Start 1.0 – Identify Information Required 2.0 – Gather Information 3.0 – Assign Ratings in the SMS Evaluation Tables 4.0 – Record Evidence to Support Ratings 5.0 – Identify Underlying SSDs 6.0 –Implement Improvement Initiatives Safety Management System 1-SO-06 March 31, 2012 Self-Evaluation Guide Page 1 of 12 1.0 - Identify information required Examine SMS Evaluation tables and identify the information required to evaluate each sub-function Information comes from documents, interviews and observation 2.0 – Gather information Conduct interviews, review documents Obtain information from multiple sources to ensure accuracy and to eliminate bias 3.0 – Assign ratings in the SMS evaluation tables Rate performance in each sub-function on scale of 1 – 7 Ratings from 1 – 4 relate to soundness Ratings from 4 – 6 relate to appropriateness Ratings from 6 – 7 relate to effectiveness 4.0 – Record evidence to support ratings Ratings are subjective and so must be supported by evidence Do not identify people by name in the evidence column 5.0 - Identify underlying system safety deficiencies System Safety Deficiencies (SSDs) prevent a company from achieving effective performance Identify underlying conditions that contribute to the issues identified in the evaluation 6.0 – Implement improvement initiatives Implement activities to improve performance Prioritise improvement activities based on risk Record activities in the QA or SMS database to ensure actions are completed and their effectiveness is assessed Finish Figure 1 – Safety Management System Self-Evaluation Process Safety Management System 1-SO-06 March 31, 2012 Self-Evaluation Guide Page 2 of 12 Introduction This user guide provides Certificate Holders with instructions on completing a safety management system self-evaluation, and provides a template with which to document a completed self-evaluation, for both internal use and for submission to BDCA if requested. Background One of the key’s to sound safety management is monitoring safety performance. If an organization has been operating an approved SMS for several years, using a systematic process to understand current safety-management performance is essential. When completing a self-evaluation of safety management performance, it is important to understand the concepts of hazard, risk, system safety deficiency (SSD) and mitigation. Refer to document 1-SO-02 Key Definitions for BDCA’s definitions of these ideas. Purpose A safety management self-evaluation allows a Certificate Holder already operating an SMS to determine the degree to which their SMS is reducing safety-risks to ALARP, and to identify areas of strong and weak safety-risk management so that improvement initiatives can be implemented. Recommended Approach For best results, assign one or two people to complete the self-evaluation. The personnel chosen to complete the evaluation should be independent from the processes being evaluated. To do a thorough evaluation, they should have a critical and analytical mindset: personnel with some experience as auditors or conducting occurrence/incident investigations are good candidates. The safety management self-evaluation process is performance-based. Therefore, while auditing skills (such as interviewing, identifying sources of information for review, etc.) are useful skills to the evaluation process, the safety management self-evaluation is not an audit. Some elements of the self-evaluation may require the evaluator to compare the company’s processes against those required by regulation, though the majority of the areas examined in the selfevaluation relate to performance (i.e., the outputs of existing company processes), not to regulated standards. BDCA has identified five Functions that together constitute effective safety-risk management. For each function, BDCA has created a Statement of Ideal Functionality. This is the performance standard against which each Function will be rated. The Statements of Ideal Functionality can be seen at the top of each page in Appendix A. These are the same tables used by BDCA to evaluate the effectiveness of certificate holders’ SMS. Safety Management System 1-SO-06 March 31, 2012 Self-Evaluation Guide Page 3 of 12 There are three indicators of safety management performance: Soundness - Does the company’s SMS have a foundation in documentation, process and management support necessary to manage safety-risks to a level as low as reasonably practicable? Appropriateness – Does the SMS consistently target hazards specific to the certificate holder? Does the SMS ensure that the organization understands and manages operational, human and organizational factors with a view to improving safety management? Effectiveness – Are processes being employed to continuously improve proactive safety management and safety performance? Does a positive safety culture exist throughout the organization? Does the SMS ensure integrated management of risk and the achievement of ALARP as a way of doing business? Assigning ratings in terms of soundness, appropriateness and effectiveness makes it easier to communicate what type of actions may be needed to address a given deficiency in performance. For example, issues related to soundness may require additional training, documentation, or coaching. Issues related to effectiveness may require new management behaviours or updated rewards and recognition systems. It is not unusual for a single organization to have ratings that range from barely ‘sound’ to highly ‘effective’, depending on the part of the company that is being evaluated, and the function being assessed. Scores from 1 to 7 are applied to indicate the level of soundness, appropriateness or effectiveness of an aspect of the company’s SMS. This achieves two results: first, it allows the company to quickly determine its areas of greatest weakness; second, it allows the company and BDCA to track the company’s performance through time. Safety Management System 1-SO-06 March 31, 2012 Self-Evaluation Guide Page 4 of 12 Steps to Complete a Safety Management Self-Evaluation Figure 1 depicts BDCA’s recommended process for completing a safety management selfevaluation, described in further detail in the paragraphs that follow. 