Safety Management System: NTSB Most Wanted is Big Investment With Little Return

By Scott Spangler on July 5th, 2011

The NTSB just published its top-10 Most Wanted improvements to transportation. Beware of Number  Three, Safety Management Systems, aka SMS. For newcomers, here’s the FAA definition: “SMS is the formal, top-down business approach to managing safety risk, which includes a systemic approach to managing safety, including the necessary organizational structures, accountabilities, policies and procedures.”

Canada started requiring SMS for all modes of transportation in 1998. Aviation’s turn came in 2005. Approved maintenance organizations (AMOs, what we call repair stations) that serve commercial operators were up first. In talking to two them, I learned two things: setting up an SMS is expensive, and it is all about the paperwork.

In ballpark numbers, it cost an Alberta AMO an estimated $500,000 to set up the system, and its annual operating expenses run into six figures. An Ontario AMO estimates its cost at $75,000, but this does not include billable time lost to analyzing, planning, putting the system in place, or training the staff to use it.

The kicker, says the Alberta AMO, is that the benefits of a safety management system are not yet quantifiable. “Accident and incidents have always been extremely low, making a statistical analysis of trends unreliable. Longer term or industry-wide trending may be required to show benefits.” Until that time, he said, what stands out are the liabilities, the  system expense and administrative burden. And its coming soon to US airports and aircraft operators.

FAA rulemaking on SMS started in 2009. It issued an NPRM, SMS for Part 121 Certificate Holders, on October 29, 2010. Its public comment period closed on March 7, 2011. The FAA is now reviewing those comments. The FAA issued its NPRM, SMS for Certificated Airports, on October 17, 2010. It extended the public comment deadline to July 5, 2011.

It would be a safe bet that once SMS has taken root in commercial air transport that it will trickle down to general aviation. After all General Aviation Safety was another of this year’s NTSB Most Wanted.

sms_componentsThe SMS seed was first planted at ICAO, and its spreading worldwide, like bureaucratic kudzu. In reading about its four “pillars,” SMS smacks of corporate continuous improvement schemes that generate a lot of paperwork, which counts as productive work in companies that employ such programs. In my experience with them, once the paperwork is delivered up the chain of management, little else happens, including the implementation of the improvement that was the subject of the whole process in the first place.

Perhaps the most important thing I learned from the hundred or so hours of continuous improvement training I received was the concept of “margin of error.” The statisticians who were training us even provided the formula. What stuck in my mind, however, is that in the real world, no matter what you do, stuff beyond your control happens. You can invest millions in trying to prevent it, but it still happens.

A less stressful, more efficient and economical solution, they suggested, is to work to the margin of error and then deal with the stuff that happens. And maybe that’s where we are with aviation safety in both commercial and general aviation. I think many pilots, mechanics, and technicians could deal with this. Unfortunately, these decisions are made by those who measure their productivity and justify their existence and essential participation in paperwork. –Scott Spangler

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3 Responses to “Safety Management System: NTSB Most Wanted is Big Investment With Little Return”

  1. Safety Management System: NTSB Most Wanted is Big Investment With … | Share My Aircraft News Says:

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  2. Steve T. Says:

    News flash! SMS has already “trickled down” to General Aviation. Some of this is due to foreign mandates that those of us that fly internationally are required to comply with. Some of it, however, is just proactive operators that have always been willing to embrace safety enhancements (TCAS and EGPWS) even before mandated. Further , I’ll bet a month of Rob Mark’s royalties that the FAA will NOT mandate an SMS for FAR Part 91 operators in the foreseeable (say, 10 years) future. They simply do not have the personnel to oversee the behemoth that would be required in an approval and enforcement system. In fact, when the FAA transformed the SMS ANPRM to an NPRM, it included only Part 121. It realizes it does not have the folks to deal with PART 119, 125 and 135 operators yet!

    I do not see a direct correlation between an SMS and continuous improvement program (CIP). Though, as Deming proved, and Detroit belatedly discovered, a CIP (in the form of Kaizen) is not a bad role model! Self-examination, yes, but small, continuous improvement is not the goal of an SMS. Rather it is the implementation of a process that will make the quantum leap of preventing that one accident or incident every so often.

    I see an SMS as more of a continuous “show and tell” program. If there is a hazard in the system, why discover it, mitigate it (“deal with stuff as it happens”), and then NOT share it with your community? We as pilots have done this for years. The genius of the NASA ASRS is that the carrot of “getting out of jail” is dangled in front of pilots to get them to fill out the form post-incident.

    Pilots, technicians, flight attendants and ramp workers CAN “deal” with an SMS. But, can managers? It is up to managers to enable buy-in by making it part of the fabric of operations. Make it another “pain in the butt”, and it WILL become just another manual on the shelf, gathering dust.

    Long before the term SMS came into vogue, forward-looking operators had in place many of the pieces of what is now known as an SMS. So, for these folks, 95% of the “work” is already done. It is that last 5% that are the details that can prove to be the devil.

    Finally, I must disagree with your comment, “Unfortunately, these decisions are made by those who measure their productivity and justify their existence and essential participation in paperwork.” The NTSB may be many things, but it is NOT, IMO made up of this type of person. Three members of the board are licensed pilots. One was a line pilot for a major US airline AND a Director of Aviation for a corporate flight department. The staff folks on the aviation side of the NTSB, who make recommendations to the Board, are smart, dedicated aviation professionals. Not a paper-pusher amongst the lot!

  3. Felipe Andrade Says:

    I heard that SMS will soon become the ICAO Annex 19 (by soon I mean next year). Lets see how the community will embrace it.

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