Aviation SMS Manuals – What Should be Included, Part 1: Essential Elements
For business aircraft operators, probably one of the least appealing and least "flashy" elements of the Safety Management System (SMS) model is the documentation of processes and procedures, otherwise known as "the manual." Even writing about the SMS Manual conjures up remedies for insomnia. Regardless of how stodgy the subject is, there tend to be mixed views of what the purpose of an SMS Manual is and what needs to (or needs not) be included. While there are many examples available in the industry of what a manual should look like, there is only one manual that is appropriate for your organization: the one that is created based on the reality of what your organization is doing to effectively manage safety.
1. What is the purpose of the aviation SMS Manual?
The purpose of the SMS Manual is to tell a story, a non-fiction one, of what your organization does to manage and ensure safety. It should tell who does what, why it is done, and what the expected output of the process will be. Furthermore, it should also state who has authority and responsibility for the things being done and to whom that individual is accountable. The reason for this is if the process needs to change or is not performing as planned, then those in the organization will know who to turn to. The bottom line is your manual should be a reflection of reality in what your organization does to effectively and systematically manage safety. It should be a document of what is accomplished, rather than what is aspired to.
An unhealthy view of the manual is one in which the documentation is seen as a cure-all to all SMS woes. In this paradigm, the manual itself is seen as the SMS. It erroneously follows the logic of "write it, and it (the SMS) will come." The fact that an organization has documented processes and procedures does not necessarily attest to the fact that the organization is actively and systematically managing safety. Simon Roberts, in his article "New Role for the Regulator" (AeroSafety World, Aug. 2013) further explains this by stating: "Having a well-crafted safety management manual and delivering SMS training won’t itself produce an effective SMS." The documentation, again, should reflect what your organization is actually doing to effectively manage safety. Ultimately, this document will provide: standardization across the operation, repeatability, measurement in support of continuous improvement, and guidance during changing times.
2. What should be included in your aviation SMS Manual?
This tends to be a very distressing question for some operators when constructing their manual. There is seeming uneasiness around the wonderment of "have I not included enough" or "have I made this more complex than what it needs to be?" Both are valid concerns, and trying to construct the appropriate manual may find the author(s) oscillating between these in an attempt, or struggle, to appease internal customers and external authorities (Civil Aviation Authority [CAA], audit, or otherwise). There are some good examples out there, such as this SMS Manual framework, but caution needs to be exercised when using these so-called templates, which we will address in the next article. However, in the end, whatever is placed in that manual must reflect what your organization is actually doing. In other words, if your manual states that each submitted hazard is reviewed and assessed by a 10-man safety action group, then signed off on by various departments, and you are, in actuality, part of a small, two-man flight operation, there is obviously a gap between reality and what is written.
The International Civil Aviation Organization’s (ICAO) Document 9859, 3rdEd. also provides a little guidance on what your organization’s SMS Manual should include. Chapter 5, paragraph 5.3.36 suggests that the manual should describe: "…the organization’s SMS according to its components and elements. Such a document facilitates the organization’s internal administration, communication and maintenance of the SMS." Further down in paragraph 5.3.38, a more concise list of what should be included in relation to the specific components and elements is provided. However, even in this more expository list, it is not stated exactly what should be written. This follows the performance-based flavor of SMS, in that the end – and not the means – is the focus.
I do want to say that I am not intentionally trying to be coy regarding specific SMS Manual content in the above paragraph. What I am trying to convey is that your organization needs to only include in the manual what is done to resolve the outputs of the various SMS processes and, in the end, the performance requirements of the SMS. However, to obtain this objective, one needn’t write something that is overly complex or technical. Dr. Patrick Hudson, in his paper "Safety Management and Safety Culture: The Long, Hard and Winding Road," states, "In reference to lessons learned in implementing SMS in the oil and gas industry, … when documenting the SMS, it is not necessary to document every single detail." He goes on to state, "Where necessary references can be made to specific documents or procedures, what is needed is the overall structure, not necessarily the details." Interestingly, in reflecting on this lesson regarding documentation, he sees that highly complex and overly-detailed documentation is "… a major reason why SMSs were seen as over-complicated and expensive." He concludes,"… an effective system is possible with much less."
Finally, it is important to note that when writing the manual, it is important to keep your audience in mind. When describing your SMS processes, writing in a clear and understandable manner goes a lot further than trying to dress it up with words that would normally be found in the realm of academia. Friedrich Nietzsche sums it up best when he said, "Good writers have two things in common: They prefer to be understood rather than admired; and they do not write for knowing or over-acute readers."
Best practice, when constructing your SMS Manual, is to keep the process simple and avoid creating an overly complex document. Your SMS Manual should reflect the reality of what your organization is doing to proactively manage safety and control risk.
If you have any questions about this article or about other aviation SMS topics, contact me at firstname.lastname@example.org.
Stay tuned for Part 2, which covers starting the process of creating an SMS Manual.