Safety Management Systems, or SMSs, are a fundamental building block of aviation’s neverending quest to improve safety. Following a full round of adoptions of new proposals at the 41st ICAO Assembly, we sat down with Henry Gourdji, the Flight Safety Foundation’s director for safety strategy and policy, for a wideranging discussion on what the FSF learned from its research into SMSs to feed into the agenda — and what surprised them.
The Flight Safety Foundation (FSF) research, summarised in its report to the Assembly Outcomes from the Global Safety Assessment Project [PDF], covered a wide variety of airlines in almost every region of the world.
“Overall,” Gourdji tells us, “I think we were quite encouraged that the industry was quite resilient, and it’s with the maturity of SMSs, I think — that’s why they’ve done so well during the pandemic, including the smaller operators.”
Gourdji explains that the foundation “partnered with the airline associations around the world — in Asia and Africa and South America. The only region that we did not was in Europe, and only because Europe with EASA were already quite mature and getting a lot of their oversight or surveys done by EASA at that point in time.”
The initial goal, set before the COVID-19 pandemic, was to validate the maturity of SMSs as a structure, as well as its implementation by the industry and its oversight by regulators.
The issue the FSF wanted to test, Gourdji says, was “not just theory: how are they applying SMSs, especially during the pandemic? That was very enlightening to see. We were able to gauge the levels of maturity of an air operator’s SMS. At the same time, how was the regulator overseeing the operator? How are they dealing with the exemptions and the extensions? We were able to gauge that as well, based on the responses to surveys and based on the interactions from the workshops.”
The pandemic context was particularly useful for gauging adaptability
“We know that SMSs vary by operators,” Gourdgi explains. “Larger operators, for the most part, put in their SMSs way in advance many years earlier — SMSs have been around for well over a decade.”
The fact that the research was undertaken within the context of the first major pandemic in the existence of commercial aviation was particularly enlightening when it came to smaller operators, however.
“We wanted to look at special operations, air ambulance, offshore operations, smaller carriers, not necessarily international — it could be domestic. How did they manage?” Gourdji continues. “We were surprised: they actually did quite well.”
Critical to the successful implementation of an SMS is its live nature: as live documentation, as live processes, in response to live events — and, often, live in the middle of operations as externalities are occurring.
“What we found is that during a pandemic, change was a constant. Change was almost on a weekly basis — I don’t want to say daily basis, but they had to adjust based on every country coming up with new regulatory requirements,” Gourdji says.
As just one example, for flight operations, less traffic meant changes in routes, which meant changes in approaches, and thus changes in standard operating procedures and manuals.
“We found,” Gourdji continues, “that many operators can tick the box by saying: yes, we we’ve taken the regulations of the state and we’ve implemented SMSs.”
But questions remained: how well has that SMS been implemented and embedded? How often was it reviewed and updated?
“Those operators who have really matured were reviewing their assessments and the risk assessments, in some cases, on a monthly basis or weekly basis, while others kept it kept it at every six months or every year,” Gourdji says.
Implementing the best of SMSs at all operational scales is critical
At its most basic, an SMS is a set of principles and components, scaled to the higher end of complexity: large international carriers operating a wide variety of aircraft across multiple regulatory contexts and into hundreds of jurisdictions, coordinated internationally by ICAO as a UN body, implemented by states.
“ICAO comes up with requirements and states do everything possible to meet those requirements: they come up with one standard,” Gourdji explains. “ICAO only deals with international — they don’t deal with domestic — although they encourage you [the regulating state] to take those requirements and make your domestic requirements as well. But nothing prevents domestic from having a two tier system — simplify it for domestic operations, for smaller operations.”
In some cases, especially within larger more developed countries, this occurs. European countries regulated by EASA are an example, as are the US, Canada, Australia and the UK. But the very long tail of smaller countries — the majority of jurisdictions by number — adopt ICAO’s requirements for all operators.
This, Gourdji suggests, can be adapted for scale: “You’re not going to change the components of SMS: you’ll still have safety policy and objectives you need to have, you need to put in safety, risk management, safety assurance and promotion. The key processes, safety management, hazard identification, occurrence reporting, risk management, performance management, quality assurance — capture them. But you can simplify, you don’t have to bring in everything that ICAO calls for. It doesn’t have to be a very thick document on how to manage an SMS. This is one of the recommendations that came out of the report.”
Cooperation and best practice will be vital for the digital future
Implementing the SMS principles at scale is itself complex, but sharing best practice is standard within the industry, with centres of excellence within larger and more experienced state regulators and the ICAO Technical Cooperation Bureau on hand to assist.
Much digital software is available, although there is not yet a specific digital standard beyond ICAO Annex 19 and its guidance — there is no delivery certification, ISO standard or kitemark here.
Whatever approach is taken, Gourdji emphasises, it’s important to understand that an organisation has to embed safety culture within itself: “that doesn’t come by just bringing in a consultant. But you can bring in the pieces, the reporting, identifying risks, and how you’re going to do that. But you’re going to have to train all the staff from the top down — training and understanding about safety reporting.”
The space where digital regulation, certification and safety interact is certainly one to watch for the future.
“I think the biggest challenge,” Gourdji says, “is that the industry is moving so quick with this, technology is advancing so quick. It’s the regulators and ICAO who have to keep up with it. They have to support it, and they have to regulate it, but they can’t hold [the industry] back.”
New technologies and implementation methods including cloud computing, APIs, automation of safety management tasks, incident management, employee risk management and operations all need to be incorporated in a way that is consistent with an organisation’s SMS.
As one example, Gourdji says, “we have algorithms that can analyse vast amounts of data from various sources. We’re seeing that for weather, weather patterns, aircraft performance, maintenance records — that helps us identify potential safety risks and provide some proactive solutions.”
And there’s more to come as technology accelerates.
“The rapid progress that we’re seeing in artificial intelligence, machine learning, data analytics… SMSs will become more sophisticated: sophisticated in identifying the potential safety hazards, analysing data, and predicting safety risks,” Gourdji expects.
Published 13 July 2023
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