Safety Management Systems (SMS) is the term used to refer to certain regulatory and enforcement frameworks. These frameworks generally apply to transportation, but have also been explored in other industries. An SMS is the specific application of quality management to safety.
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[edit] Description of SMS
SMS is a management system used to manage all aspects of safety throughout an organization. It provides a systematic way to identify hazards and control risks while maintaining assurance that these risk controls are effective.[1] SMS has been defined as:
...a businesslike approach to safety. It is a systematic, explicit and comprehensive process for managing safety risks. As with all management systems, a safety management system provides for goal setting, planning, and measuring performance. A safety management system is woven into the fabric of an organization. It becomes part of the culture, the way people do their jobs.[2]
Each industry has various reasons for adopting SMS. For example, the global aviation accident rate has remained at a relatively flat rate for nearly 30 years.[3] If growth projections for air transportation are met, there will be a major aviation accident each week in the future and the industry will suffer increasing numbers of serious accidents in the years to come.[4] If the existing system is no longer able to improve on passenger safety, then it is logical to develop new systems.
Safety Management Systems drive cross-functional cooperation in anticipation of continuous improvement in safety.
[edit] Regulatory Perspective
[edit] SMS Implications
SMS is intended to support a move away from prescriptive regulations (which specify criteria that must be adhered to) toward performance-based regulations which describe objectives and allow each regulated entity to develop its own system for achieving the objectives. In other words, industry must develop its own policies and systems to reduce risk, which should include implementing systems for reporting and correcting shortcomings. The regulator then changes its emphasis from verifying adherence to the criteria to examining the organizational systems and their effectiveness.
While SMS is an important advance in safety management, it is only as good as its implementation. SMS means that organizations need to ensure they are looking at all the risks within the organization as a single system, rather than having multiple, competing, ‘Safety Management Silos.’[5] If safety is not seen holistically, it can interfere with the prioritization of improvements or even result in safety issues being missed. For example, in March 2005, BP's Texas City Refinery (BP) exploded, killing and injuring nearly 100 people. The investigation concluded that the company had put too much emphasis on personal safety thus ignoring the safety of their processes.[6] The antidote to such silo thinking is the proper evaluation of all risks, a key aspect of an effective SMS.[7]
[edit] Implementation
[edit] International Adoption of SMS
Several international organizations require member nations to adopt SMS. As discussed above, the International Civil Aviation Organization is one such organization. ICAO has recommended that all aviation authorities implement SMS regulatory structures.[8] ICAO has provided resources to assist with implementation. Canada is one of the countries that has introduced an SMS framework for the aviation industry.
The International Maritime Organization (IMO) is another organization that has adopted SMS. All international passenger ships and oil tankers, chemical tankers, gas carriers, bulk carriers and cargo craft of 500 gross tons or more are required to have a Safety Management System.[9] In the preamble to the International Safety Management (ISM) Code, the IMO states, “The cornerstone of good safety management is commitment from the top. In matters of safety and pollution prevention it is the commitment, competence, attitudes and motivation of individuals at all levels that determines the end result.”[10]
[edit] Corporate Implementation of SMS
Many corporations have adopted SMS to enhance their own operations. For example, the Bristow Group, a helicopter services company, has its own SMS. The process is summarized as “a simple, practical but powerful four-element model based on three processes that feed a fourth.” The three processes are risk management, monitoring, and safety reporting and investigation. These three processes combine to provide the fourth process, integrated insight into operations. Insight is the means bywhich management reviews their operations and ensure they make full use of all predictive, proactive and reactive activities and deliver the right improvement actions.[5]
[edit] United States Implementation of SMS
The United States has introduced SMS for airports through an advisory circular[11] and other guidance.[12]
The United States announced at the 2008 EASA/FAA/TC International Safety Conference that they would be developing regulations to implement SMS for repair stations, air carriers, and manufacturers. The FAA has formed a rulemaking committee to address the implementation. Currently, the FAA is supporting voluntary pilot projects for SMS.[13]
[edit] Indian Implementation of SMS
The Bangalore International Airport published a safety management system in 2007.[14]
[edit] European Implementation of SMS
The EU document Guidelines on a Major Accident Prevention Policy and Safety Management System requires an SMS. The Directive is aimed at the prevention of major accidents involving dangerous substances, and the limitation of their consequence.[15]
[edit] Canadian Implementation of SMS
Since 1999, SMS implementation has been a key priority for Transport Canada, the regulatory and oversight authority for inter-provincial and international rail, marine and aviation transportation safety and security. SMS has been in place for the Canadian rail industry since 2001, while the formal implementation of SMS in aviation began in 2005.
