Adopting the concept of SMS (or System for Safety Management, as the NZ CAA prefers to call it) is a long overdue move by the Authority (or any industry, for that matter). It should be commended. The aims and principles have many benefits, not only to aviation, but to society as a whole.
I fully embrace the concept, but cannot claim to be an expert. SMS reflects the way I have been brought up to think, in the military and civilian worlds. In the military environment, people can end up hurt – or dead – very quickly, in any number of new and inventive ways.
This is also possibly one of the reasons why I have found myself in conflict with the “let’s not fix it if it’s not broken” and “let’s wait until it happens before we make any changes” brigade. It usually involves me being accused of having an over-developed imagination – which, of course, is an assessment I can’t argue with.
Unfortunately, not all members of this brigade exist outside the group that regulates on behalf of those who partake in aviation. I have a recording of one such CAA ‘staffer’ telling me in no uncertain terms that I ‘can’t keep raising safety concerns’ and that ‘35 years ago things were busier, so we would just have to live with it’. This individual would no doubt be one of those tasked with making subjective assessments regarding operators’ SMS policies and procedures.
GAA has often reminded the CAA of the principles behind Just Culture. Unfortunately, I suspect the Authority has not yet learned how not to alienate its customers.
I’m sure the guys who spent years drafting this proposed rule have the right intentions and have honestly done the best they can. I applaud their efforts for what must have been a colossal undertaking. But then they went and shot themselves in the collective foot by announcing that all submissions had to be in by 19 June.
At the SMS seminar I attended, there was a fair level of cynicism among the audience. Although supporting the concept of SMS, their overriding theme seemed to be: “Who in the CAA is competent and capable of making assessments of what are essentially very subjective operator processes, in an objective manner?”
Chatting with attendees over lunch merely confirmed this feeling, with the overall opinion being: “This is the way it’s going to happen, get on with it” and “Oh! by the way, you have less than ten days to get any submissions into us” (seven days after the last seminar date).
I believe that the CAA has not fully appreciated that the concept of SMS is a hearts, minds and attitude process. It is much akin to Buddhism, which is a way of life (performance-based) as opposed to the ‘compliant’, tick-the-box check-list of most other religions’ scripture and dogma.
Yes, the CAA will be very happy to charge out audits at $285/hr whilst its people try to learn the ropes of this new and (to some of its staff) alien concept.
One of the documents I found at the seminar, written by a consultant, stated that even more consultants would be generated along the way and that the SMS process may be reduced to a check-list, procedure-based audit, for the convenience of the auditor, that would completely miss the whole concept of SMS thinking.
It was also heartening to note, in the documentation, an admission that not all regulatory authorities are ‘performing’ within a Generative environment – suggesting that some operate within the Bureaucratic or even Pathological model.
And that is one of the major sticking points. How can the CAA audit what is essentially something conceptual by using the same thinking paradigm that may be responsible for the problems in the first place? QA systems (QMS) will still be there, quantifiable and measurable. So too would be the records of identified risks and threats required by SMS. But how do you measure the way someone proactively thinks and potentially acts on that information? It is not impossible, but it is very unlikely to be measurable at an audit.
The CAA seems oblivious to the high number of aviators (professional as well as private) who are disengaged with anything that emanates from Asteron House.
It comes down to something like this: a company could have a brilliant product. However, if that company evidently lacks credibility, honesty and integrity, plus a fair and just after-sales service, then the product will remain on the shelf, unsold.
If the CAA was serious about making significant headway in ‘selling’ its products, it would have to address the above issues. Many companies send questionnaires to their customers, to discover what they think of their products, staff and service. Successful companies listen, and provide the goods and services the client wants – not what the company has to sell!
Any organisation that is so poorly regarded by those it represents or regulates (and the CAA must be aware of this) should be honest enough to face the truth. I wouldn’t mind chipping in (above what I already fork out) for the CAA to hire a good PR consultant and win the hearts and minds of the disaffected – provided the Authority was transparent (warts and all) and its staff were held to the high standards they expect from us. Then, and only then, would the CAA gain credibility.
I have great admiration and support for those hard-working, helpful, forward-thinking CAA people who radiate integrity. There are many of them within the Authority. I just hope that they don’t get demoralised and leave.
Accepting all that, it must be difficult for a politically appointed director of any organisation to make any real, effective change without first clearing out obsolete baggage that no longer fits the vision or is fit for purpose.