Part 3
SAFETY MANAGEMENT SYSTEMS
DRAFT
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Part 3 DRAFT Chapter 12 - Establishing A Safety Management System
Chapter 12
ESTABLISHING A SAFETY MANAGEMENT SYSTEM
Outline
INTRODUCTION
TEN STEPS TO SMS
1. Planning
a) Review
b) Safety assessment
c) Performance indicators and safety targets
d) Strategy
e) The plan
2. Senior Management’s Commitment to Safety
a) Policy
b) Objectives
3. Organization
a) Safety manager
b) Organizational structure
c) Responsibilities and accountabilities
d) Safety committee
e) Training and competence
4. Hazard Identification
5. Risk Management
6. Investigation Capability
7. Safety Analysis Capability
8. Safety Promotion and Training
9. Safety Management Documentation and Information Management
10. Safety Oversight and Performance Evaluation
Appendices
1. Sample safety policy statement
2. Suggested topics to be included in a CEO statement on safety commitment
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Chapter 12
ESTABLISHING A SAFETY MANAGEMENT SYSTEM
INTRODUCTION
Effective safety management requires a systems approach to the development of safety policies, procedures and practices such that the organization will achieve its safety objectives. As in other management functions, safety management requires planning, organizing, communications and direction. Safety management integrates diverse activities into a coherent whole for accident prevention. Follow-up will be required to evaluate and validate the effectiveness of the organization’s safety management practices, thereby closing the system safety loop.
There are several ways of meeting an organization’s needs for safety management. There is no single model that “fits all”. Size, complexity, and the type of operation, as well as the corporate safety culture and operating environment, will influence the structure most suited for individual organizations and their unique circumstances. Some organizations will require a formal Safety Management System (SMS) (as described in Chapter 5 – Basics of Safety Management). Others may require most of the same functions to be performed, but perhaps with a less structured approach. They may also face resource limitations and be able to carry out only selected safety management activities. Accordingly, this chapter will focus on establishing a Safety Management System. The degree of formality and rigidity in the SMS should be a reflection of the organization’s needs, rather blind adherence to doctrine.
Whether or not a formal SMS is required, starting and operating an effective processes for safety management can be a daunting task. Taking a systems approach will help ensure that the elements necessary for building an effective system are present. Following are ten steps for integrating the various elements into a coherent safety management system (SMS). It would be an overwhelming – if not impossible – task to implement all functions of an SMS simultaneously. Rather, the steps may be addressed gradually – in manageable proportions. This would allow the organization to adopt and become acquainted with the requirements and results at each step before proceeding.
Much has been and will be said about the importance of the corporate safety culture. Corporate attitudes towards safety may require adjustment in order that plans for a SMS can proceed smoothly.
While there is certain logic to the sequence of the steps as outlined, it is not prescriptive. Particular steps may be delayed, pending a more suitable time. As the various steps are implemented, this Chapter provides a confirmation checklist at each step to highlight the necessary actions.
TEN STEPS TO AN SMS
1. PLANNING
Consistent with general management practice, safety management begins with careful planning. An organization striving to improve its safety management processes may be well served by appointing a group of key line managers (and the person most likely to be designated the organization’s Safety Manager) to conduct this planning phase.
a) Review
The planning group may be able to build upon existing strengths by taking stock of the organization’s current capabilities for safety management (including experience and knowledge, processes and procedures, resources, etc.). Shortcomings in safety management experience must be recognized and resources to assist in development and implementation of the SMS identified. On the other hand, many operational units already have internal procedures in place for the investigation of incidents, hazard identification, safety monitoring, etc. These should be reviewed and perhaps modified for integration within the SMS. It is important that the organization re-use as many existing procedures as practicable, as there is no need to replace known and effective procedures and processes. By building on such an experience base, the development of a SMS will be less disruptive. During this review process, the planning group should also examine best industry practices for safety management, consulting with other organizations of similar size and mission.
b) Safety assessment
The design and implementation of a SMS will likely be a major change to the organization, capable of generating new safety hazards. One tool that may assist the planning group at this time is the safety assessment (as described in Chapter 13 – Safety Assessments). The synergy of a group of experienced managers systematically questioning and challenging all aspects of the organization’s current and planned approach to safety management, should reduce the risk of surprises in implementing the SMS, enhance the group’s knowledge of the current situation and requirements, and prepare the way for effectively implementing change.
c) Performance indicators and safety targets
The planning group should define safety performance indicators and set safety performance targets for the organization (as discussed in Chapter 5 – Basics of Safety Management). These indicators and targets must be realistic – taking account of the organization’s size, complexity, type of operations, resource base, etc. A realistic time line for the planned changes necessary for meeting these targets must also be agreed. Even though setting these indicators and targets may be difficult, they provide the basis for evaluating the success of the SMS.
d) Strategy
Based on the agreed safety targets above, the planning group can develop a realistic strategy for meeting those needs. The strategy should probably combine both reactive and proactive elements (as described in Ch 5 – Basics of Safety Management). Consideration should be given to the types of safety processes and safety activities that will be sought (as outlined in the following steps). Dependent on the number of new initiatives being considered and resource availability, a phased approach may be desirable. The strategy may also define the degree of formality the organization requires with respect to its “system for managing safety”. Senior management’s input is required during the development of the strategy.
e) The plan
The planning phase should result in a detailed plan for the development and implementation of the SMS. Typically the planning time frame will be one to three years ahead. The plan should consider such aspects as: safety objectives, safety strategy, safety management processes and activities, resource implications and timelines.
