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9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
3
ICAO Regional Workshop on SMSObjectives:
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
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
4
Canadian ImplementationOverview:
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
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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Lessons LearnedAccountabilitySustainabilityLegislationEnforcementReportingEvaluationComplexity
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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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
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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Accountability LessonsInsufficient 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
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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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 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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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
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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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
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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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
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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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
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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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
9 - 10 October 2008 10th Steering Committee COSCAP-SEA, Macau
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Complexity of Certificate HoldersSignificant 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