1.0 – Identify Information Required The evaluation will examine different types of information, including: the documentation and training that underpins the SMS and provides guidance to managers and staff; day-to-day safety-risk management activities (such as hazard and event reporting, mitigating actions, daily management activities, and the integration of operational and technical activities with SMSrelated activities); and evidence that risk management and SMS-related activities influence long term planning, allocation of resources, etc. Activities in most SMS self-evaluations will consist of: The review of policies, procedures and guidelines related to the SMS; The examination of training records and course materials related to the SMS and technical functions; A review of activities resulting from internal and/or external audits or evaluations; The review of reports of hazards and events, and the follow-up actions; Interviews with a sample of managers and staff; and The observation of daily activities related to the company’s day-to-day operations. It is important to reduce bias when evaluating an SMS. People close to the SMS will be good sources of information, but it is possible that they may be blind to issues. In order to minimize and hopefully eliminate bias and to get different perspectives on the effectiveness of the SMS, interview middle managers, supervisors and line employees about their experiences with the SMS, and their thoughts on how it is performing. 2.0 - Gather Information Conduct interviews and examine documents to find evidence of SMS performance. Refer to the statements of ideal functionality and the sub-function descriptions located in the SMS Evaluation Tables (Appendix A) to help develop questions. Multiple lines of evidence for each area will result in more accurate measures of performance. Safety Management System 1-SO-06 March 31, 2012 Self-Evaluation Guide Page 5 of 12 Interview Behaviours DO DON’T Start and end on time Intimidate the interviewee Have open-ended questions prepared when Ask too many closed questions: they can lead you go into the interview. the interviewee to the answer, and bias the interview Introduce yourself and the interview purpose Interrupt or talk over the interviewee to put the person at ease Listen attentively Bring more than two interviewers to an interview Interview in pairs when possible Conduct an interview with someone’s supervisor in the room. Take notes Get distracted (e.g., don’t check emails) Answer questions about the evaluation Ignore the interviewee’s answers process. Take some time to establish rapport with the Stick purely to prepared questions: adapt your interviewee. interview as needed to get the best information. Ask follow-up questions to gain deeper understanding. Turn off your cell-phone or blackberry 3.0 - Assign Ratings in the SMS Evaluation Table The SMS Evaluation Tables (Appendix A) are the tools used to communicate a Certificate Holder’s rating in each of the five functions of an effective SMS. When assigning scores using the guidance below, refer to the statements of “Ideal Functionality” and to the different sub-functions on the template to determine what constitutes ideal functionality. This will help you to determine where the company being assessed falls on the spectrum of performance. Ratings of 1 to 4 Ratings of 1 to 4 relate to Soundness, which generally applies to the foundation of the service provider’s safety management – the structure that enables it to consistently manage safety risks. Ratings of 1 to 4 are to be expected in any organization that has only recently implemented an SMS. A score of ‘1’ in any sub-function indicates that the functionality is absent and that the service provider is unaware of the need for the functionality or is not planning to develop the specified functionality. Safety Management System 1-SO-06 March 31, 2012 Self-Evaluation Guide Page 6 of 12 A score of ‘2’ is applied if the functionality is absent or nascent, but the service provider is aware of the need for such functionality and plans to address the shortfall. A rating of ‘3’ is normally the minimum required for an assessment of ‘sound’ safety management. Scores less than 3 indicate the function is not sound – that it lacks documentation, knowledge and/or commitment to function. Ratings of 2 to 4 in a mature SMS may indicate problems in the company’s safety culture, where the processes have become ineffective or are not consistently followed, or top-management commitment to proactive safety management has waned or been eroded by complacency. Ratings of 4 to 6 Ratings of 4 to 6 generally relate to the Appropriateness of the service provider’s SMS. In other words, the company is conducting the “right activities for the right reasons”. If a company’s SMS is Appropriate, priorities within the company are risk-based. The organization demonstrates that it is well on the way to being proactive. Hazards and risks are identified before changes are initiated, and the mitigating actions are taken as necessary. Staff have (and are employing) the necessary skills to manage risk. Safety management is integrated with other management systems, and with business processes. Measures of safety performance are sought and used. Ratings of 6 to 7 Ratings of 6 to 7 indicate Effective functionality, and normally co-relate with a positive safety culture. In a company with an Effective SMS, proactive safety management is consistently conducted, and there are signs of constant “correction” in how the organisation manages safety risks – at the individual level, and as a collective entity. The organization is resilient: able to identify and recover from abnormal conditions quickly and with minimal loss. The company at all levels has a healthy sense of unease which helps to combat complacency. 