Safety Officer Teleconference (2)

The first topic discussed was the new 2014 IS-BAO protocol and audit report form. It and the revised Standards are available for download from the IBAC website. The question concerned how the new Form 8.2 within the Chapter 3 SMS section, has some new questions about Appropriateness and Effectiveness, which are marked with blue and green highlighting. Is this something that the operator fills out or the auditor fills out? On the call, Walter answered that these are questions that came from the old Form 8.1 SMS evaluation matrix and will normally be filled out by the auditor.

• I called Sonnie Bates with IBAC to verify my answer and it turns out I’m not entirely correct. Yes, some of these questions come from the old Form 8.1, but some of them are new and come from the most current ICAO Safety Management Manual (SMM) Doc 9859, Third Edition, 2013, and from a document called the Safety Management International Collaboration Group SMS Evaluation Tool (both available for download from our site at http://www.aeronomx.com/downloads.html).
• It also turns out that the operator should fill out answers and provided references to all of the questions in Chapter 3, including those in the blue and green shaded areas. During the onsite visit portion of the audit, after reviewing the operator’s answers, looking at documentation, and conducting employee interviews, the auditor may change the answer more to the way he sees it.
• Since this is a change to a new way of reviewing the SMS, there might be some awkwardness in providing answers and references. But you as the operator, do your best. You should have an opinion and a reason why you feel your SMS is appropriate and effective. If you don’t know, then you are missing the big point of safety assurance. Right?

The next topic concerned Hazard Reports. Or some operators may call it something else such as Safety Reports or similar. The question is, in regards to an SMS, how many is an appropriate number of hazard reports that should be reported in a given year? To start with, is there a meaning to what the number is? Yes, from two standpoints: 1st is from identifying hazards, the 2nd is getting buy-in and participation from your employees into the SMS. There is one clearly wrong answer, and that is zero reports. It indicates no participation. As to how many above zero is subject to the size and complexity of the flight department. Walter offered an opinion, as a point of reference, he uses the number of employees in the department should equal the number of reports in a year. For example, if you have 7 pilots, 2 mechanics, and 2 staff members, for a total of 11 employees, you should average a minimum of around 11 hazard reports a year. Sure some employees will fill out 2 or 3 and other will fill out none, but the average should work out. Of course there is going to be variations from company to company, but basically Walter is of the opinion, that as vigilant aviation professionals, we should be able to spot/experience and report at least one hazardous situation in a year. Walter has even seen some operators make it a requirement for employees to file a report each year, or each quarter, or even each month. This is meant to keep everyone vigilant and participating into the SMS. The counter-argument is that people might fill out frivolous reports.

Feed back from the callers included these comments:

• Required reports like this will “cheapen” the value of the hazard report.
• One commentator said their department uses mandatory Hazard Reports for data-collection purposes for a specific list of 10 or 12 things that have happened, such as go-arounds.

A related question was asked: How do you motivate employees to fill out Hazard Reports. Comments to this questions were:

• It is important to actually take action on the Hazard Report through the SMS with analyzing it, coming up with a corrective action, implementing the corrective action, and then following up later to review for effectiveness. If people see that the company responds to reports that are submitted, then they see it is worthwhile. If no action is taken, there is little motivation to fill out a report.
• One commentator said that he makes it a point as the Safety Officer to meet with a new employee soon after they are hired and talk with them about safety culture and the SMS. It is a sign of showing that safety is taken seriously here.

One caller mentioned that they are working on one area to improve their SMS and wanted to know if anyone else was doing something similar. What they are doing is when a Hazard Report comes in, their Safety Committee will give it an initial risk score from the risk matrix. They then analyze the cause, come up with a corrective action and implement. The new thing they are trying is to have a different group of individuals, ones other than the ones who did the initial scoring, then give the situation a new risk score from the matrix, to see if the mitigation is being effective. No one stated they were doing something similar, but comments were made that it sounded like a good idea.

One commentator mentioned that they are not really happy with the online SMS service that they have and was asking if anyone knows of an online SMS service that is perfect. Here are some of the responding comments:

• It is hard to find the perfect online SMS service. One size does not fit all. It is important to find a vendor that will listen to you and be willing to customize the SMS process to the way you like it.
• Walter mentioned if we were to take a poll among the callers, we would likely hear answers that included the top 10 or so services out there. I haven’t encountered the operator yet that is perfectly happy with their vendor provided SMS.
• One caller said they use PRISM and are generally happy with it but continue to work with ARGUS in fixing some of the processes.
• One caller said that they made their own. There are two Microsoft products, InfoPath and SharePoint that are good to use for this.
• One caller said they are the flight department to a bank and that none of the SMS vendors met the data security protocols for the bank, so they made their own.
• One caller said they use Fltplan.com and are happy with it.
• Walter would like to mention that you can access on the NBAA website, the Products and Services section will have a listing of vendors that provide online SMS services.
• Walter mentioned that it is an important point to ask your SMS vendor about data security. You are sharing sensitive information with an outside party. How do they make their website secure, from being hacked? How would they respond to a court subpoena for data? How would they segregate the data in responding to a subpoena if they were to provide the data, and keep my information safe and secure? I have encountered some flight departments that have had their SMS Hazard Reporting to go through their legal counsel’s office intending to give it some legal protection. In my opinion, the reporting in such situations was poor – who wants to tell the executive office that we “screw up”?

That concluded the call. It was 30 minutes in length. Next call is Tuesday, February 25th, at 11:30am Eastern time. Thank you for your participation. Please let other Safety Officers know of the opportunity to join the call or to access these meeting notes. Thank you.