The first topic discussed was from a presentation that Walter gave at the HAI Helicopter Convention called “The Best Safety Device is a Good Manager” (a copy of slides available for download from the AeronomX website. What does a Safety Officer do if he or she has a flight department manager that is not fully supportive, or worse yet, opposed to safety management efforts?
o One caller said that his Chief Pilot submitted a hazard report on which he also wrote the suggested solution to what happened. When the Safety Officer and Safety Committee received the report for analysis, they were of the opinion that to implement the suggestion the Chief Pilot provided would have increased risk to the hazard, not reduce it, so the Safety Committee did not want to make it their recommendation but rather mitigate it with a different solution. The Chief Pilot disagreed with their recommendation and wanted to implement his suggestion. What followed was 18 months of a stand-off between them, only to be ultimately resolved when the Chief Pilot retired. It was an awkward and uncomfortable situation.
§ Walter added a comment here to say it is important that the Safety Officer himself be objective about the issue and not subjective, in other words is the Safety Officer thinking clearly himself, that this is a real issue and others agree, or does only he think it is important and maybe it really isn’t. The goal for most SMS is to lower risk to the lowest acceptable level as practical. Who decides where is the risk becomes acceptable? That is up to company management, in their opinion as to what it takes to get the job done.
• [To expand my explanation somewhat that I did not say on the call.] Situations may come along that folks disagree where that level is, in fact, an individual pilot may have a personal level of acceptable risk that is lower than what the company is will to accept. An easy example to understand this is a company that does low-level powerline patrol in a light single-engine piston aircraft. The company must fly low enough for the observer to see enough detail and the economics of the situation allow only the use of the cheaper to operate ASEL airplane. There is the hazard of single engine and low level flight. The company accepts that risk with whatever mitigation means they use. What if the safety committee there comes up with the recommendation that they should use a King Air flying at 3,000 feet and with a high-resolution gps/laser directed turret-mounted camera for patrols? Does management have to accept that? Based on economics it might not work and drive the company out of business. Rather, if you are a pilot flying for that company, it is expected that the risks of the mission are an acceptable risk to you too. If not, you shouldn’t work there. Using this example and applying it to the situation above, though not all the facts of the situation are given, it is up to the chief pilot to ultimately the lowest level of risk practical. However, if the chief pilot is flat out wrong, misguided, or doesn’t truly understand the risks, or is well outside the normal boundaries of industry practices, then I think the Safety Officer/Safety Committee is obligated to push on the issue. That is what the dotted-line on the organizational chart from the Safety Officer to the Accountable Executive is there for. It might be a “you bet your job” situation, but that is why it is there. Pick your battles. If it truly is an unacceptable risk, use the dotted-line if all attempts to reason with the Chief Pilot have failed.
o Another caller said that his Chief Pilot was rather controlling in that only he was allowed to talk to the Accountable Executive about flight department issues. The AE was a regular passenger on the plane and the Safety Officer was one of the pilots and therefore could talk with the Accountable Executive about things related to that specific flight. But the Chief Pilot would get upset if the Safety Officer talked about flight department safety issues with the Executive.
o Another caller said his relationship with the Chief Pilot was good, but on several occasions on trips that the Chief Pilot was the PIC, he would want to bend the rules for himself. On one occasion he wanted to extend the duty hours because he thought it was OK for himself. The caller said that as the Safety Officer he approached the Chief Pilot to point out to him that he is setting an example for the whole department if he doesn’t follow the ops manual limits himself. The caller continued to say that the trend and the culture of the flight department is set by what the boss does. In this specific instance, the Chief Pilot agreed and a third pilot was added to the flight.
• A caller brought up a new topic. What should the flight department do when implementing an SMS, it is turns out that the department should no longer be doing something it has been doing for years? What if there has been an unsafe practice going on and they want to change, BUT it touches upon a point that affects service. The example given was this operator did not really know or do much about abiding to zero fuel weight limitations for the aircraft. They would regularly fill all the seats of the aircraft, which turned out to be beyond the zero fuel weight limitations of the aircraft. After implementing the SMS, this issue was brought up. The analysis was clear that they should be following the OEM limitation of the aircraft and that regularly exceeding the ZFW has probably put additional stress on the airframe. They no longer wanted to ignore the ZFW limitation, but that meant they had to tell corporate management they could no longer go with all 7 passenger seats filled, but rather with only 6 passengers. Awkward moment. So how does one explain to the boss that they cannot take that 7th passenger any more? When the boss asks why, are you really going to say that what we’ve been doing for years has been wrong and unsafe? What is the boss going to think? Obviously not something good.
o Several callers added a couple more similar stories of Sabres without de-icing capability flying into known icing conditions, and Lears exceeding limits.
o One caller responded to say that this is why when implementing an SMS it is important to do so with the understanding and acceptance by corporate management. Tell management that by implementing an SMS, it will likely result in changing some of the processes and procedures, even those we have been doing for years. And that changing our procedures might affect service. Emphasis to management that by implementing an SMS adds value to the operation and includes best practices.
o This same caller continued to say that in his experience, that the development and implementation of an SMS is usually associated with a change of flight department management. Prior flight department management was allowing bad practices to continue. He said that he didn’t want to necessarily throw the prior chief pilot under the bus, but hey, the truth is the truth.
o Walter commented: I don’t know the silver bullet answer that works every time for this situation. I agree that you should set the expectations of management that things might change when an SMS is implemented. I absolutely would not want a flight department to continue with a bad practice just because they are afraid to change if they had to explain why – that they have been wrong/unsafe all these years. Yes, this may be a situation where you have to “man up” and do the right thing no matter the consequences. But then again, don’t be too harsh on yourself. If we consider ourselves professionals, and have been given the proper training, and don’t have suicidal tendencies, then we should really ask ourselves what is the root cause of why it was the way it was? Was it complacency? Was it a somewhat acceptable practice at one time? Was it because of organizational dynamics that change did not come sooner? That is truly what needs to be corrected.
• Another caller said that to implement an SMS as part of IS-BAO, and to not take it to heart and follow SMS principles, just means one has created a lot a paperwork for nothing. There needs to be buy-in by management and everyone in the department.
o Another commented that be aware that to everyone comes to understand and accept SMS practices it at their own pace. It takes a constant reassurance and encouragement.
• That concluded the call. It was 35 minutes in length. Next call is Tuesday, March 11th, 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.