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Photo: Margo Marchbank

FSA JULY–AUG 09

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NOT SAFETY FIRST, BUT SAFETY ALWAYS
NOT SAFETY FIRST,
BUT SAFETY ALWAYS

Regular public transport operators are undergoing a transition to the proposed CASR Part 119, which will mandate safety management systems for ‘passenger transport services using aeroplanes or rotorcraft, and some categories of cargo transport’. It is envisaged that this will incorporate therefore not only Australia’s current 48 high and low-capacity regular public transport (RPT) operators, but will also include some additional 400 charter operators. Flight Safety editor, Margo Marchbank, in the first of a series of articles on SMS implementation, gives an overview.

‘I don’t believe in “safety first”, but “safety always”,’ says CEO of Toll Aviation, Trevor Jensen. ‘If you say safety first, then it’s very easy to say, “OK, we’ve considered safety, now we can get on with the job”. Whereas, if “safety always” is the culture, then you don’t move away from it.’ Toll Aviation is one of three ‘pilot’ organisations working closely with CASA on the implementation of safety management systems (SMS) in the transition to Part 119. SMS have been on the radar for over ten years, and many proactive RPT operators, recognising that they are a critical part of doing business, already have robust SMS in place. They’ve been mandatory for certified aerodromes since January 2007, and aerodromes with international flights even earlier, since 2005. (Further in this article, there are case studies of two very different aerodrome SMS experiences. See page 12.)

There are four major components to the required SMS:

Safety policy, objectives & planningThere are four major components to the required SMS: Safety risk management Safety assurance, and Safety

Safety risk managementthe required SMS: Safety policy, objectives & planning Safety assurance, and Safety training and promotion. As

Safety assurance, andpolicy, objectives & planning Safety risk management Safety training and promotion. As part of the phased

Safety training and promotion.& planning Safety risk management Safety assurance, and As part of the phased implementation of CASR

As part of the phased implementation of CASR Part 119, CAO 82.5 (HCRPT) and CAO 82.3 (LCRPT) were mandated in January 2009, requiring operators to implement an SMS according to a staggered timeline. These phases are depicted below.

Toll Aviation has a fleet of 12 aircraft: two French ATR 42s; 10 Metros (eight 3s and two 23s); and three 737s contracted from Airwork NZ. And, on any one day, they may also contract up to 50 aircraft. The company employs 115 people: 38 pilots (ten on the ATRs and the rest on the Metros); 42 engineers; 12 ground staff; and the remaining 23 in finance and admin. Although Toll is not a CAO 82.3 or 82.5 operator, they have chosen to implement an SMS meeting the standards and timeframes associated with HCRPT operation. Their Metro operation is based around a number of bank runs to centres such as Cairns, Townsville, Mt Isa, Moree, Coolangatta and Mackay. Then there are the freight services – one ATR

flies out of Brisbane to Bankstown, Melbourne and Adelaide, while the other does the reverse leg – Adelaide to Brisbane, at the same time. The Metros also fly the Adelaide to Melbourne route.

Trevor explains that their Monday to Friday roster appeals to many pilots for whom no flying on weekends is a lifestyle choice. He is very much aware of the competition Toll faces from the major airlines, in attracting and retaining pilots. ‘The minute the major airlines want pilots, we lose them,’ he explains, ‘with up to a 50 per cent turnover’ in the good times, so part of the company’s risk assessment is the pressure this places on maintaining standards. However, the current economic downturn has a positive side – decreased airline recruitment has meant less workforce attrition. ‘The downturn has given us time to put our SMS in place with a stable workforce,’ he says.

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SAFETY ALWAYS SMS IMPLEMENTATION PHASES 2009-2011 Phase 1 Phase 2 Phase 3 Safety Policy, Objectives
SAFETY ALWAYS
SMS IMPLEMENTATION PHASES 2009-2011
Phase 1
Phase 2
Phase 3
Safety Policy, Objectives and Planning
Management commitment & responsibility
Safety accountabilities of managers
Appointment of key safety personnel
SMS implementation plan
Gap analysis
Documentation
Third party interface
Coordination of the emergency response plan
Safety Risk Management
Risk assesment & mitigation process
Hazard identification process
Reactive
Proactive/predictive
Proactive/predictive/hazard
identification
Safety Assurance
Safety performance monitoring & measurement
Reactive - incident & accident
estigation
Internal safety investigation
The management of change
Continuous improvement of the safety system
Safety Training & Promotion
Training & education
Safety communication
Key personnel
All safety critical personnel
All safety critical personnel
‘The minute the major airlines 10 want pilots, we lose them,’ The timing is also
‘The
minute the
major
airlines
10
want
pilots,
we
lose
them,’
The timing is also right for their SMS
for another reason. Toll Aviation arose
from three companies: Jetline, Jetcraft
and Jetcare, which have been aligned
into the one organisation over the
past 12 months. This consolidation
provided a good opportunity, Trevor
Jensen says, to work with CASA
on examining Toll’s systems very
closely, as a prelude to establishing
an integrated SMS for the new
entity. An important first step
was a thorough gap analysis.
‘Safety doesn’t have to cost
money,’ Trevor explains, so Toll
used Survey Monkey (a simple
tool for designing surveys
online, with the capacity to
then analyse the data), to
survey their pilots, engineers
and ground staff ‘to see how
we as a group see ourselves.
I’m not a salesman for
Survey Monkey, but it’s a
great tool which costs you
nothing. In a short time
we were able to come up
with results looking at
our compliance.’ This
analysis was revealing,
Trevor says. ‘If you take
level 10 to be the level
FSA JULY–AUG 09

