A continuous process and appropriate arrangements for systematic review of safety issues that encourage reporting of threats and hazards and submission of safety improvement proposals by staff.
Continuous improvement of the SMS: a formal process to identify the causes of sub-standard performance of the SMS, determine the implications of sub-standard performance in operations, and eliminate such causes. (ICAO Doc 9859)
To ensure that changes are made to improve safety where they appear needed. (EUROCONTROL ESARR 3)
Recently, ICAO introduced amendments to several Annexes to the Chicago Convention in order to harmonise and extend provisions relating to safety management and achieve standartisation of Safety Management System frameworks mandated for implementation by the different service provider organisations - airlines, maintenance organisations, air navigation service providers, airport operators. These organisations shall implement an SMS “…that as a minimum aims to make continuous improvement to the overall level of safety.” Thus, there are two closely coupled aspects of safety improvement which need to be considered by an organisation: continuous improvement of the safety performance and continuous improvement of the SMS.
An aviation service provider should ideally continuously improve the effectiveness of its safety management system (SMS). According to ICAO Doc 9859 - Safety Management Manual, the continuous improvement of the SMS is an element of the safety assurance component of the SMS framework. Assurance builds on the principle of the continuous improvement cycle. Safety assurance ensures control of safety performance, including regulatory compliance, through constant verification and upgrading of the operational system. These objectives are achieved by: systematic review and optimisation of risk management controls; safety audits (both internal and external); internal evaluations - safety surveys and safety analyses; independent strict document controls and ongoing monitoring of safety controls and mitigation actions.
Internal audits and evaluations involve the assessment and evaluation of the operational activities of the organisation as well as of the SMS-specific functions, such as risk management, safety assurance and safety promotion. Internal audits are an important tool for managers, used to obtain information with which to make decisions and to keep the safety of services at acceptable level. The operational activities build the domain where hazards are directly encountered, where deficiencies in activities contribute to safety risks, and where direct control and resource allocation can mitigate the safety risks. Audits and evaluations are an essential tool that helps managers identify effective safety risk controls, and following their implementation, to verify they continue to perform and are effective in maintaining satisfactory operational safety performance.
Continuous improvement of the SMS thus aims at determining the immediate causes of below standard performance and their implications on service provision and the operation of the SMS. Continuous improvement applies to:
- proactive evaluation of facilities, equipment, documentation and procedures
- proactive evaluation of an individual’s performance to verify the fulfilment of that individual’s safety responsibilities
- reactive evaluations in order to verify the effectiveness of the system for control and mitigation of safety risks.
According to ICAO “continuous improvement can occur only when the organisation displays constant vigilance regarding the effectiveness of its technical operations and its corrective actions. Indeed, without ongoing monitoring of safety controls and mitigation actions, there is no way of telling whether the safety management process is achieving its objectives. Similarly, there is no way of measuring if an SMS is fulfilling its purpose with efficiency”.
In difference to ICAO, EUROCONTROL ESARR 3 - Use of safety management systems by ATM service providers places the safety improvement element of the SMS in the safety promotion domain. The related implementation guidance material places the emphasis on the need to encourage personnel to play active role in the continuous safety improvement loop.
Processes and methods should be introduced to facilitate reporting and submission of proposals by staff. A systematic way to deal with proposals should also be defined. The originator should receive feedback on the decision and actions taken on the proposals that have been brought to management attention. To propose solutions to identified hazards, staff must be aware of them and the existing remedial actions taken. This could be achieved by means of arrangements for safety awareness and lesson dissemination.
To achieve the goal for continuous safety improvement there should be a tangible form of commitment of the organisation’s management. Processes should be defined to establish management review mechanisms for translating intentions into positive action. ESARR 3 identifies three essential objectives for the SMS management review processes:
- Review the SMS operation to determine:
- first, whether the SMS is working in its own terms and especially whether safety procedures are being followed;
- secondly, whether the SMS is continuing to meet regulatory requirements;
- and finally, but most important of all, to know whether the safety objectives of the organisation are being achieved;
- Consider problems, suggestions and proposals identified through the SMS operation; and
- Agree and authorise changes in the SMS, as well as other modifications which may be appropriate.
A positive safety culture in the organisation is an essential enabler for continuous safety improvement.
- ICAO Doc 9859 - Safety Management Manual, Fourth Edition - 2018;
- ICAO Integrated Safety Management website;
- Commission Implementing Regulation (EU) No 1035/2011 of 17 October 2011 laying down common requirements for the provision of air navigation services and amending Regulations (EC) No 482/2008 and (EU) No 691/2010;
- Eurocontrol Safety Regulatory Requirement - ESARR3, Use of Safety Management Systems by ATM Service Providers;
- ESARR Advisory Material/Guidance Document - EAM3/GUI3 ESARR3 and Related Safety Oversight;
- FAA Advisory Circular No. 120-92 Introduction to Safety Management System to Air Operators, See, Appendix 1, See Section 6.8 Continual Improvement.