design, development and delivery of safety management system training to transport canada: six years...
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Design, Development and Delivery of Safety Management System Training to
Transport Canada: Six Years and Counting
David Wilson, Stantec (formerly Jacques Whitford)
Roger Barker, ISR
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Outline
• The Mandate
• The Plan
• Course Design and Development– Transport Canada’s Start Point– Inclusion of International and Audit Content
• Course Delivery– Institutional Challenges– Regional Challenges
• Internal vs. External Reaction
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The Mandate
“The broad objectives of the SMS course are:
• For Delegated Officers (DOs) and Management to develop a detailed understanding of SMS, thereby instilling confidence and obtaining buy-in to TC’s SMS program
• For DOs to develop the skills necessary to execute their mandates in the assessment of SMS”
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Aviation mission and vision
To develop and administer policies and regulations for the safest civil aviation system for
Canada and Canadians using a systems approach to managing risks
– Continuous improvement – High level of public confidence
Flight 2005: A Civil Aviation Framework for Canada
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0.0
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Safe Environment
Safety Awareness Safe Person in Safe Environment
Supervision Driven
Team Driven
Behavior Driven
INC
IDE
NT
RA
TE
Command & Control Programs Management Systems
Evolution of Safety Management
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Towards Zero...
…is the condition to which risks are managed to acceptable levels.
WorkplaceSafetyStandards
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TC Requirements
• “Aviation organizations should establish and maintain a safety management system that conforms to all of the requirements of applicable Canadian Aviation Regulations (CARs) and Standards”
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TC Requirements
There are 9 parts to the CARs:1. General Provisions2. Aircraft Identification and Registration and Operation of a
Leased Aircraft by a NON-registered owner3. Aerodromes and Airports4. Personnel Licensing and Training5. Airworthiness
– Aircraft Certification (AC) – Maintenance & Manufacturing (M&M)
6. General Operating and Flight Rules7. Commercial Air Services8. Air Navigation Services9. Repeals and Coming into Force
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The Plan
• Phase 1: Analysis– Deliverable 1: Training Needs Analysis, Learning
Strategy, Final Work Plan and Background Update• Phase 2: Evaluation and Design for CBA and AMM
– Deliverable 2: Course Syllabus, Course Materials• Phase 3: Pilot Course
– Deliverable 3: Pilot Course, Course Evaluation• Phase 4: Course Delivery to CBA and AMM
– Deliverable 4: CBA Course, AMM Course
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The Plan cont’d
• Phase 5: Validation of Course Delivery to CBA and AMM– Deliverable 5: Confirmed Assessment Protocol, Course
Validation• Optional Phase 6: Adaptation for Other Functional Branches
– Deliverable 6: Adapted Course(s)• Optional Phase 7: Course Delivery to Other Functional
Branches– Deliverable 7: Other Functional Branch Course(s)
• Optional Phase 8: Validation of Course Delivery to Other Functional Branches– Deliverable 8: Course Validation(s)
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Course Design
• Definition of the target population
• Identification of the SMS knowledge level of target audience
• Review of CARs and notices of proposed amendments (NPAs) to CARs relating to SMS
• Review all applicable national and international (e.g., UK, Australia and GAIN) aviation SMS policies and guidelines
• Assessment of the existing safety culture within the target audience
Safety Metrics Assessment
• Survey-based tool from sub-consultant
• Distributed internally to approx. 1000 DOs: 150 replies
• Intent was to identify:– Internal issues/barriers within TC– Issues/barriers external to TC (customer,
industry, etc.)
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Training Needs Assessment
• Front line staff were fully aware of their needs and challenges– Different measures are required to measure safety and
SMS;– The interdependencies of attitude, behaviour, and
motivation cannot be ignored– Inspectors need practical demonstration of a functioning
SMS from the ground up,– If support, guidance, and structural leadership from
management are not forthcoming (as happened with Risk Management training), then SMS training will fail.
