 to 2008

3 ICAO Regional Workshop on SMS Objectives:  To identify potential obstacles on the implementation of Safety Management Systems (SMS)  To discuss possible alternatives to overcome these obstacles  To propose courses of action to ICAO  Any other relevant aspects

4 Canadian Implementation Overview:  4-Phased approach to implementation with milestones  Rules for Airline sector – June 2005  Rules for airports and air navigation system providers – January 2008  SMS in all regulated organizations by 2010

5 Lessons Learned  Accountability  Sustainability  Legislation  Enforcement  Reporting  Evaluation  Complexity

6 Accountability  Within Transport Canada (CAA) and within the aviation industry  Certificate Holder must identify Accountable Executive  Accountable Executive (CEO) leads implementation and enables change (Behaviours = culture)  Line managers responsible for safety performance in their area of responsibility  Safety Managers support and assist

7 Accountability Lessons  Insufficient independence to manage resources related to operations and activities (budget for safety)  Difficulty identifying appropriate position within large aerospace organizations  Must be correct at the beginning or SMS Implementation will be compromised  Fear of personal liability for certificate holder performance

8 Sustainability Challenges  Insufficient management commitment due to lack of safety (technical) knowledge  Lack of commitment due to belief that SMS implementation will not be cost-effective  Inconsistent utilization by company personnel due to lack of understanding

9 Sustainability Aids  Viewing SMS approach to risk management as opportunity to continuously improve rather than a journey with an end point  Incorporating continuous improvement into all aspects of operations  CAA to foster sharing successes of early adopters to demonstrate the benefits  Make clear that SMS is not completely new -- many elements are already in place (e.g. quality system, accident prevention program)  Emphasise business case and business risk

10 Legislation Legal constraints  Accident investigation vs Compliance investigation (i.e., enforcement)  Desire for open reporting vs Obligation to investigate non-compliance  Desire for open reporting vs National Access to Information provisions (i.e., mis-use of shared information) Need for National legislation to address

11 Enforcement  The term is ambiguous, contributing to misunderstanding and compromising effective policy development at State level  State response to non-compliance (Safety Policy) must evolve as SMS implementation progresses  State response to non-compliance (Enforcement Policy) must evolve with SMS implementation  Both aspects are crucial to supporting and promoting voluntary compliance  Guidance for Industry and Training for CAA personnel to enable effective implementation

12 Reporting  Early involvement of Employees in SMS development encourages buy-in and fosters collaborative relationships  Effective Non-punitive reporting policy absolutely necessary to support reporting behaviour  SMS will lead to an increase in the number of reports  CAA needs an equivalent internal reporting policy and supporting processes

13 Evaluation  Data must be interpreted and used properly  Within Certificate Holder: non-punitive reporting policy, which has the sole purpose of creating a blame-free reporting environment to create a reporting culture  Within Industry: SMS enforcement policy applicable to Individuals and Certificate Holders to foster internal investigation, corrective action and transparency  Within CAA: reporting cultures and systems as well as legal protections, where appropriate

14 Complexity of Certificate Holders  Significant implementation differences between large and small companies (i.e., complex vs less complex)  Differences related to both resources available to implement and systems required  Guidance especially important for both less complex certificate holders and CAA personnel  ICAO might integrate guidance material on the introduction of SMS for small to medium operators or service providers into new editions of DOC 9859