SMS vs the Management of Safety – what’s the difference?
Throughout our industry, there is a perception that a Safety Management System (SMS) is some complex, burdensome and mythical beast; this new (or actually not so new) and shiny thing that we must bolt on to our organisations as an additional requirement, overtaking everything that has gone before it. It is another thing we have to spend time and effort developing and writing another manual for. We talk about SMS into Pt M, SMS into Pt 21 etc, as if we are forcing a set of requirements into the existing regulatory construct. In reality, however, the intent is subtly different.
Whilst ICAO Annex 19 talks about SMS, the words of the most mature extant EASA regulation (ORO.GEN.200) in fact does not even talk about SMS, it refers to the Management System. Am I splitting hairs or is there a reason for this? The key point in this is that rather than requiring an additional isolated management system on top of the compliance monitoring (or Quality) management system, the intent behind the words is that organisations develop a way of running their business that makes sure they are compliant and safe. That is the fundamental requirement of all aviation regulations, so in reality, there is little different to what we should already be doing. Compliance with the intent of the regulation is at the very heart of a safe operation – that’s why the regulations were written in the first place!
From our broad exposure across the regulators and the regulated organisations, we are noticing a real difference between two camps; those that consider SMS as a stand-alone additional requirement and treat it almost in isolation as something to be done because the regulator requires it, and those that have considered the intent of the changing regulations, recognising the need to be compliant and safe as two very intertwined and co-dependent partners.
From our perspective, the effective management of safety deals with both together and delivers considerable business benefit in terms of protection from financial, reputational and legal harm as well as risk to life. We are seeing some organisations adopt the principles and techniques to manage safety effectively already, well before the regulations require them to because they can see the broader value to themselves, their people and their customers.
SMS, Management System, Management of Safety – in the end they are simply words that have been taken by some to mean the same thing at times; is it not the intent of the words we should be focussing on? Regardless of what you choose to call it, if the intent of the regulation (to protect your organisation from harm), is embedded in your approach to managing your organisation and your culture, it becomes ‘Business as Usual’, reduces the burden on managers in the long run and can improve all aspects of business performance. Who wouldn’t want that?