In January 2009, when Armando Martinez became director of safety at Miami Air International, the safety management system (SMS) concept still was being refined, but already vendors were showing up at our door offering solutions. Working for a small air carrier, Martinez knew that we did not have unlimited dollars or time to throw at any problem, much less one that didn’t produce revenue, so he began to network with others from the industry and the U.S. Federal Aviation Administration (FAA) to get their perspectives and to see what resources were available.
During the process, we learned several things. First, the FAA was looking for small carriers to volunteer to participate in the pilot program. Second, we already had a program to track accidents and incidents and it could be expanded to handle SMS requirements: the Aviation Safety Action Program Web-Based Application Tool (ASAP/WBAT) developed by Universal Technical Resource Services (UTRS). Last, the bond that would hold it all together, and the key to successful implementation of a robust SMS, would be the development of a content management system (CMS) built around the principles of the SMS framework.
Then-CEO Ross Fischer (a founder of Miami Air in 1990) gave us our marching orders: Miami Air would volunteer to participate in the FAA’s SMS pilot program. He knew that not only would we be part of the process, but also that Miami Air would receive extensive assistance.
Miami Air is a member of the National Air Carrier Association (NACA), and we worked with other NACA members to expand the use of the WBAT software to track safety incidents and audits. Armed with these cost-free resources, Martinez felt Miami Air was poised to begin the process. Free is good, when you are a small carrier. With backing from the CEO, my offer of part-time help as his executive assistant, and a fair but small budget, we launched Miami Air on the path toward implementing an SMS.
The management team at Miami Air always has had a strong positive attitude toward safety. Good safety practices support lower insurance premiums and the ability to maintain valuable contracts with government agencies as well as serve high-end customers such as sports teams, all of which enhance the bottom line. However, the “silo mentality,” though not pervasive, was a problem when it became apparent that everyone — operations, maintenance, quality assurance, finance and all other company departments — would have to be placed under the umbrella of the Safety Department. The cooperation we received from upper management was essential to the attitude adjustments necessary to engender a cohesive workforce that supported the SMS at every level.
In an effort to alleviate some of the apprehension that accompanies change, we tried to make the process as simple as possible. During the implementation, we realized we only had to ask for two completely new things for company personnel to do. First, we had to train and encourage every employee to use WBAT for reporting safety concerns, incidents and accidents.
Second, we asked management to document the results of risk assessments as hazards or risks were encountered during the normal course of business. In the past, management promptly addressed risks and hazards, but the actions rarely were documented. Given the longevity of the management group at Miami Air, there was a strong reliance on “tribal knowledge” and the fact that if the same hazard was encountered again, the people who had handled it in the past were there to provide the necessary guidance to avoid or mitigate it.
Another problem was finding a method to manage the company’s SMS. Researching, analyzing and recording responses according to SMS expectations were daunting tasks. We went back to management to request a full-time analyst to help manage the SMS implementation. In February 2011, we hired Dustin Quiel to manage the project. With Quiel’s help, we could cover not only the handling of day-to-day SMS responsibilities, but we also had an opportunity to grasp the complexities of the changes that would be required to comply with this new regulatory mandate. He found ways to integrate data from existing company programs as well as put SMS to work in the most effective and least painful way.
A new problem arose: The answers we considered acceptable were falling short of FAA requirements. The guidance of Derek Cheatham — our FAA mentor for this process through frequent calibration meetings — became our touchstone for resolving problems. Cheatham challenged our answers, pointed out the shortfalls and provided encouragement to keep to the process.
The flexibility of the WBAT program became more evident, and after extensive discussions with Nicky S. Armour and Harry Van Soestbergen of UTRS, an SMS implementation module was developed, allowing us to easily track our progress.
During the 11th WBAT conference in October 2011, however, the FAA shocked the industry when it announced a cut in funding for the UTRS WBAT project. Miami Air, along with many other carriers, already was heavily reliant on the WBAT system, having implemented a combination of the WBAT modules, including the SMS implementation, on-the-job injury reporting, audits, ASAP and incident reporting.