2. SENIOR MANAGEMENT’S COMMITMENT TO SAFETY
The ultimate responsibility for safety rests with the directors and senior management of the organization. The whole ethos of an organization’s attitude to safety – its safety culture – is established from the outset by the extent to which senior management accepts responsibility for safe operations, particularly the proactive management of risk.
Regardless of the size, complexity, or type of operation, the success of the SMS depends on the extent to which senior management devotes the necessary time, resources and attention to safety as a core management issue. Here, actions speak louder than words. What management visibly does for safety will determine the safety culture (and hence the safety performance) of the organization.
Safety policies and objectives set out what the organization is striving to achieve, and how it is going to get there. Management’s commitment to safety is first demonstrated to all personnel of the organization through its stated safety policies and objectives.
a) Policy
Management’s commitment to safety should be formally expressed in a statement of the organization’s safety policy. This should reflect the organization’s philosophy of safety management and become the foundation on which the organization’s safety management system is built. The safety policy outlines the methods and processes the organization will use to achieve desired safety outcomes. They serve as reminders as to “how we do business around here”. The creation of a positive safety culture begins with the issuance of clear, unequivocal direction
A safety policy may take different forms, but will typically include statements concerning:
- the overall safety objective of the organization;
- the commitment of senior management to the goal of ensuring that all aspects of operation of the system meet safety performance targets;
- a commitment by the organization to a proactive and systematic approach to the management of safety;
- a commitment by the organization to making the maintenance of safety its highest priority; and
- the organization’s policy concerning responsibility and accountability for safety at all levels of the organization.
The policy statement should be a written document, issued under the authority of the highest level of management of the organization, and should be communicated to all staff. A sample corporate safety policy is included at Appendix 1 to this chapter. This statement presents a tangible indication of senior management’s commitment to safety. An alternative to this type of safety policy is a statement of commitment by the CEO to the maintenance of the highest standards of safety. An example of topics that might be included in a CEO’s statement of commitment to safety is included at Appendix 2 to this chapter.
In preparing a safety policy, senior management should consult widely with staff. Consultation ensures that the document is relevant to staff, giving them a sense of ownership in it. Corporate safety policy must also be consistent with relevant State regulations.
b) Objectives
Related closely to safety policy (and safety culture) is how an organization sets its objectives. Clearly stated objectives can lead to a commitment to action that will enhance the safety of the organization. In some organizations no explicit safety objectives are stated. A few exceptional organizations set their objectives formally, clearly enunciating their vision, defining desired outcomes, spelling out the attainable steps for meeting the objectives, and documenting the process. They have agreed to relevant safety indicators and have adopted realistic safety targets.
3. ORGANIZATION
How an organization arranges its method of doing business and managing safety will influence its resilience to misadventure and its ability to reduce risks. Several considerations are fundamental to establishing an effective organization that will support the SMS. For example:
— Appointment of a Safety Manager;
— Determination of organizational structure for safety;
— Statement of responsibilities and accountabilities;
— Creation of a Safety Committee and
— Training and competency
a) Safety Manager (SM)
One of the first tasks in establishing a safety management system is to appoint a safety manager. Safety management activities need a focal point (or champion) as the driving force for the systemic changes necessary to effect safety across the entire organization. The function is best accomplished by the appointment of a full-time Safety Manager whose responsibility is to promote safety awareness and ensure that the prevention of accidents is the priority throughout all divisions and departments in the organization.
Safety management is a responsibility shared by each line manager, supported by the Safety Manager. Specific safety activities are the line managers’ responsibility. Senior management must not hold the SM accountable for line managers’ responsibilities; rather the SM is accountable for rendering effective staff support for all line managers to ensure the success of the organization’s safety management system. While the SM may be held accountable for any deficiencies in the safety management system itself, the SM should not be accountable for the safety performance of the organization.
Ideally, the SM should have no responsibilities other than safety. This would generally be the case in large organizations where a full time SM position can be justified. In smaller organizations, safety management may have to be the responsibility of a manager who also has other duties. It would be preferable, in such cases, that the person responsible for safety management did not also have direct responsibility for any of the operational or engineering areas, to avoid possible conflicts of interest. Whether the SM position is a full time one, or forms only part of the responsibilities of the designated manager, the duties and responsibilities of the position will be the same. Regardless, the SM is a member of the overall management team of the organization, and needs to be at a sufficiently high level in the management hierarchy to ensure that he or she can communicate directly with other senior managers.
The SM should be responsible for managing all aspects of the operation of the safety management system. This would include ensuring that safety documentation accurately reflects the current environment, monitoring the effectiveness of corrective actions, providing periodic reports on safety performance, and providing independent advice to the Chief Executive, senior managers and to other personnel on safety-related matters.
An example of the Terms of Reference for a Safety Manager is included at Appendix 1 to Chapter 15 (Practical Considerations for Operating an SMS).
b) Organizational structure
Two different approaches to organizational structures that are consistent with the requirements for assuring both safety and efficiency are outlined below. Both are designed to support a coherent “safety management system”. The solid lines represent formal reporting relationships, whilst the broken lines represent informal lines of communication.[1]
Figure 12-1. Organization for safety management: Sample A
The sample organization in Figure 12-1, Sample Organization A, is typical of many companies with good safety records. The Flight Safety Officer (FSO) reports directly to the Director of Flight Operations. However, the FSO does not have responsibilities for accident prevention in other departments. To cover considerations of safety in maintenance, a Maintenance Quality Assurance Manager (reporting directly to the Director of Maintenance) coordinates informally with the FSO through the “safety office”. Although the organization chart depicts an informal reporting relationship from the Safety Office to the executive level, this structure does not promote a truly systems approach to safety management. Rather, the organization focuses on safety issues from the perspectives of flight operations and maintenance, only.