Aviation SMS Manuals – What Should be Included, Part 2: Beginning the Process
This business aviation blog post continues from our last article last week, titled: "Aviation SMS Manuals – What Should be Included, Part 1: Essential Elements."
Your aviation Safety Management System (SMS) Manual needs to be a "living, breathing" document. It should not only reflect the reality of your corporate culture today but accommodate ongoing "tweaks" to the safety consciousness of your organization in future.
The following is an overview of what you need to know:
1. Where should you start?
It is not an easy feat to sit down with a blank piece of paper and begin the process of writing your manual armed with only the International Civil Aviation Organization (ICAO) performance-based guidance. Just as it would be easier to build a house from a pre-constructed frame, it might be helpful to utilize a framework to help organize the applicable information into a logical format. These frameworks come in many different varieties and sources and range from a "bare-bones" skeletal outline to a fully populated (processes and procedures) framework that requires the author to insert only the company name and appropriate position titles/names. A strong word of caution regarding the latter: It should be expected that the contained processes will be adjusted to meet your organizational needs. Experience has taught me that if you try to fit your organization into a manual, you will more than likely fail. At risk of reiterating this point ad nauseam, your manual needs to reflect what your organization can and is doing to resolve the safety management processes.
A good place to start is the previously referred to ICAO Doc. 9859, 3rd Ed., Chapter 5, paragraph 5.3.38 for an "inventory" of the elements that need to be described in your SMS Manual. Excellent guidance is also provided in Appendix 4 of Chapter 5. You will notice that even this enhanced guidance does not give specifics concerning how to explain the process, but rather what needs to be explained.
As previously mentioned, there are frameworks out there that go further and even provide process descriptions for you. But, again, a word of caution: You will likely have to tweak or adjust the process written to fit your organization in order to effectively obtain the desired outputs. Then, you will have to go back and alter that process in the manual to match what your organization is doing. The International Business Aviation Council has great examples of policies and processes in their SMS toolkit and a good example of structure in their Generic Company Operations Manual framework. Additionally, aviation SMS manuals from other operators across different segments may also serve as guidance and as a learning aid when trying to determine how your processes will look in operation and on paper. Just remember that those manuals should reflect what works for them, which may not work for your organization.
Finally, it is important to state that creating your manual will be an ongoing, iterative process. Since it must reflect reality, if your organization is in the middle of SMS implementation and has not yet implemented all the elements of a mature SMS, then there is no reason for a description of how those elements are resolved to be in your manual at that point. The ICAO Safety Management Manual (Doc. 9859) states that SMS documentation (Element 1.5) implementation, throughout the phased SMS implementation, is progressively implemented in phases. Ultimately, even during post-SMS implementation, the aviation SMS manual must be a living document. As your organization changes, so will the way things are done. Therefore, the aviation SMS Manual, as a reflection of reality, must also be updated to reflect the changes.
The idea of creating a manual to describe your organization’s SMS in the scope of all safety management activities is probably the least desirable one. However, following the adage, "If it isn’t documented, it doesn’t happen," a well-documented SMS does provide for repeatability, guidance, and measurement. All the same, just because it is documented doesn’t necessarily mean that an SMS is "happening" or happening the way it is documented. The processes documented must reflect reality and what your organization is doing to effectively manage safety. Documentation that details down to the individual procedure or task may not be necessary and can have the adverse consequence of over-complicating the process, leading to frustration or abandonment. There are many examples to help the writer get started, but if the framework or template already contains written descriptions of the processes, it is important that they be adjusted to fit what is working in your organization. Finally, the entire aviation SMS Manual, which describes a complete and mature SMS, cannot be written overnight. It is a process that will reflect the components that are already implemented and functioning. Once the manual is complete, though, your organization will have a robust document that will accurately describe to employees (current and future), regulators, and auditors how your company effectively operates its SMS.
If you have any questions about this article or about other SMS topics, contact me at email@example.com.