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An aviation Safety Management System (SMS) as proposed in ICAO Annex 19, is consolidated on four pillars:
- Safety Policy and Objectives;
- Safety Risk Management;
- Safety Assurance;
- Safety Promotion.
The end objective of an SMS is to foster the required Safety Culture within an organisation which rests upon the four pillars listed above, and before starting looking at the Safety Culture, it is important to establish these pillars first.
All EASA Approved Part 145 Organisations are required to design, document and implement an SMS and its related processes by the 2nd December 2024. Further details and guidance are available on EASA’s GUIDE FOR COMPLIANCE UPON REGULATION (EU) 2021/1963.
In this article the first pillar of SMS, “Safety Policy and Objectives” is discussed.
Management Commitment towards Safety
The senior management of an organisation is normally responsible to define the objectives and targets to be met. This applies also for the SMS. The accountable manager together with his group of nominated persons and senior managers, forming the Safety Review Board, are to define the safety objectives and the safety policy adopted by the organisation. The SMS Safety Objectives and Policies, once defined, are to be laid down in what is referred to as the Safety Policy Statement.
SMS Safety Policy Statement
Ref: EASA 145.A.200(a)(2)
The SMS Safety Policy Statement can be thought of as a description of the overall philosophies and principles of the organisation with regard to Safety and it should:
- reflect organisational commitments towards safety, and its proactive and systematic management, including the promotion of a positive safety culture;
- include internal reporting principles, and encourage personnel to report maintenance-related errors, incidents and hazards;
- recognise the need for all personnel to cooperate with the compliance monitoring and internal investigations;
- Show senior management commitment to provide all the necessary resources (human, financial or otherwise) to implement and support the achievement of the safety objectives set-out by the organisation;
- be endorsed and signed by the accountable manager;
In addition to the above the Safety Policy should clearly indicate which types of behaviours are unacceptable related to the service provider’s aviation activities and include the circumstances under which disciplinary action would not apply.
There may be additional elements that are to be included in the Safety Policy Statement which are mandated by the local competent airworthiness authorities. It is therefore highly recommended that any recommendations as published by the respective competent authorities are referred to and implemented when compiling the statement.
The SMS Safety policy is to be included in the organisation Maintenance Organisation Exposition MOE (Ref: EASA 145.A.70) and / or in the Safety Management System Manual (SMSM).
The Safety Policy is to be prominently displayed within the organisation both physically as well as virtually as applicable.
The physical display of the Safety Policy is achieved normally by framing and displaying a physical high quality print version of the policy in common areas such as meeting rooms, foyers, common office spaces and in the hangar.
Virtual display is normally achieved by publishing the Safety Policy Statement on the organisation’s intranet sites.
Reviewing the SMS Safety Policy
The SMS Safety Policy is to be kept up-to-date and relevant to the organisation. This means that the organisation is required to look at the Safety Policy and evaluate its relevance vis-à-vis the situational circumstances of the organisation.
It is empirical, therefore, that a procedure or a process is developed and implemented that would ensure that the Safety Policy is kept “alive”. Some common aviation industry practices include the review of the policy at least annually in the last quarter of the calendar year during a Safety Review Board (SRB) Meeting. The SRB is to assess the Safety Performance Indicators for that year and determine whether the objectives are still relevant or not and adjust the Safety Policy Statement as needed.
Integrating the SMS Safety Policy Statement
Organisations may hold multiple organisation certifications within the scope of EU Regulation 2018/1139 as well as having other certifications such as (IOSA certification, EN 9110 certification and ISO 14001) and may prefer to integrate the Management System into one to avoid duplication. This approach gives the opportunity to the organisation to harmonize the different management system processes and adopt a common approach. It makes the implementation and upkeep of a Safety Management System much more efficient by utilizing existing organisational structures.
In this case the SMS becomes part of an Integrated Management System. In this scenario the Safety Policy Statement may be integrated with the other Policy Statements required by the other certifications held by the organisation. The organisation in this case might need to conduct a review of all the different requirements to identify any common requirements that might exist. Attention should be made to ensure that when a common integrated policy statement is compiled, the policy statement complies with all the different requirements coming from the different certifications held by the organisation.
The senior management team of an organisation plays a very important role in defining the SMS Safety Policy and Objectives and it is also thus logical that the same senior management upholds the principles, values and beliefs of the same statement in the discharge of their duties.
The SMS Safety Policy is the first step in implementing an effective Safety management System as it reflects the organisation’s commitment and approach toward Safety. It is very important all employees within organisation are familiar with the policy as it should act as a “compass” when making decisions during the accomplishment of maintenance activities.