Regular public transport operators are undergoing a transition to the proposed

CASR Part 119, which will mandate safety management systems for ‘passenger

transport services using aeroplanes or rotorcraft, and some categories of cargo

transport’. It is envisaged that this will incorporate therefore not only Australia’s current 48 high and low-capacity regular public transport (RPT) operators, but will also include some additional 400 charter

operators. Flight Safety editor, Margo Marchbank, in the first of a series of articles on SMS implementation, gives an overview.

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‘I don’t believe in “safety fi rst”, but “safety always”,’ says CEO of Toll Aviation, Trevor Jensen. ‘If you say safety fi rst, then it’s very easy to say, “OK, we’ve considered safety, now we can get on with the job”. Whereas, if “safety always” is the culture, then you don’t move away from it.’ Toll Aviation is one of three ‘pilot’ organisations working closely with CASA on the implementation of safety management systems (SMS) in the transition to Part 119. SMS have been on the radar for over ten years, and many proactive RPT operators, recognising that they are a critical part of doing business, already have robust SMS in place. They’ve been mandatory for certifi ed aerodromes since January 2007, and aerodromes with international fl ights even earlier, since 2005. (Further in this article, there are case studies of two very different aerodrome SMS experiences. See page 12.)

NOT SAFETY FIRST, BUT SAFETY ALWAYS

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Phase 1 Phase 2 Phase 3

Safety Policy, Objectives and Planning

Management commitment & responsibility

Safety accountabilities of managers

Appointment of key safety personnel

SMS implementation plan

Gap analysis

Documentation

Third party interface

Coordination of the emergency response plan

Safety Risk Management

Risk assesment & mitigation process Reactive Proactive/predictive

Hazard identifi cation process Proactive/predictive/hazardidentifi cation

Safety Assurance

Safety performance monitoring & measurement Reactive - incident & accidentvestigation

Internal safety investigation

The management of change

Continuous improvement of the safety system

Safety Training & Promotion

Training & education Key personnel All safety critical personnel All safety critical personnel

Safety communication

SMS IMPLEMENTATION PHASES 2009-2011

There are four major components to the required SMS:

Safety policy, objectives & planning

Safety risk management

Safety assurance, and

Safety training and promotion.

As part of the phased implementation of CASR Part 119, CAO 82.5(HCRPT) and CAO 82.3 (LCRPT) were mandated in January 2009,requiring operators to implement an SMS according to a staggeredtimeline. These phases are depicted below.

Toll Aviation has a fl eet of 12 aircraft: two French ATR 42s; 10 Metros (eight3s and two 23s); and three 737s contracted from Airwork NZ. And, on anyone day, they may also contract up to 50 aircraft. The company employs115 people: 38 pilots (ten on the ATRs and the rest on the Metros); 42engineers; 12 ground staff; and the remaining 23 in fi nance and admin.Although Toll is not a CAO 82.3 or 82.5 operator, they have chosen toimplement an SMS meeting the standards and timeframes associatedwith HCRPT operation. Their Metro operation is based around a numberof bank runs to centres such as Cairns, Townsville, Mt Isa, Moree,Coolangatta and Mackay. Then there are the freight services – one ATR

fl ies out of Brisbane to Bankstown, Melbourne and Adelaide, while the other does the reverse leg – Adelaide to Brisbane, at the same time. The Metros also fl y the Adelaide to Melbourne route.

Trevor explains that their Monday to Friday roster appeals to many pilots for whom no fl ying on weekends is a lifestyle choice. He is very much aware of the competition Toll faces from the major airlines, in attracting and retaining pilots. ‘The minute the major airlines want pilots, we lose them,’ he explains, ‘with up to a 50 per cent turnover’ in the good times, so part of the company’s risk assessment is the pressure this places on maintaining standards. However, the current economic downturn has a positive side – decreased airline recruitment has meant less workforce attrition. ‘The downturn has given us time to put our SMS in place with a stable workforce,’ he says.

