Most upper-level aviation managers are convinced of a good safety management system’s benefits, as are most operations staffs. Safety officers may find less enthusiasm within maintenance departments.
“SMS is a duplication of effort,” goes a frequently heard attitude among maintainers. “We already record maintenance actions.”
This may be true, but there is a difference between maintenance procedures and safety management. One certifies compliance with maintenance regulations; the other helps manage risk. Many technical faults have safety implications, but documenting their correction does not entail examining the risk involved in a fault or document controls put into place to mitigate it.
Maintenance procedures rarely collect data on a fault’s occurrence. A well-designed SMS collects data, documents controls and allows for analysis and trend detection. This enables proactive prevention of recurring faults and may reduce costs.
A recent case study of a maintenance oversight revealed that an operator had no procedures (in maintenance or the SMS) for dealing with outsourced work. A third-party organization completing a repair inadvertently had left tape over a static port. Had the directors of maintenance and of safety worked together closely during the SMS’ creation, maintenance and safety policies might have been put in place to prevent this kind of incident.
One of SMS’ virtues (and necessities) is feedback to those who submit reports. If someone reports a safety concern that is addressed through maintenance action, the reporter and all employees must be able to see documentation showing what was done and why. Little is more damaging to a safety culture than a widespread belief that filing reports never leads to change. Feedback can fix that.
It must be obvious that, if maintenance issues are not reported within a safety system, there is no assurance that the issues have been fixed. One of the most self-defeating comments ever written on a safety report was, “This is not a safety issue. This is a maintenance issue.” The manager who wrote that closed the report with no documentation of remedial action and no analysis of the risk.
A safety officer’s duties include encouraging all of an organization’s employees to make full use of an open, non-punitive reporting system. The phrase “safety is everyone’s business” might be cliché, but it is true. Everybody should encourage good reporting by being fully involved in risk management, hazard analysis, safety assurance and safety promotion.
One of the most obvious symptoms of a good safety culture is the attitude of the accountable executive. Within an SMS, the accountable executive is the only person with the authority to accept residual risk. This person, therefore, must be fully committed to active participation in all the SMS’ aspects, including maintenance. This person must get full and complete documentation of all maintenance safety and operational issues.
Questions to consider in assessing maintenance’s support for your SMS include whether your safety committee includes a mechanic. Does your director of maintenance contribute fully to safety reporting? Are safety concerns about maintenance adequately resolved and documented? In safety promotion, does maintenance provide information about aircraft, such as modifications, airworthiness directives or service bulletins?
You also might ask whether your crews have doubts about the quality of maintenance and whether maintenance personnel know and understand the company’s safety program.
The International Helicopter Safety Team offers a very good SMS maintenance tool kit on its website. Designed to help operators assess existing activities, it addresses the maintenance organization’s purpose, scope of work, key roles and responsibilities, key policies and resource requirements. It also offers guidelines for such areas as maintenance procedures, quality assurance, training and recordkeeping. Operators can use the kit to make maintenance a vital part of an SMS program.
We need to know that those who fix aircraft are looking after those who fly them. Implementing an SMS in an organization (large or small) will help save lives and resources. It will also help maintenance personnel develop risk management skills that are in great demand in the industry.
I would like to thank John Kirk of Aviation Safety Auditors for his expertise. As always, take action to fly safe!