Safety Management Systems

Safety Management Systems (SMS) is the term used by Transport Canada to refer to a new regulatory and enforcement framework for civil aviation. This new framework puts increased reliance on the aviation industry to cultivate a safety culture and in so doing enhance aviation safety. It is the only country in the world to introduce such a framework for the aviation industry. SMS has been criticized as a potential risk to civil aviation and the flying public due to its reliance on whistleblowersFact|date=September 2008.

Description of SMS

SMS is defined by Transport Canada 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. [ [http://www.tc.gc.ca/civilaviation/SystemSafety/Pubs/tp13739/menu.htm Transport Canada publication TP 13739] ]

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 [ [http://www.tc.gc.ca/civilaviation/RegServ/Affairs/cars/Part1/107.htm Canadian Aviation Regulations] ]

Implications

From a regulatory perspective, SMS mark a move away from prescriptive regulations (in which regulatory requirements are set out in detail, and require strict adherence to specific criteria) to performance-based regulations (in which the objective is set out, and the regulated entity is only measured against achievement of the objective). [ [http://www.tc.gc.ca/civilaviation/SMS/FAQ/Regulations/Q3.htm Transport Canada SMS FAQ] ] In practical terms, it will require that the aviation industry institute policies and systems designed to reduce risk, such as by implementing reporting systems for the reporting and correction of shortcomings. Transport Canada inspections will have "a change of emphasis from direct operational oversight to oversight of the organizational systems and their effectiveness." [ [http://www.tc.gc.ca/civilaviation/SMS/FAQ/General/Q3.htm Transport Canada SMS FAQ] ] Organizations deemed to have effective SMS can expect fewer inspections. [ [http://www.tc.gc.ca/civilaviation/SMS/FAQ/Assess/Q2.htm Transport Canada SMS FAQ] ]

While acknowledging that achieving cultural change within organizations will be a challenge [ [http://www.tc.gc.ca/civilaviation/SMS/FAQ/Implement/Q4.htm Transport Canada SMS FAQ] ] , and that success is largely dependant on success in achieving that change, [ [http://www.tc.gc.ca/civilaviation/SMS/FAQ/Regulations/Q2.htm Transport Canada SMS FAQ] ] Transport Canada is confident that the new system will supplement the current regulatory framework, increasing the safety of civil aviation.

The Implementation of SMS

Transport Canada began implementing SMS in 2005. [ [http://www.tc.gc.ca/CivilAviation/SMS/implementation.htm Transport Canada SMS Implementation Timeline] ] With the introduction of Bill C-7, an "Act to Amend the Aeronautics Act", [ [http://www.parl.gc.ca/common/bills_ls.asp?lang=E&ls=c7&source=library_prb&Parl=39&Ses=2 "Act to Amend the Aeronautics Act"] ] Transport Canada has begun the final phase toward implementing SMS. Planned next steps will include certification of civil aviation participants in 2009 and full implementation by 2010. [ [http://www.tc.gc.ca/tcss/StrategicPlan/Appendix-A/4/menu.html Transport Canada Strategic Plan] ]

Criticism of SMS

Lack of 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 Transport Canada is neglecting these responsibilities, at the cost of human lives. [ [http://www.pej.org/html/modules.php?op=modload&name=News&file=article&sid=7345 Peace, Earth and Justice News] ] The whistleblower 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." [ [http://cmte.parl.gc.ca/Content/HOC/Committee/391/TRAN/Evidence/EV2940197/TRANEV51-E.PDF Standing Committee on Transport, Infrastructure and Communities minutes dated May 14, 2007] ]

The Canadian Association of Journalists [ [http://www.eagle.ca/caj/ Canadian Association of Journalists] ] nominated Transport Canada for its Secrecy Award for a second time, indicating that the Bill will cause "a veil of secrecy [to] fall over all information reported by airlines about performance, safety violations, aviation safety problems and their resolution." [ [http://micro.newswire.ca/release.cgi?rkey=1605254106&view=42015-0&Start=0 Canadian Association of Journalists press release] ] Similar oversight issues are touted as the cause of crashes and other disruptions in the United States, with the FAA receiving the blame. The U.S. Department of Aviation's inspector general stated that "it appears FAA management fostered a culture whereby air carriers were considered the primary customer of its oversight mission instead of the flying public." [ [http://www.dailyherald.com/story/?id=215397&src= Chicago Daily Herald] ]

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 the new rules 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. [ [http://www.cbaa.ca/portal/comm/news/allan-cutler-whistling-in-the-dark/?searchterm=cutler, "Whistling in the Dark", Ottawa Citizen] ]

Other Criticisms

Other criticisms have also been raised regarding SMS:

* Risk assessments are performed by the company being regulated, [ [http://www.tc.gc.ca/civilaviation/SMS/FAQ/Assess/Q4.htm Transport Canada SMS FAQ] ] , potentially leading to a conflict of interest.
* SMS may be biased towards large companies that are better able to implement and absorb costs associated with SMS. [ [http://www.tc.gc.ca/civilaviation/SMS/FAQ/Benefits/Q2.htm Transport Canada SMS FAQ] ]
* No formal risk assessment was conducted into SMS principles, [ [http://www.tc.gc.ca/civilaviation/SMS/FAQ/General/Q5.htm Transport Canada SMS FAQ] ] and no other country has implemented SMS, leading to concerns that Transport Canada is unaware of the long-term costs, both in human and financial terms, of the new approach.

References

ee also

* Safety
* Civil Aviation
* International Civil Aviation Organization
* Transport Canada

External links

* [http://www.tc.gc.ca/CivilAviation/SMS/menu.htm Transport Canada SMS Site]