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The timing is also right for their SMSfor another reason. Toll Aviation arosefrom three companies: Jetline, Jetcraftand Jetcare, which have been alignedinto the one organisation over thepast 12 months. This consolidationprovided a good opportunity, TrevorJensen says, to work with CASAon examining Toll’s systems veryclosely, as a prelude to establishingan integrated SMS for the newentity. An important fi rst stepwas a thorough gap analysis.‘Safety doesn’t have to costmoney,’ Trevor explains, so Tollused Survey Monkey (a simpleytool for designing surveysonline, with the capacity tothen analyse the data), tosurvey their pilots, engineersand ground staff ‘to see howwe as a group see ourselves.I’m not a salesman forSurvey Monkey, but it’s agreat tool which costs younothing. In a short timewe were able to come upwith results looking atour compliance.’ Thisanalysis was revealing,Trevor says. ‘If you takelevel 10 to be the level

we want to be for ICAO standards (International Civil Aviation Organization), then for most items we were hovering around six, but on hazard identifi cation, it was three out of 10.’

He says that by conducting the survey and analysing its results, they were able to be more realistic. ‘If we had asked ourselves, for example, “Do we have a hazard identifi cation system?” we probably would have said, “Yes”. But now, rather than just ticking the boxes, digging deeper has identifi ed the weaknesses, so we know where we’ve got to put our effort in.’ The process took Toll Aviation three months, but Trevor says, it ‘gives us a very honest assessment of our SMS readiness’.

Having this data has also helped in convincing the corporate group of the need to resource safety management within the company – training, IT systems and so on. ‘You can never win an argument on emotion, but good data can help you win.’

Trevor and his team have now assessed all the required elements, and established a list of the tasks needed to put their SMS in place, with the tasks allocated in a schedule for phases 1, 2 and 3 of implementation. As they write their manual, they can sign off on each of these tasks. Toll is also part of the pilot group trialling the new online SMS manual authoring and assessment tool (MAAT). When Flight Safety visited the company headquarters in Brisbane, Trevor was about to sit down with the CASA SMS project team to begin populating the manual builder online.

In conclusion, Flight Safety asked him what he felt were the key points of an SMS. ‘Keep it simple; safety has to be pragmatic,’ he replies. ‘It’s not about having big manuals – your SMS documentation should refl ect how you do your business. Make sure it refl ects what you do.’ And in training and communicating about safety, make sure the way you do it suits the audience. There’s no point in having pages of instruction, with the intent in the middle of the document, if the guys don’t want to read nine pages. ‘We have to understand our audience a lot better,’ he says.

‘The minute the

major airlines want pilots,

we lose them,’

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The whole system is electronically based, and with hyperlinks to the regulations, there is always access to the source document (e.g. the CASA, EPA or WorkCover websites). Clicking on the link therefore takes you straight to the most recent version. Every activity they undertake has a safe work method statement and risk assessment that identifi es hazards in relation, not only to the activity, but the area of operation, which may vary from day to day. ‘We’re in the early stages of trialling a new system, using a PDA/Blackberry, so that you can download documentation when you come back into the offi ce. Or, in the case of one of our pilots who may be fl ying outback, he can obtain remote access to our server 24/7,’ Geoff explains.

He estimates that the initial certifi cation process, involving fi ve months of manpower and downtime cost EPS about $50,000; with ongoing audit costs (around $12,000 annually) and annual registration fees for the three certifi cations of another $12,000. But Geoff argues, ‘ It wasn’t too long ago that the only

EPS HELICOPTER SERVICESAccording to principal, Geoff Sprod, EPS helicopters are confi dent thatwhatever SMS standards CASA introduces in the near future for charteroperators, they will be ready. On their website, Bankstown-based EPSHelicopter Services Pty Ltd state their mission is: ‘to provide a safe,effi cient, cost effective helicopter management service in support of our clients’ strategies and objectives.’ It was this desire to maintainan ongoing emphasis on safety, and to establish a point of differencewith competitors, which led Geoff and chief pilot, Paul Caristo, toimplement a quality assurance system.

EPS Helicopter Services own two helicopters, a Bell 206BIII Jetranger,and their latest acquisition, a Eurocopter AS350SD2. They conductcharter and aerial work activities that include pipeline and power linesurveys, banner towing, sling loads, fi re fi ghting and parachuting forpromotional events, to name a few.

