Bringing legitimate safety issues to the boss who cares, but may be untrained in the ways of safety management systems (SMS).
|This Bell 212 was used for Salt River Project power line construction in Arizona. Photo by Dave Scott|
We all know that bringing problems to management without offering potential solutions is usually viewed as mere complaining. As safety professionals, we also have to appreciate that managers have enough to worry about without having a safety flag thrown at them every time they want to generate a new source of income. Then there are those companies that use the mantra of “Safety First,” yet really focus on “Revenue First.” Sound familiar?
As an organization’s safety proponent, you must recognize many of our associates view safety programs as being a diametrically opposed to the revenue component of business. This fear stems from the notion that the costs, both in time and money to appease the safety watchdog, will inhibit mission completion or profit. It is a myth, and like all myths based on incomplete or biased view of the truth. So the goal here is to educate your associates that, in fact, “Within a healthy safety culture this notion of safety being diametrically opposed to generating revenue couldn’t be farther from the truth.”
Like a helicopter, the members of an aviation department are often a compilation of opposing forces, which ultimately and magically work together to somehow take flight. It’s always the same: operations versus maintenance, or revenue versus costs. Ops relentlessly assigns missions for pilots. Pilots fly as much as possible (and on occasion create “unscheduled” maintenance). Mechanics tend to conduct routine maintenance and of course fix aircraft every time one of those unscheduled events occur (unless that unscheduled event results in something that can’t be fixed). Maintenance ultimately returns the aircraft back to hands of the ops folks (and hope not to see the aircraft again until a scheduled action comes due).
Management’s role is to drum up the business and to set policy, which ops and maintenance have to live by in order to continue their own circle of life. Then there is the outlier, the one system that management, ops and maintenance can utilize in the struggle to find a balance that enhances profit and long term prosperity: Safety. Some of you may be muttering “BS” right now, but bear with me.
If we wanted 100 percent safety, our aircraft and crews simply wouldn’t fly. Since not flying won’t work for us, we must accept some degree of risk to reap any gain and understand that mistakes will occur. A solid and proactive safety system can keep operators from making the same mistakes others learned the hard way, mistakes which can have financial costs financially and ultimately risk the lives of your employees.
Taking it a step further, a predictive safety system will help identify risk factors and develop mitigation strategies before they rear their ugly head and cause significant events. So, in a nutshell, the safety officer’s role is to assist management in establishing policies and processes that allow flights to be conducted within acceptable levels of risk, and then to provide the support necessary to keep the company on track. The postscript to that is that the safety officer is not there to tell management what they can and cannot do. This warrants repeating…
Golden Rule: It’s not the job of the safety officer to tell management what they can and cannot do!
The challenging part for most safety officers is determining what the company’s appetite for risk is—risk that will be ultimately managed and mitigated through company policies, standard operating procedures (SOPs), training and standards which the safety officer will play a role in developing. Does this mean that company management cannot operate outside those guidelines on occasion? Absolutely not!
Quick example: Take exceeding a contract Part 135 flight time limit to ferry an aircraft to a job. Management announces that it now views ferrying to the job as being under Part 91 and therefore not subject to those particular limits. Is that legal? Yes. Are they now assuming that pilots don’t get tired while flying under Part 91? No, but it must be recognized, risk will be higher. There is lots of data behind fatigue vs. performance, so what’s the gain? Is it worth the increased risk? What can we do to mitigate the risk, etc?
In this example, the safety officer needs to bring to management’s attention that the new policy is eliminating a risk management strategy (fatigue countermeasures) and essentially setting the stage to operate at an increased level of risk.
Bear in mind that the previous fatigue/flight time threshold was the company’s risk trigger and that risk management policy was established at a time when there was no sense of urgency to decide if this level of risk was acceptable to obtain the gain (revenue) The safety objective is to point out that it is now time to employ some greater thought and look at modifying existing mitigation strategies or developing new ones before blindly adventuring down that road in search of revenue.
A truly savvy safety officer will even have taken the time to develop some alternatives for the boss and/or safety team to consider. This is the point of proactive decision making as apposed to reactive. One of the main tenants of SMS, and if you want to kick it up a notch the International Standards of Business Aviation (IS-BAO), is to know, via trigger points, when your risk levels are ratcheting up and/or bumping against set limits (risk management thresholds that were created to prevent revisiting previous lessons learned or worse known or forecasted hazards). In a sense, the safety officer is management’s sentry, always on the alert for operational creep, that dangerous phenomena that can degrade an otherwise safe set of standards.
The point here is not to teach risk vs. gain, mitigation, SMS, CRM, EI-EI-Oh or any other tools of the trade. The point is that if you are the safety officer, your relationship with management should not be one of preaching or enforcing rules. This approach will alienate you, and the last thing that you should become is the enemy of income, someone to try and get around, or just someone to blame when things go wrong. Safety officers are educators. They are historians. And most importantly they are enablers! A safety professional provides the necessary information, tools and knowledge to enable management to make informed, proactive decisions.
Safety officers ensure management gets involved in the decision making when, for example, fatigued pilots or maintainers are advocating courses of action to get a flight out using a plan that circumnavigates the safety system. The safety officer’s role is not to make the final decisions, but rather to ensure decisions are made at the appropriate level with the proper attention to risk. Teach, coach and mentor to employ the tools of the trade with candor and an ever-present eye on all the bottom lines: risk/cost and reward/revenue. Stay upwind of the smoke.
Note: This is first part of a series of articles designed to help company safety officers implement safety management systems. Dave Scott is an aviation safety instructor for the Squadron Inc. and former U.S. Coast Guard chief pilot for the HH65 Branch.