4.0 – Record Evidence to Support Ratings The last column in the SMS Evaluation Tables provides a space for the evaluator to record evidence to support the findings in each of the sub-functions of an effective SMS. Concrete evidence is crucial to the accuracy and credibility of an SMS self-evaluation, since the ratings assigned are subjective. It is very important that people reading the evaluation report understand why a given rating was assigned. Safety Management System 1-SO-06 March 31, 2012 Self-Evaluation Guide Page 7 of 12 5.0 - Identify Underlying System Safety Deficiencies Sometimes issues identified with the way an SMS is performing are related to an underlying condition known as a System Safety Deficiency (SSD), which is a condition or circumstance that allows hazards of a like nature to exist. Examples of SSDs include: - Lack of management support for non-punitive reporting or the development of a justculture; Lack of documented key-processes, such as change management or risk assessment; Inadequate QA processes related to work or to documentation; Less than adequate personnel resources or training in safety-critical areas; Etc. If underlying SSDs identified through self-evaluation are not addressed, the company can expect to see repeat problems and will be exposed to a greater degree of safety risk. 6.0 –Implement Improvement Initiatives Improvement initiatives should be developed based on the ratings assigned in the tables and the SSDs identified. Activities should be prioritised according to the effect they will have on aviation safety (i.e., they should be prioritised based on risk). Activities should be tracked in the company’s QA or SMS database to ensure that they are tracked to completion and evaluated for effectiveness. Conclusion Self-evaluation of safety management is an excellent way to build understanding of the performance of an SMS, and to identify areas for improvement. The BDCA is available to review any SMS self-evaluation report and will provide feedback on the application of the process, the conclusions reached and the actions taken. 1-SO-06 March 31, 2012 Page 8 of 12 APPENDIX A SMS Evaluation Tables Function 1 - Proactive & Comprehensive Safety-risk Management. All components of the organisation are actively engaged in or support the proactive management of safety-risks (e.g. operational, technical, financial, HR components, etc.). Safety-risk management is top-down, and integrated with strategic, business and HR planning and performance measurement. The SMS is integrated with other management systems (e.g. financial, HR, quality, etc.). Safety-risk management by contracted service providers, partners and stakeholders is aligned with and contributes to the SMS. Function Proactive & comprehensive safety management a. Performance-based safety policy (e.g. strategic safety goal) and principles (e.g. sharing and using safety-related information) guide the organisation’s direction, and its staff’s behaviours b. Safety goals & objectives are explicitly set (safety planning) and measured, and progress reported (accountability), to continuously improve safety management and performance. c. Safety planning is integrated with project, business and strategic planning d. Department-wide safety management policies & procedures are applied (e.g. committees; reporting programs); and integrated with other company policies/procedures (operational/organizational) e. Policies and processes for proactive safety-risk management are employed when introducing change (operational, technical, organizational) f. Safety management activities of sub-contracted service providers (aviation and non-aviation) are compatible and effectively integrate with the Certificate Holder’s safety management. Not Present Exists in Part Exists Completely 1 2 3 4 5 6 7 ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ Observations / Evidence (cite sources) Attachment Page 8 of 5 1-SO-06 March 31, 2012 Page 9 of 12 APPENDIX A SMS Evaluation Tables Function 2 - Individual and Organizational Reliability The Accountable Manager is responsible for safety performance, and formally delegates responsibility for specific functions and tasks, which are clearly articulated in up-to-date job descriptions. There are neither gaps nor overlaps, and spheres of influence are respected. Managers and staff are qualified and proficient. Procedures are documented, up-to-date and employed by all. Processes to continuously improve organizational performance are embraced and valued by all. Function Individual and organizational reliability a. b. c. d. e. f. g. There are explicit, unambiguous, aligned roles and responsibilities within the organization which are known, employed and respected. There are explicit and unambiguous roles and responsibilities between the organization, contracted service providers and other stakeholders. Qualified staff demonstrate safety management & technical competence (e.g. training, certified, performance evaluation). All components of the organisation