In 2007, Paul was about a third of the way into putting the new company’soperations manual together, Geoff explains, when the pair decided,‘Let’s develop a fully integrated management system that would drivethe business,’ rather than simply having an SMS. Recognising that thehelicopter world is a highly-competitive market, and that the businesswould benefi t from the security of ongoing contracts, they decided toembark on securing SAI Global ISO certifi cation. ‘Ask any Joe on thestreet, and they know what the symbols mean’, Geoff explains, ‘the‘fi ve coloured ticks’ are the most recognisable QA symbols anywhere’.So EPS opted to undertake not only quality assurance (QA) (ISO 9001),certifi cation, but also environment (ISO 14001) and OH&S (AS 4801).

Their fi ve months of developing policies and procedures covering allaspects of the business, including safe work method statements, risk registers, risk assessments, staff training and induction, paid off. Afterrectifying minor areas during the pre-audit check, they passed theiraudit in October 2007, gaining their triple SAI Global certifi cation. Thiscertifi cation process ensures the system continually evolves with thebusiness towards best practice, and is reviewed with ongoing audits tomaintain certifi cation.

MORE THAN ‘TICKING THE BOXES’

www.epsheli.com.au homepage

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thing that mattered was the hourly rate. Over the past two years we have seen a change in tender requirements, and acknowledgement that tenderers have some form of quality, OH&S and environmental policies and procedures in place. And more recently, you not only have to provide evidence of such systems, but also any external certifi cation. Anyone who chooses not to go down this road soon will be behind the competition.’ For EPS the additional certifi cation brought direct commercial benefi t: a few months after certifi cation, EPS secured

a government contract, competing against other major operators. While price accounted for a percentage, other factors such as quality and environment were an issue. Their success, Geoff says, could be attributed to the fact that EPS was the only operator with a certifi ed system which covered all three aspects, giving them a high score in that component of the tender.

Over the next couple of years Geoff believes the reliance on providing evidence of a safety management system will increase signifi cantly. Additionally, a far greater emphasis will be placed on a company’s SMS as a measurement of their performance, rather than simply on their price.

SMS & AERODROMES Just as the current SMS Phase 1, 2 & 3 requirementsare a transition to CASR Part 119 – SMS requirementsfor Australian aerodrome operators followed a similartransition. CASR Part 139 (safety standards forAustralian aerodromes) came into effect in May 2003,with a 1 November 2005 deadline for aerodromeswith international operators; and 1 January 2007deadline for all other certifi ed aerodromes. KeithTonkin, of Aviation Projects, outlines case studies of two very different aerodromes which implementednew SMS.

NORTHERN PENINSULA AIRPORT (YNPE)

BACKGROUNDNorthern Peninsula Airport (NPA, formerly Bamaga/Injinoo Airport) is located on the northern tip of CapeYork Peninsula in far North Queensland. Like manyremote communities, the fi ve Aboriginal and Islandercommunities of the Northern Peninsula area relyheavily on air transport for access to medical and otheressential support services. The airport is therefore acritical element of community infrastructure.

To provide for an expected increase in operatorcapability, the airport was prepared for certifi cationin late 2007, and received its aerodrome certifi cateearly in 2008. A critical condition of certifi cation wasassurance by the Northern Peninsula Area Regional

Council, which managed the airport, that they wouldprovide adequate resources and funding so that theaerodrome would meet regulatory requirements.

Not only did the SMS satisfy one of the requirementsfor certifi cation, but importantly, it was a way of being proactive by identifying existing and potentialissues and the resources and management actions toaddress them.

SMS DEVELOPMENTThe airport management had limited knowledge of how to develop and implement an SMS. So after fi rstlooking at the principles and methodology of an SMSin the CASA-developed SMS template, they participatedin a workshop to identify risks to the safe operation of the airport. These risks and their associated treatmentswere documented in a risk register and treatment plan,in MS Excel format. By using Excel, which is readilyavailable, local airport management staff could view,manage and manipulate the register document easily.

