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SMS Data Management Challenges
A safety management system (SMS), just like a quality management system (QMS) or environmental management system (EMS) is not effective unless event data is collected, processed and managed correctly and in a timely manner. Aviation safety professionals are generally not data management experts yet they are tasked with making data-driven decisions that will impact the entire organization. Properly structured databases and file systems allow aviation service providers to access and mine data in the most efficient manner.
Following are some of more common data management challenges faced by aviation safety managers.
1) Reported issues are not submitted or classified properly. This problem affects organizations of all sizes. This phenomenon occurs in safety management programs when issues are not reported, reported issues are not made in accordance with accepted organizational procedures, or reported issues are not classified correctly. When issues are not reported, but simply "fixed," valuable data may be lost. Should managers wish to conduct research to analyze trends to discover ways to improve processes or safety, improper classification of safety issues would make any attempt to validate the assumptions questionable at best. Also, should an auditor or top management bring questions up regarding the validity of the research or aggregated reports, having the data improperly reported/classified will greatly increase the likelihood that the data has little to no value. However, one must not go to extremes and spend inordinate amounts of time generating large amounts of data while managing "trivial" issues. What may be important to one organization may be insignificant to another.
2) SMS data management is not supervised by trained safety managers. In this situation the safety manager might delegate his/her oversight responsibilities to someone else in the company that may not be adequately trained or qualified to assess risks and classify SMS related issues. Another situation might arise if the safety manager does not dedicate the appropriate time and effort to fulfill responsibilities related to proper data management. This may occur when the "safety manager" responsibilities are sidelined in favor of other "revenue-generating" activities.
3) SMS data not maintained in an accessible manner for authorized corporate users. This scenario impacts medium to large businesses more than smaller organizations. This situation often occurs in collaborative environments where all safety, security and compliance data is maintained by one individual, typically the director of safety or assigned safety manager. This situation becomes particularly problematical if each department, such as maintenance, security and flight ops is responsible for their own data management. In these cases, data is often stored on individual work stations or on file servers where access is limited by department. In other cases, managers might maintain data in their homes or on their personal laptops.
4) Safety, security, quality, compliance or administrative data not maintained properly by responsible personnel. The information is not maintained in sufficient detail, is inaccurately recorded, or not maintained in identifiable files. Regulating authorities (FAA), external auditors or reviewers would find this to be a serious breach of exercising appropriate responsibility regarding the proper management of safety related issues.
5) SMS data not stored properly. This commonly occurs with reported issues, audit findings, training and qualifications, and operational policy data. Careless storage of the data that could lead to the data being deleted or rendered unusable is a significant matter. Safety managers must ensure their organizational safety data is being backed up daily. In many cases, auditors find that aviation service providers and/or their safety managers have acted negligently, have not fulfilled their stewardship duties, and have violated contractual obligations. Best practices dictate that SMS data should be backed up regularly and stored in at least two geographically distinct locations.
6) SMS data retention policies not followed. Those involved with managing SMS data should have clear knowledge of how long different kinds of data must be retained to satisfy all compliance requirements and provide appropriate support in the event of lawsuits or disputes over incidents. Corporate or outside legal counsel is a good source for seeking help on crafting a data retention policy.
7) Company SMS data not in the control of the organization at all times. This is a major concern if a safety manager leaves a company and takes a copy of all the corporate SMS data and/or does not leave a copy of the safety information for the organization. This places the operator in an untenable position since it has neither fulfilled its regulatory compliance responsibility nor its duty to the stakeholders.
Safety managers need to understand these data management principles, regardless of whether they hire outside SMS consultants or manage their SMS data in-house. SMS Partners is available to assist your organization solve its data management challenges.
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SMS Gap Analysis Part 1
When an organization develops and implements an integrated, comprehensive safety management system (SMS) for its entire company, it needs to incorporate procedure(s) to identify and maintain compliance with current safety-related, regulatory, and other requirements. As part of the procedures, top management should define the organization's safety policy and convey its expectations and objectives to its employees. The following safety policy and objectives should be addressed as part of the SMS implementation plan. Other objectives such as key safety personnel and emergency preparedness and response will be covered in future editions of the SMS Partners newsletter.
1. Does the organization identify who is responsible for the quality of the organizational management processes (name, position, organization)?
2. Does the organization's SMS include the complete scope and life cycle of the organization's systems, including:
- Flight operations?
- Operational control (dispatch/flight following)?
- Maintenance and inspection?
- Cabin safety?
- Ground handling and servicing?
- Cargo handling?
- Training?
3. Does the organization require the SMS processes to be:
- Documented?
- Monitored?
- Measured?
- Analyzed?
4. Does the organization promote a positive safety culture?
5. Does top management ensure that the organization's quality policy, if present, is consistent with (or not in conflict with) its SMS?
6. Does the organization establish and maintain measurable criteria that accomplish the objectives of its safety policy?
7. Does the organization ensure the SMS complies with legal and regulatory requirements?
8. Does the organization ensure all SMS outputs are:
- Recorded?
- Monitored?
- Measured?
- Analyzed?
9. Does the company commit to having senior management be involved in the SMS?
10. Does top management define the organization's safety policy?
11. Is the safety policy documented?
12. Does the organization's safety policy include:
- Commitment to implement SMS?
- Commitment to continually improve the level of safety?
- Commitment to manage safety risk?
- Commitment to comply with all applicable regulatory requirements?
- Commitment to encourage employees to report safety issues without reprisal (non punitive reporting policy)?
- Clear standards for acceptable behavior?
13. Does the safety policy provide guidance to management on setting safety objectives?
14. Does the safety policy provide guidance to management on reviewing safety objectives?
15. Does the organization ensure the safety policy is communicated, with visible management endorsement, to all employees and responsible parties?
16. Does the organization identify and communicate management and individuals' safety performance responsibilities?
17. Does the organization have methods to periodically measure performance objectives and design expectations of the safety policy component?
18. Has top management defined the organization's safety policy and conveyed the expectations and objectives of that policy to its employees?
19. Does the organization ensure top management has the ultimate responsibility for the SMS?
20. Does the organization's top management provide the resources needed to implement and maintain the SMS?
21. Does the organization define levels of management that can make safety risk acceptance decisions?
22. Does the organization ensure that aviation safety-related positions, responsibilities, and authorities are:
- Defined?
- Documented?
- Communicated throughout the organization?
23. Does the organization periodically measure performance objectives and design expectations of the management commitment and safety accountability element?
Each organization should carefully consider how to manage the various and related SMS processes and components to ensure that there is a way to enable inputs from employees and a means to convey all the safety policy and communications. SMS Pro™ provides a comprehensive and cost effective web-based application that meets these objectives. To learn more about SMS Pro™ go to www.aviation-sms.com.
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