�ݺ�ߣ

Editor's Notes

1. Significantly, the US Part 135 Business Aviation sector (generally 10 or more certificate holders) and Part 145 Repair Stations will come under new FAA scrutiny under the System Approach for Safety Oversight AFS 30 office at the FAA. The Safety Assurance System (FAA’s internal program) takes the success of ATOS for the large Part 121 carriers, end expands it significantlyHowever both the new rule and the new oversight will be based on System Safety principles that have been around for nearly 15 years.Our approach today is to show you how to cost effectively you to meet or exceed the requirements of the coming rule and over-sight while doing so with minimal ‘additional’ change – in other words the 8 steps toto enable SMS as part of your day to day business
2. There are many interpretations as to what is an SMS. For the US marketplace we really need to focus on what the FAA SMS guidance leads to
3. An efficient SMS has many components – capture, analysis, assessing risk, tasking and reporting. In order to get there we have identified 8 steps.Gain Top Management CommitmentImplement Safety Management Across an Air CarrierEnsure Documentation, including Processes, Signatures and DeliveryEnable a Culture of Incident ReportingCapture and Analyze all Safety Related InformationTie Risk Assessment to Incidents and Relate Cost ImpactAudit – Making Sure You Do What You Say You Will DoReport and Share Information with Management and Regulators
4. Let’s look at these in order. The ‘order’ is based on the FAA guidance material generally available
5. Provide a framework for adoptionCreate an environment where safetyisthe business and information about safety is generated as part of normal day-to-day operations.Facilitate reporting of eventsFacilitate analytics across the businessFacilitate a constant view of the health of the business as it related to safetyLimit new costs and minimize re-training
6. Any questions of comments about how an electronic SMS enables Management Commitment
7. So how do we actualize SMS
8. Once management has defined the roles responsibilities and has put in place a just culture, now what?
9. Safety and risk management are informational problems. All information related to operations, policies, procedures and documentation need to be brought together for visibility and analysis. Information silos make visibility and analysis almost impossible to address With SMS: Sharing information is no longer optional. How does a certificate holdercreate an environment of sharingon a limited budget? One place for all information
10. You need to provide an information foundation as we have discussed to capture and maintain knowledge of the risk profile of the certificate holder, engage and encourage all personnel to both report and act on safety recommendations.By bringing information together with engagement of the entire organization you provide the enabling engine for the safety culture
11. A principle building block of safety is documentation. Clearly defining all actions required to operate provides the foundation for repeatability and enforcement of consistency. Critically though, you need to be able to manage change in documentation and enable distribution to those who need it
12. Tech pubs is usually the last thing thought of when changing or enhancing processes in the certificate holderHow many sticky notes do you have in your manuals. In one organization I worked with the training manual had over 400 sticky notes – tough to maintain consistency and clarity of directionHow do you ensure that the latest approved documentation is in place where needed? How do you stop people from working with outmoded documentation?An how often does your organization face challenges with departmental ownership of documents, their styles, formats and applicability
13. The reality:The tech pubs department and documentation in general is the last thing anybody thinks about in the business.  That being said, without clear and well defined documentation, the business is potentially out of compliance with rules.  Many smaller operators have dust covered manuals in place Providing a well defined and easy-to-use change management process plus related workflow to make sure it gets done would certainly be recognized by the regulator as they oversee the adherence to the ‘rule of the documentation’.  In the aviation business, the ONLY things that get done are those documented.  If operators are doing things that are not clearly documented they are out of compliance and could lose their operating certificateAfter all the FAA Guidance says that: a) Documentation will be:LegibleDated (with dates of Revisions)Readily identifiableMaintainedin an orderly manner Retainedfor a specified period of time as determined by the organization
14. Documentation Management systems or Content Management systems are expensive, complex and specialized. A good electronic SMS solution provides the fundamental ability to change, append and distribute current documentation and provides ready access to all who need it.It also provides the capability of positive acknowledgement that a document has been read and enforces acceptance through electronic signatures
15. OK so how do you get everybody to report incidents and occurences throughout the business.By year end Finnair all employees will have access to an electronic SMS solution to enable and track event identification and resultant corrective and preventative action
16. FAA Guidance says: The organization will establish and maintain a confidential employee safety reporting and feedback system as in Component Employees will be encouraged to use the safety reporting and feedback system without fear of reprisal and to submit solutions/safety improvements where possible.  Data from the safety reporting and feedback system will be monitored to identify emerging hazards. Data collected in the safety reporting and feedback system will be included in analyses
17. SMS guidance also mandates that confidential reporting maintain s the confidential nature of the reportingEnables people to report without fear of consequence (where appropriate)Yet these issues need to be acted upon, so the confidential reports need to be brought into the corrective/preventative action processes of the companyA good electronic SSMS will enable the use of the knowledge gained fron reporting yet protect the source
18. A good SMS solution enablesConfidential and normal reporting from everybody in the company including suppliers and third partiesIt will capture and manage all safety related eventsIty will provide a foundation for analysis, audit, corrective and preventative action and changeAnd most importantly it will engender a follow up capability that ensures, with minimum effort, that all identified and tasked items are in fact are completed and documented
19. Reiterating my comment from earlier, SMS is an informational challenge. All safety and risk related occurences need to be brought into a common platform for management, tasking and follow up.Information in silos are ineffective. If you have ASAP, FOQA, LOSA and other reporting mechanisms for your company, how can you gain a consistent, accurate and timely view of ALL the information you need for analysis and action. The management team needs to have a single view of the safety and risk profile of the organization at all times
20. The FAA guidance indicates:System descriptions and task analysis developed tothe level of detail necessary to:   a) Identify hazards  b) Develop operational procedures, and c) Develop and implement risk controls.Capabilities to identify risks associated: Reported and actualized incidents, manage them and provide corrective and preventative actionsYou need to create a single place where everything about the company related to safety and risk is maintained and is accessible to all (where appropriate). You need to bring together all the disparate pieces of the puzzle to gain a consistent and comprehensive view of the safety and risk profile. And you need to be able to report on any and all.