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Global Review of TC SMS • Global references:
– OHSAS18001
– GAIN
– CASA Australia - Guide to Aviation SMS
– SMS for Commercial Air Transport Operations - Guide to Implementation (UK)
– OGP Checklist for an audit of safety management
• Resulting additions to the TC model:– Continuous Improvement
– Feedback
– Annual Management Review of the SMS
– Contractors must meet safety standards which do not impinge on the SMS of the organisation
– Inter and Intra-company Safety Performance Comparison
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The TC SMS Model
1. Safety Management Plan• Safety Policy
• Non-punitive Safety Reporting Policy• Roles, Responsibilities & Employee Involvement
• Communication• Safety Planning, Objectives & Goals
• Performance Measurement• Management Review
2. Document Management• Identification & Maintenance of Applicable Regulations
• SMS Documentation• Records Management
6. Emergency Preparedness
5. Quality Assurance
4. Training
3. Safety Oversight• Reactive Processes • Proactive Processes
• Investigation and Analysis• Risk Management
Course Development
• Addressing Gaps:– Audit Approach– Approach to Assessing SMS: Assessors vs.
Inspectors– The TC SMS Model vs. Plan-Do-Check-Act
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Course Delivery
• Initial 4-day course (‘03-’04)– 19 deliveries
• V2: 4-day course (’04-’05)– 18 deliveries
• V3: 3-day course (’05-’09)– 15 deliveries (eLearning course starts in fall ‘09)
• 2-day awareness course
• 2-day multi-model course
• ½ day refresher course
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3-day Course Content• History of SMS• Introduction to TC SMS• SMS Elements
– Safety Management Plan– Documentation– Safety Oversight– QA, Training, EPR
• Safety Performance Measurement • Safety Culture • Implementation of SMS • SMS Evaluation Guide• Process to Assess Industry SMS• Completing the Assessment
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Addition of Broader Audit Approach
• DOs used to inspections and checklist-driven audits
• ‘Process’ vs. ‘procedure’ view not well differentiated: had to get up out of the trees
• No methodology for producing defensible, quantified assessments of SMS: development of the SMS Assessment Process
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Plugging the Holes with PDCA
• Gaps in management system elements identified in course design were not addressed until V2/V3 of the course:– Management review– Proactive process (risk management)
• Some backlash from attendees as a result, however intent was to arm DOs as best possible to allow them to engage industry
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Institutional Challenges
• SMS needs a Paradigm shift within aviation from :– DOs are responsible for aviation safety
• responsible for operator’s actions and take accountability for them
– Operators must get all actions approved by TC
– Audits of operators are only done by DOs and the operators cannot be trusted to do carry out internal ones themselves
– Conflict of interest in the "old way of doing things"
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Regional Challenges
• Different degrees of involvement and engagement by Regional Directors
• Regional cultural differences: adversarial vs. partner approaches from POIs/PMIs
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Internal vs. External Reaction
• Within TC:– Sounds good in theory– Are we prepared to back this up?– How does this system scale from large to
small?– Will TC really enforce the SMS CARS?
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Internal vs. External Reaction cont’d
• Within industry:– Larger operators/AMOs/airports: we do this
now (but may lack some rigour…)– Hazard analysis and identifying risk significant
activities often a weakness– Smaller operators: what is it exactly that you
want me to do (and when exactly do I get to make a living…)?
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In Conclusion
• Training of TC Civil Aviation a major undertaking (time, personnel, cost)
• Paradigm shift just now starting to show broadly in TC
• Communicate, communicate, communicate: can it ever be enough?
• We see senior managers taking more of a lead, and see that aviation experts are needing to become more proficient in management
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In Conclusion cont’d
• SMS is about risk control - the loop of hazard-risk-objectives-measures-audit-management review drives a big shift in the way management perceive their roles and forces communication into the organizations
• Tough part awaits: small operators
• Grateful to have been able to play a role
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