demonstrate consistent adherence with: - regulations & standards; - operational, technical & safety management policies/processes. Documents are complete, controlled, up to date and employed. Organisational reliability is periodically measured (e.g. risk-based audit program) and the results employed. Processes are actively employed to continuously improve organisational performance. Not Present Exists in Part Exists Completely 1 2 3 4 5 6 7 ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ Observations / Evidence (cite sources) Attachment Page 9 of 5 1-SO-06 March 31, 2012 Page 10 of 12 APPENDIX A SMS Evaluation Tables Function 3 - Explicit Safety Risk Management Mechanisms are in place to identify, analyse, assess and manage hazards and risks, with a focus on their organisational “roots” - system safety deficiencies. Safety-risk management is conducted in all components of the organisation. Hazard analyses are employed proactively during the development and deployment of technical systems, and during operational and organisational changes. Hazards and SSDs are identified from numerous sources, including reporting programs, audits and inspections, committees, evaluations and surveys, etc. Information is employed in day-to-day decisions, and longer-terms plans to improve or sustain safety performance. Function Explicit safety-risk management a. b. c. d. e. f. g. h. i. j. Safety policy & principles “drive” safety management decisions and staff activities throughout the organisation Information from an up-to-date safety-risk profile shapes short- and long-term decisions throughout the organisation The occurrence (event) reporting program is trusted and understood, and consistently employed (input, analysis, output) The hazard reporting program is trusted and understood, and consistently employed (input, analysis, output) Explicit hazard analyses and risk assessments are consistently and effectively employed to manage future and ongoing safety-risks System safety deficiencies are periodically identified by analysing safety-related information Company-wide safety management data is collected, analysed and employed in tactical and strategic decisions Where applicable, fatigue is consistently and effectively managed Abnormal operations are anticipated, planned for and managed Up-to-date emergency response is planned, coordinated and tested/measured Not Present 1 2 Exists in Part 3 4 5 Exists Completely 6 7 ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ Observations / Evidence (cite sources) Attachment Page 10 of 5 1-SO-06 March 31, 2012 Page 11 of 12 APPENDIX A SMS Evaluation Tables Function 4 - Safety Culture Everyone in the company understands their role and is committed to sharing information so that the risks related to organizational, human and operational factors are actively managed. Proactive safety management is embraced throughout the organization. There is a free flow of safetyrelated information vertically and laterally, within and outside the organization. The positive safety culture provides organisational resiliency, which enables the organisation’s SMS to remain appropriate and effective during times of change. Function Not Present Exists in Part Exists Completely 1 2 3 4 5 6 7 Safety information is valued and used at all levels of the organisation. It is obtained from consistent, unfettered and active (3-way) communication throughout the organisation. ☐ ☐ ☐ ☐ ☐ ☐ ☐ Safety information is actively sought and communicated with stakeholders, including BDCA. ☐ ☐ ☐ ☐ ☐ ☐ ☐ c. Staff have confidence in non-punitive reporting. ☐ ☐ ☐ ☐ ☐ ☐ ☐ d. Managers trust and employ validated, safetyrelated information from all sources. ☐ ☐ ☐ ☐ ☐ ☐ ☐ e. Everyone from all levels “walks the talk” and are actively engaged in proactive safety management. ☐ ☐ ☐ ☐ ☐ ☐ ☐ Safety Culture a. b. Observations / Evidence (cite sources) Attachment Page 11 of 5 1-SO-06 March 31, 2012 Page 12 of 12 APPENDIX A SMS Evaluation Tables Function 5 - Safety Measurement The organisation seeks and employs feedback regarding the effectiveness of its safety management activities (e.g., internal audits, selfassessments, meeting debriefs). This information is used to improve the SMS, the company’s other management systems, and the company’s safety performance. Measures are used to modify day-to-day activities and priorities; and influence strategic initiatives. Function Safety measurement The strategic safety performance of the organisation is consistently and periodically measured, and the results employed to continue or change ongoing initiatives to manage safety risks to a level as low as reasonably practicable. (This inquiry aligns with 1 b.) b. Safety-related information from across the company is systematically and consistently collected, analysed and employed to identify areas of strong or weak safety performance (and SMS performance). c. System safety deficiencies (SSDs) are assessed in terms of safety significance to guide priorities to improve safety management/performance d. Risk-based audit and evaluation plans are employed to obtain independent measures of safety performance (internal or third party), including measures of soundness (i.e. adherence to processes) and of appropriateness and effectiveness (i.e. reduction in safety risks or improvements to safety management performance). (Measures of soundness align with lines of inquiry from section 2, and particularly 2 f. Measures of appropriateness and effectiveness align with those in sections 3 and 4). Not Present Exists in Part Exists Completely 1 2 3 4 5 6 7 ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ ☐ Observations / Evidence (cite sources) a. Attachment Page 12 of 5