21. A good SMS provides a common information store for analysis and actionIt needs the ability to identify issues and initiate corrective and preventative action to ensure it is not repeatedAnd everybody needs visibility to their required action to ensure safety across the organization
22. Remember you need a single version of the truth to manage safety in any organization Everybody need to sing from the same songbook, and departmental differences and personalities need to be minimized
23. How do you prioritize your reaction to safety related challenges in your business
24. How do you prioritize corrective and preventative action.  Today gut feel is the prime decision criteria.  Q-Pulse enables fact-based decisioning.  By tying actual (estimated) cost to non-compliance the decisions become more fact-basedUse fact to determine the value of change, making decisions fact-based.  Provides and additional layer of decision making information to management Identifying and tracking cost besides enabling better decisions focus the entire management team’s view on doing the correct thing based on reality.  Most Part 135 operations especially outside maintenance are reactive and event-focused.  Q-Pulse forces management to base decisions on fact, and enables analysis to determine the best course of action based on the historical cost of non-compliance/conformanceIf closed loop processes were in place would we have had the accident?  Q-Pulse-  as a management tool to manage the ‘information’ about the business, its processes, and its people
25. How do you prioritize corrective and preventative action.  Today gut feel is the prime decision criteria.  Q-Pulse enables fact-based decisioning.  Identifying and tracking cost besides enabling better decisions focus the entire management team’s view on doing the correct thing based on reality.  Most Part 135 operations especially outside maintenance are reactive and event-focused.  Q-Pulse forces management to base decisions on fact, and enables analysis to determine the best course of action based on the historical cost of non-compliance/conformance
26. So how do you prove your approach to regulators and more importantly how do you ensure that you are operating safely – auditing is the key. Whether described as checklists, IEP’s SAS, or IOSA Audit questionnaire, auditing is critical to ensuring you are compliant to regulations and conformant to system safety principles
27. Organizations MUST monitor operational data Determine conformity to safety risk controls Measure the effectiveness of safety risk controlsAssess SMS system performanceIdentify hazardsLine management of operational departments MUST:Conduct regular internal audits of safety-related functions of the organization’s operational processes (production system)Conduct internal evaluations of:1. Operational processes SMS at planned intervals to determine that the SMS conforms to objectives and expectations2. Planning of the evaluation program will take into account: a) Safety criticality of the processes being evaluated, and The results of previous evaluations.3. The organization will define:a) Evaluations, including: (1) Criteria,(2) Scope, (3) Frequency, and(4) Methods;b) The processes used to select the evaluators; and c) Documented procedures, which include:The responsibilities
28. The issue in the US is the upcoming FAA mandate. Regulators analyze businesses based on the processes they have in place to ensure compliance to regulations and conformance to system safety principles.  That is, each carrier is unique.  The FAA oversight of each carrier is unique.  The issue under scrutiny is whether the Part 135 (or anybody) for that matter has the closed loop ‘systems’ in place to ensure follow-up and safe operations Conduct internal evaluations of:1. Operational processes SMS at planned intervals to determine that the SMS conforms to objectives and expectations2. Planning of the evaluation program will take into account: a) Safety criticality of the processes being evaluated, and The results of previous evaluations.3. The organization will define:a) Evaluations, including: (1) Criteria,(2) Scope, (3) Frequency, and(4) Methods;b) The processes used to select the evaluators; and c) Documented procedures, which include the responsibilities and Authorities
29. Auditing is critical and systemized approaches are necessary. Audit creation needs to be straight forward with easy-to-assign tasking and follow up. Audits generally raise questions which engenders further investigation. That investigation needs to be quickly and easily assigned and follow up
30. The last section of the FAA Guidance discusses the requirement to report things you are doing right and things that are not so right, but where action is in place to rectify the situation. Also reporting is critical to managing the safety environment at your company
31. So how do you report on all the things going on, on all the actions (corrective and preventative) on the status of everything. How do you do it cost effectively. The answer is to employ an effective electronic SMS. That electronic SMS needs to bring together al aspects of safety management. The SMS has to be accessible, effective, be able to minimize bad data, that incorporates analytics, and activity tracking. All aspects need to be reported on for effective management and to create a view of the operation’s SMS behavior at all levels.
32. The SMS has to be able to support inquiry from all aspects, fully and with no loss of captured information. It needs to be available and transparent (where appropriate) across the organization.You need one place to capture, store, analyze and report on safety throughout your company – and to include partners, vendors and regulators. You need one version of the truth for everybody
33. Q-Pulse provides the information platform to evaluate the risk profile across the company.  Eliminates information silos.  Engenders non-punitive reporting (event capture) Captures all aspects of the business.  Enables consistent reporting. Provides a single ‘version of the truth” about the operation, validation they are doing the right thing, gets the regulators off their backsIf closed loop processes were in place would we have had the accident?  Q-Pulse-  as a management tool to manage the ‘information’ about the business, its processes, and its peopleIncident reportingDocument managementAuditAssetPeople and credentialsTraining and competenceCorrective and preventative actionAnalyticsReportingAt a cost effective price