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Some of the issues identifi ed in the development of the SMS, and actions taken to rectify them are as follows:

1. Emergency callout – Limitations because of fi xed-line and mobile phones meant that the airport manager (who also does the refuelling) was not always contactable for callout by emergency services such as the Royal Flying Doctor Service (RFDS). A satellite phone was therefore provided to the airport manager.

2. Frequency confi rmation – Although a Unicom service was available, limitations associated with staff availability and radio equipment, as well as signifi cant frequency congestion on the large CTAF(R) shared with nearby Horn Island Airport and other airports in the Torres Strait, led to the decision to establish Northern Peninsula Airport as a separate CTAF(R) and to install a combined AFRU/PAALC. This process will be concluded with the August 2009 amendment of ERSA.

AD-HOC OR UNFORESEEN RISKSAs with any aviation activity, despite the intention to proactively manage safety risks, unforeseen risks requiring reactive management action occur from time to time. Some incidents which occurred at NPA, and how these were managed to minimise future risks are as follows:

1. ‘Near miss’ – A light aircraft landed short of the runway while conducting a circuit to land, due to failure of the throttle cable. The subsequent emergency response revealed some opportunities for improvement in relation to call out procedures, telecommunications systems and response vehicle capabilities. The airport manager reported these issues, which were discussed with airport management and other stakeholders for consideration and implementation. Results were recorded in the risk register and treatment plan.

2. Pavement failure – ground water infi ltration of the runway pavement required urgent repairs to be carried out at short notice. This required closure of the airport for a number of days on several occasions, with implications to RPT operators,

emergency services etc. A full engineering designof pavement repairs & additional drainage wascommissioned immediately. The pavement repairswere carried out in accordance with the engineeringdesigns provided. The results of these activities wererecorded in the risk register and treatment plan.Further drainage & runway pavement upgrades arescheduled when funds are available.

STAKEHOLDER CONSULTATIONAll of the above issues required engagement withstakeholders to ensure that they understood andaccepted the risk treatments being implemented,and that an acceptable level of safety would bemaintained. These stakeholders included aircraftoperators and agents, council staff, local communitymembers, regulatory authorities, suppliers andcustomers.

Sometimes change can bring about unintendedconsequences, so during the development of risk treatments, stakeholders were asked fortheir input regarding potential impacts to theiractivities, including operational implications,amended procedures, most appropriate means of communication etc.

Stakeholders received information concerning thetreatment actions which had been determined,through email broadcasts to user groups, newspaperarticles, telephone, fax, industry publications andnewsletters, NOTAMs as well as AIP/ERSA and otherinformation sources.

SMS ONGOING MANAGEMENTAirport management accepts that risks need to bemanaged proactively. They organise meetings of the SMS safety committee every six months or so toreview the SMS and the risk register and treatmentplan, so that planned actions to treat known riskshappen; potential risks are identifi ed and actions putin place to treat them.

The meeting also tables and considers reports andinformation from the previous period relevant to theSMS, such as ad-hoc reports or other information;and safety/technical inspection reports.

‘. . . it was a way of being proactive by identifying

existing and potential issues and the resources

and management actions to address them.’

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SAFETY CULTUREIncreased regulatory obligations as a certifi ed airport under CASR 139, as well as status as a security-controlled airport under transport security regulations meant the community had to reconsider its approach to the airport. Improved maintenance of infrastructure and services, restrictions to access, more rigorous operational procedures and increased management involvement also required a prioritisation of funding and human resources, so the airport management met its regulatory requirements.

SUNSHINE COAST AIRPORT (YBMC)

BACKGROUNDSunshine Coast Airport (SCA), owned and operated by Sunshine Coast Regional Council, is Australia’s twelfth-largest airport by passenger numbers. It supports jet RPT services operated by Jetstar, Tiger and Virgin Blue; numerous fi xed and rotary wing training organisations, including Singapore Flying College; as well as aircraft maintenance and support operations. It is a security-controlled airport with screening requirements.