[edit] Rail
Transport Canada’s Rail Safety Directorate incorporated SMS into the rail industry in 2001. The Rail Safety Management System requirements are set out in the Railway Safety Management System Regulations.[16] The objectives of the Rail Safety Management System Regulations are to ensure that safety is given management time and corporate resources and that it is subject to performance measurement and monitoring on par with corporate financial and production goals.[17]
The effect of SMS in the rail industry has not been positive as a 2006 study indicated that rail accidents were soaring.[18] Critics have argued that this evidence should preclude the adoption of SMS in the aviation sector.[19]
[edit] Aviation
An SMS approach to safety for civil aviation in Canada has been under development since the mid-1990s.[20] Transport Canada provides some flexibility to industry so that they may tailor the safety management system to meet their unique operating requirements, but expects the company to measure how well the system works. However, the system must still meet the requirements set out in the regulations.
Canadian Aviation Regulations specify that SMS is "a documented process for managing risks that integrates operations and technical systems with the management of financial and human resources to ensure aviation safety or the safety of the public", and should include
- a safety policy on which the system is based
- a process for setting goals for the improvement of aviation safety and for measuring the attainment of those goals
- a process for identifying hazards to aviation safety and for evaluating and managing the associated risks
- a process for ensuring that personnel are trained and competent to perform their duties;
- a process for the internal reporting and analyzing of hazards, incidents and accidents and for taking corrective actions to prevent their recurrence
- a document containing all safety management system processes and a process for making personnel aware of their responsibilities with respect to them
- a process for conducting periodic reviews or audits of the safety management system and reviews or audits for cause of the safety management system
- any additional requirements for the safety management system that are prescribed under these Regulations[21]
Transport Canada is responsible for the inspection of aviation operations to ensure that they meet safety regulations. Under the new SMS scheme, Transport Canada will conduct audits to determine whether a safety management system is in place and is working. However, critics have noted that
As part of the changes, a federal program to audit airline safety procedures has been cancelled and Transport Canada intends to stop regulating the frequency of inspections. Transport Canada inspectors won't enforce safety regulations for companies with their own safety management systems. They will simply inspect safety reports written by the companies themselves.[19]
This concern underlines the perceived gap between ICAO's intended use of SMS as an additional layer of safety, and Transport Canada's apparent use of SMS as a replacement of mandated safety inspections. Transport Canada denies that this is the case, however.[22]
Concerns about Canadian implementation of SMS sparked an Air Safety Round Table discussion on April 21, 2009, held on Parliament Hill. A new website, Safe Skies, aims to provide Canadians with access to the discussions and related documents, and provides a gathering point for concerned citizens.
[edit] Purported Benefits of SMS in Canada
Proponents of SMS argue that SMS not only benefits passengers by way of safer and more secure transit, but industry as well. A successful SMS enables organizations to better comply with regulations and other requirements, minimizing the likelihood of an adverse event. SMS also improves employee and passenger health and safety through early identification of risks and potential hazards. And finally, SMS positively impacts staff by creating trust, increased morale, which all leads to improved performance. Employees involved in their own safety are generally more conscientious, more productive and have less absenteeism.
[edit] Criticism of SMS in Canada
[edit] Need for Strong Enforcement Capacity
Critics of SMS have argued that for it to work, it is critical that regulatory oversight be constant and effective. They argue, however, that there is considerable evidence that in Canada Transport Canada is neglecting these responsibilities, at the cost of human lives.[23] Hugh Danford, a former bush pilot and Transport Canada Civil Aviation Inspector, testified before the Standing Senate Committee on Transport, Infrastructure and Communities on May 14, 2007:
It appeared to me that management's main concern was to get out of the enforcement business and the liability issues inherent in that responsibility… Of the 20 Canadian crashes, 25% had a root cause of 'lack of regulatory supervision'. This was not our interpretation; this information was quoted from TSB reports... I think the SMS concept is workable, but it can only work if there is a strong enforcement component. I get nervous when reports are mandatory and confidential."[24]
However, during testimony during the same Standing Senate Committee on Transport, Infrastructure and Communities hearing on May 14, 2007, noted above, Mr. Franz Reinhardt, Transport Canada’s director of policy and regulatory services (now retired), responded to criticisms about enforcement capacity by noting that "People will continue to be subject to safety oversight in the future, even in an SMS context. In fact, inspectors will then be on site to ensure compliance with the rules and standards." In terms of whistleblower protection, the change to a safety culture will offer significant protection to anyone noting shortcomings.