Fischer immediately began writing letters to the FAA stressing the importance of the support needed by small carriers to implement SMS. He emphasized that the WBAT system was an essential aid in implementing SMS for many companies operating on thin margins. Through the efforts of a letter-writing campaign, WBAT funding was continued, though with reduced manpower. However, we recognize that eventually with further budget cuts, WBAT funding will again come under serious scrutiny.
To exit SMS Level One,1 Miami Air developed an overall plan to meet major landmarks and an additional plan for accomplishing each SMS framework requirement. The Safety Department determined which of the detailed gap analysis questions it could research and answer and apportioned the rest to the other departments.
The basic steps to exit Level One were:
- Assess and record the extent to which Miami Air complied with the detailed gap analysis questions;
- Formulate an implementation timeline; and,
- Schedule the Level One exit with the FAA’s SMS Program Office.
If we thought getting through Level One was a hard work, we learned that a more labor-intensive stage was just beginning. Implementation of the plan was the next step, and it required documentation, enforcement, training and meticulous record keeping. In addition to moving forward with Level Two, Fischer left his position as CEO to become chairman of the company’s board of directors. Jim Proia, also a founder of Miami Air and writer of all the manuals for the airline’s initial certification, succeeded him. Proia’s knowledge and expertise made the leadership transition seamless. He was already on-board with the implementation and a staunch supporter of the SMS. Additionally, Proia had been instrumental in acquiring the CMS, as he was thoroughly knowledgeable on technical publications at Miami Air.
Implementation required that internal and external audits be scheduled, recorded and analyzed in WBAT. Additionally, extensive changes had to be made to the safety manual and other manuals throughout the organization. Finally, we had to achieve consistencies and interfacing of our company manuals, and we had to create an organization manual to delineate the lines of authority and the responsibility for SMS.
The key component of this process required that Miami Air purchase a CMS to help us comply with SMS requirements. After much research, we purchased and helped develop a low-cost product from SiberLogic, a software developer from Canada. Alex Povzner, president of SiberLogic, was interested in adapting his company’s software for the aviation industry and SMS requirements. This product would help ensure that we had consistency and common interfacing across our manuals, managed change and maintained a hazard registry.
Out of Level Two
Other requirements we had to address to exit Level Two were creating a risk matrix, a risk management flowchart, including the safety risk management and safety assurance processes, and safety objectives. Again, good risk management was in place at Miami Air, but it had never been thoroughly analyzed or documented in a way that was accessible to everyone. Now, we had to put the various components together, publish them and enforce the consistent use of these tools throughout the organization. We had to write safety objectives and communicate them to management and staff.
Currently at Miami Air, all employees initially are trained in the use of the WBAT reporting system and require annual recurrent training. Each year, we tailor the recurrent training to incorporate lessons learned. This demonstrates that management uses the information provided by employees to mitigate or eliminate hazards.
As a result, we have consistently seen a growth in the use of the WBAT reporting system since implementation in 2009. With the creation of a safety committee that includes staff members from every department, we have found that employees are more comfortable about sharing safety concerns without fear of reprisal or recrimination. We are always gratified when an employee takes the time to share concerns or suggestions with members of management because it shows that what we are doing with our SMS is effective within the Safety Department and throughout Miami Air. Everyone understands they are part of the safety process. They have learned that their input is of value to the company and management takes their concerns seriously.
All employees needed to understand what “just culture” means and the difference between acceptable and unacceptable behavior. An honest mistake is acceptable, but a willful violation will never be tolerated. Miami Air has established a safety reporting hotline and although anonymous reporting is an FAA-required element of an SMS, employees still prefer to approach Martinez personally with their concerns. We have been able to nurture a just culture based on trust.
