The concept of the Safety Management System (SMS) in aviation has gathered pace in recent years.Organisations across the industry have developed and implemented effective systems to help them proactively and systematically identify their hazards and risks and put in place measures to mitigate them.
As part of its transformation to a risk based approach to regulation, the UK Civil Aviation Authority (UK CAA) has decided to follow suit and develop its own Regulatory SMS (RSMS), one that is internal to the CAA but looks both outwardly and inwardly. There are many benefits to the regulator following a more holistic, structured and systematic approach to safety regulation.
The UK CAA’s RSMS sits at the heart of its approach to Risk Based Surveillance (RBS). ICAO Annex 19, combined with the EASA Authority Requirements (ARs) for EU Member States, requires national authorities to implement their own management systems for safety regulation.
Early on in the transformation to RBS, the UK CAA recognised the need to go beyond the requirements and take a customised approach. Before embarking on the design and development of a RSMS, the UK CAA first conducted a thorough analysis of the ARs and the ICAO SMS framework. This led to the development of a bespoke framework that took the best learning from industry SMS implementation whilst also ensuring compliance with EASA requirements. The UK CAA’s RSMS consists of all the main components that you’d expect to see in an industry SMS, such as a safety policy, risk management process, safety assurance processes and tailored training programmes.
The main difference between a Regulatory SMS and the SMS of an aviation service provider is that the Regulator doesn’t own the safety risk; the risk is owned by the airline, airports and other organisations. The Regulator’s task is to identify where safety challenges exist and work with the industry to help them manage their risks. This is an important distinction to make. The UK CAA’s ability to act as an information and intelligence conduit allows it to develop unique perspectives on the management of safety and identify safety issues that run across different organisations and industry sectors.
One of the keys to success, for both public and private organisations, is a common understanding of what must be achieved and how. The RSMS is the common system that provides the UK CAA with a unified approach. It ensures that everybody understands their own individual roles and can communicate safety intelligence in a standardised way across professional boundaries. It brings all safety management aspects under a single system and gives everybody the opportunity and tools to influence safety outcomes.
The Regulatory SMS works in much the same way as its industry cousin. Data is gathered from a multitude of sources – including audit findings, Mandatory Occurrence Reports (MORs) and expert knowledge of staff. It is then analysed by a dedicated team who work with technical specialists to identify aviation safety risks from the analysed data. These risks are then assessed and prioritised using a similar methodology to that used in many industry safety management systems. The risks can be escalated to an appropriate UK CAA safety management forum, where decisions can be made about how the Regulator can best influence the management of the risks.
There are various options for the UK CAA to
influence safety, such as:
- Altering the focus of oversight for a whole sector of industry towards known risks,
- A safety improvement project could be commissioned, or
- New policies and guidance could be published.
Regardless of the chosen option, the RSMS ensures that activities undertaken by the Regulator are clearly defined, scoped and launched under pan-CAA governance and knowledge, with the focus being on the highest priority risks.
The greatest benefit of the UK CAA’s RSMS comes from building ‘pictures’ of risk at various levels of the aviation system. Industry sector risk pictures and a total aviation system risk picture allows the Regulator to share safety intelligence internally and also across the industry, enabling a cross-pollination of safety risk knowledge, sharing the best ways that the Regulator has come across to mitigate the risks.
A successful transition to Risk Based Surveillance will require both the industry and the regulator to adapt to new challenges and be novel and collaborative in their joint approach to safety management. A Regulatory SMS has given the UK CAA the best opportunity to positively influence safety outcomes for UK consumers and the travelling public worldwide by systemically prioritising its resources towards the most significant safety risks.