Sunshine Coast Airport is better resourced than Northern Peninsula Airport, but has its own unique issues because of its much greater scope and scale of operations, and its correspondingly more

complex compliance and reporting requirements.It is also approaching limitations in operationalcapacity brought about by an unanticipated increasein passenger numbers and the type of operationsconducted at the airport.

INTEGRATION WITH OTHER RISK-BASED MANAGEMENT PROGRAMSBecause of the increased scope, scale and complexityof activities it conducts and supports, Sunshine CoastAirport manages a number of risk-based complianceprograms in addition to the SMS. These includean environment management plan, a security risk management plan (part of the Transport SecurityProgram), a workplace health and safety programand an asset management program.

As well as these statutory requirements, all signifi cantprojects undertaken at the airport involve a proactiveformal risk management component.

Sunshine Coast Regional Council also requires allsignifi cant risks (including business continuity, fi nancialand legal liability issues) to be managed as an outcomeof the airport’s annual performance plan.

Managing these separate programs creates asignifi cant issue. They do not all have the same risk criteria—likelihood and consequence descriptors, risk matrix, management and reporting actions required,level of acceptable risk etc. This disparity makesallocating resources effectively

Photo: courtesy Sunshine Coast Airport

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more diffi cult, and degrades the value of risk information communicated to some stakeholders.

Working with the Australian Airports Association, CASA developed an electronic SMS builder to provide airports a simple means of compliance, and a consistent basis for assessment by aerodrome inspectors. Unfortunately the risk criteria, such as likelihood, consequence, level of risk etc did not align with the council’s risk policy. Using the CASA methodology, an ‘extreme’ consequence (multiple fatalities) with a ‘rare’ likelihood, managed with treatments that had limited effect resulted in a ‘low’ risk, whereas using the council’s framework, a similar scenario resulted in a ‘high’ level of risk.(That electronic SMS builder is no longer available. See MAAT below.)

Council’s risk management database also did not cater for aviation operational safety risk. For the airport, this was measured fi nancially as a cost/revenue consequence, in safety outcomes and also in terms of interruption to operations. So, in the interests of simplifying compliance and program management, the SMS is a standalone program using CASA’s template until all risk-based management programs can be coherently incorporated into the council system.

Risk criteria and risk assessment have to be uniform, so that across council, various departments and business units can communicate levels of risk effectively.

Work is currently underway to integrate these risk management programs, with a single database for recording the risk register and treatment plan, so that all risks managed by the airport can be identifi ed, assessed, treated, monitored and reviewed within a single management program, using the same criteria. This integration will make identifying, reporting and managing risks more effi cient, improve decision making and resource allocation, and reduce training requirements for system users.

TRAININGThere is a signifi cant number of staff and contractors who conduct operations at the airport, which has necessitated a more formalised training and induction program as part of the SMS.

Contractors undertake a formal induction prior to conducting works on the airport, and are subject to ongoing scrutiny for compliance.

In their induction, new staff members receive SMS and associated safety management procedure training. Safety management issues are discussed at monthly staff meetings.

Airside staff such as safety/reporting/security offi cers and operational management staff also undertake further training in safety procedures documented in the aerodrome manual and standard operating procedures manual.

For more information

Safety Management Manual ICAO (2006). Doc.9859-AN/460 Second edition, downloadable from www.icao.intAlso SMS training material available from the ICAO website.

Safety management systems for regular public transport operations. CAAP SMS-1(0) Civil Aviation Advisory Publication, January 2009

Integration of human factors into safety management systems CAAP SMS-2(0) Civil Aviation Advisory Publication, January 2009

Human factors & non-technical skills training for regular public transport operations CAAP SMS-3(0) Civil Aviation Advisory Publication, January 2009

Safety management – making it fi t Feature article Flight Safety Australia March-April 2002

Manual authoring and assessment tool (MAAT) Online tool – email sms@casa.gov.au for more information

www.surveymonkey.com Online tool designed to enable anyone to create online surveys quickly andeasily. Free (for up to 100 responses stored).

www.saiglobal.comInternational quality certifi cation body, which licenses accreditedorganisations with the internationally-recognised ‘tick’ across fi ve main areas: quality, OH&S, environment, information security and food safety.