To accomplish this, and as part of the overall SMS implementation, we created training modules to teach management and the general staff about the safety culture of Miami Air, the SMS rationale, the reporting aspect of the WBAT program and their roles in maintaining the highest practical level of safety. This training helped management and other employees understand the importance of cooperation in safety, because the main theme of SMS is that there should be a balance between the highest practical level of safety and profitability.
Miami Air previously had encouraged the use of tools to keep safety in the forefront of all of its operations, but there seldom had been any coordination between departments using these tools. Flight Operations had its manuals, policies and procedures, in addition to the flight operational quality assurance and ASAP programs. Maintenance had TRAX and CASS, its own set of procedures and safety programs.2 Under the SMS, all programs need to be universal throughout the organization. Risks and hazards have to be identified, reported and managed using the same procedures. All outputs of these processes have to be pooled for analysis.
Currently, we are working to link our reporting system to our SiberLogic CMS, which will enable us to streamline our SMS processes.
As a small company, we could not afford to make a bad decision about the CMS, one of the most expensive components of the project. During the development of the CMS, we discovered we would need additional help to convert all of our manuals into the format required by the software (extensible hypertext markup language, or XHTML), while our Publications Departments were still required to continue performing their day-to-day functions. Management then authorized the hiring of two interns to help with the conversion.
Converting and publishing manuals in the CMS was a difficult and time-consuming task, but became much easier with the continuous technical support provided by staff at SiberLogic. They expanded the software to include a hazard registry, the ability to show compliance with U.S. Federal Aviation Regulations, operations specifications, FAA Air Transportation Oversight safety attribute inspections, and any other compliance standards such as International Air Transport Association Operational Safety Audits, those of the Department of Defense, etc. These features increased the efficiency of the company’s Technical Publications Departments and allowed the Safety Department to monitor hazards, assess the impact of changes, and ensure compliance — specific requirements of an SMS. SiberLogic’s Povzner and his team have worked with us to improve this software and create new features.
We also have made strides in educating our vendors and customers on our SMS program. We train our vendors on Miami Air procedures and encourage them to share safety concerns with us.
Education, integration and cooperation are integral tools in implementing and maintaining a robust and effective SMS. Miami Air’s success involved the tools, talent and support of its management team and the assistance provided by the FAA at all levels, from our local principal operations inspectors to the SMS Program Office in Washington.
The next challenge is demonstrating that the procedures, training and tools are working together as designed to achieve our goals of continuously operating with the highest practical level of safety. This will require objective evidence that we comply with the processes and elements of our SMS. Part of measuring the success of our SMS is positive communication of safety goals, response to incidents and safety concerns, and being proactive and predictive with gathered safety data.
- We have learned many things during this SMS journey and I would like to share some, with a caution that the culture, procedures and level of management support of every organization are different. We advise others:
- Start as soon as possible. This is a lengthy process and the SMS Part 5 regulation will have a strict timeline.
- Involve your company’s management and your local FAA office as much as possible and as early as possible.
- Establish a benchmark for your company and compare it to the SMS requirements. This will give you a clear picture of what your gaps are and the effort (e.g., manpower, budget) required.
- Do not reinvent the wheel. Familiarize yourself with all the programs currently in use in your company and build your SMS compliance on them.
- Use all available resources. A lot of free information is available. SMS and safety conferences are great sources of information. Network and share, talk to other carriers about their programs.
- There will naturally be some friction as you implement SMS. Do not be discouraged.
Armando Martinez and Dustin Quiel contributed to this article.
- Level One and Level Two are two of the four stages for developing an SMS. These definitions come from the SMS implementation guide and SMS framework documents published by the FAA. Level One is the planning stage, where an operator creates a plan for implementation of its SMS. Level Two is the actual implementation. Level Three is the demonstration (via safety assurance audits) of the SMS to show whether the implementation is working as designed. Level Four is the permanent stage of continuous improvement.
- TRAX is software used by Miami Air’s maintenance department for auditing, training, compliance trending and tracking. CASS stands for Continuous Airworthiness Surveillance System.