[edit] Reliance on Internal Reporting
In addition to enforcement capacity concerns, there are concerns about the reliance on internal reporting of safety issues and violations. Given that the success of SMS relies on corporate culture, it has been argued that without strong whistleblower protection, it would be impossible to effectively implement SMS. In Canada, unions and whistleblower advocates have argued that proposed new rules would provide little whistleblower protection, leaving aviation industry employees vulnerable if they report shortcomings at the wrong time, to the wrong manager and in the wrong culture.[25]
Proponents, however, argue that identification of the accountable executive within the regulated company is an important way to encourage the reporting culture that is at the heart of the SMS. This individual acts to promote the cultural change that leads to a safety culture.[20]
[edit] No Risk Assessment Performed Prior to Implementation
Critics have also noted that while SMS is intended to be a risk assessment tool, Transport Canada conducted no risk analysis prior to implementing SMS in the aviation sector.[26]
[edit] See also
[edit] References
- ^ http://www.faa.gov/about/initiatives/saso/library/media/SASO_Briefing_Managers_Toolkit.pdf SASO Outreach, Spring 2009
- ^ Transport Canada publication TP 13739
- ^ Francis, Robert T. II. 1997. Aviation accident investigation methods and boundaries. Pp. 15-17 in Aviation Safety, H. Soekkha (ed.). VSP BV. Available through Google Books
- ^ Wells, Alexander T. and Clarence C. Rodrigues. 2004. Commercial Aviation Safety, 4th edition. McGraw-Hill Books. NY, NY. Available through Google Books
- ^ a b http://www.skybrary.aero/index.php/Beyond_Safety_Management_Systems Evans, Andy and John Parker. May 2008. Beyond Safety Management Systems. Pp. 12-17 in AeroSafety World.
- ^ http://sunnyday.mit.edu/Baker-panel-report.pdf Baker Report
- ^ ibid.
- ^ [1] Implementation of the State Safety Programme (SSP) in States (13 November 2008)
- ^ http://www.imo.org/humanelement/mainframe.asp?topic_id=287 International Safety Management (ISM) Code 2002.
- ^ http://www.admiraltylawguide.com/conven/ismcode1993.html The International Safety Management Code IMO Assembly Resolution A.741(18) – 1993.
- ^ Advisory Circular 150/5200-37 INTRODUCTION TO SAFETY MANAGEMENT SYSTEMS (SMS) FOR AIRPORT OPERATORS (February 28, 2007)
- ^ A list of guidance and supporting information can be found on the FAA website.
- ^ http://www.faa.gov/about/initiatives/saso/library/media/SMS_Brochure.pdf
- ^ Bangalore International Airport Safety Management System Manual.
- ^ http://mahbsrv.jrc.ec.europa.eu/GuidanceDocs-SafetyManagementSystems.html N. Mitchison, S. Porter (Eds). 1998. Guidelines on a Major Accident Prevention Policy and Safety Management System, as Required by Council Directive 96/82/EC (Seveso II)
- ^ http://laws.justice.gc.ca/en/showdoc/cr/SOR-2001-37//20090805/en?page=1
- ^ http://www.tc.gc.ca/eng/railsafety/publications-tp13548-267.htm
- ^ Freight train accidents soar
- ^ a b New rules for aviation safety a flight plan to disaster, critics warn
- ^ a b http://www.wingsmagazine.com/content/view/505/67/
- ^ http://www.tc.gc.ca/civilaviation/RegServ/Affairs/cars/Part1/107.htm
- ^ Transport Canada FAQ: Requirement for audits remains
- ^ Peace, Earth and Justice News
- ^ Standing Committee on Transport, Infrastructure and Communities minutes dated May 14, 2007
- ^ "Whistling in the Dark", Ottawa Citizen
- ^ Transport Canada FAQ: No risk analysis required prior to implementation