we want to be for ICAO standards (International Civil Aviation Organization), then for most items we were hovering around six, but on hazard identification, it was three out of 10.’

He says that by conducting the survey and analysing its results, they were able to be more realistic. ‘If we had asked ourselves, for example, “Do we have a hazard identification system?” we probably would have said, “Yes”. But now, rather than just ticking the boxes, digging deeper has identified the weaknesses, so we know where we’ve got to put our effort in.’ The process took Toll Aviation three months, but Trevor says, it ‘gives us a very honest assessment of our SMS readiness’.

Having this data has also helped in convincing the corporate group of the need to resource safety management within the company – training, IT systems and so on. ‘You can never win an argument on emotion, but good data can help you win.’

Trevor and his team have now assessed all the required elements, and established a list of the tasks needed to put their SMS in place, with the tasks allocated in a schedule for phases 1, 2 and 3 of implementation. As they write their manual, they can sign off on each of these tasks. Toll is also part of the pilot group trialling the new online SMS manual authoring and assessment tool (MAAT). When Flight Safety visited the company headquarters in Brisbane, Trevor was about to sit down with the CASA SMS project team to begin populating the manual builder online.

In conclusion, Flight Safety asked him what he felt were the key points of an SMS. ‘Keep it simple; safety has to be pragmatic,’ he replies. ‘It’s not about having big manuals – your SMS documentation should reflect how you do your business. Make sure it reflects what you do.’ And in training and communicating about safety, make sure the way you do it suits the audience. There’s no point in having pages of instruction, with the intent in the middle of the document, if the guys don’t want to read nine pages. ‘We have to understand our audience a lot better,’ he says.

SAFETY ALWAYS

MORE THAN ‘TICKING THE BOXES’
MORE THAN ‘TICKING THE BOXES’

EPS HELICOPTER SERVICES

According to principal, Geoff Sprod, EPS helicopters are confident that whatever SMS standards CASA introduces in the near future for charter operators, they will be ready. On their website, Bankstown-based EPS Helicopter Services Pty Ltd state their mission is: ‘to provide a safe, efficient, cost effective helicopter management service in support of our clients’ strategies and objectives.’ It was this desire to maintain an ongoing emphasis on safety, and to establish a point of difference with competitors, which led Geoff and chief pilot, Paul Caristo, to implement a quality assurance system.

EPS Helicopter Services own two helicopters, a Bell 206BIII Jetranger, and their latest acquisition, a Eurocopter AS350SD2. They conduct charter and aerial work activities that include pipeline and power line surveys, banner towing, sling loads, fire fighting and parachuting for promotional events, to name a few.

In 2007, Paul was about a third of the way into putting the new company’s operations manual together, Geoff explains, when the pair decided, ‘Let’s develop a fully integrated management system that would drive the business,’ rather than simply having an SMS. Recognising that the helicopter world is a highly-competitive market, and that the business would benefit from the security of ongoing contracts, they decided to embark on securing SAI Global ISO certification. ‘Ask any Joe on the street, and they know what the symbols mean’, Geoff explains, ‘the ‘five coloured ticks’ are the most recognisable QA symbols anywhere’. So EPS opted to undertake not only quality assurance (QA) (ISO 9001), certification, but also environment (ISO 14001) and OH&S (AS 4801).

Their five months of developing policies and procedures covering all aspects of the business, including safe work method statements, risk registers, risk assessments, staff training and induction, paid off. After rectifying minor areas during the pre-audit check, they passed their audit in October 2007, gaining their triple SAI Global certification. This certification process ensures the system continually evolves with the business towards best practice, and is reviewed with ongoing audits to maintain certification.

is reviewed with ongoing audits to maintain certification. www.epsheli.com.au homepage The whole system is

www.epsheli.com.au homepage

The whole system is electronically based, and with hyperlinks to the regulations, there is always access to the source document (e.g. the CASA, EPA or WorkCover websites). Clicking on the link therefore takes you straight to the most recent version. Every activity they undertake has a safe work method statement and risk assessment that identifies hazards in relation, not only to the activity, but the area of operation, which may vary from day to day. ‘We’re in the early stages of trialling a new system, using a PDA/Blackberry, so that you can download documentation when you come back into the office. Or, in the case of one of our pilots who may be flying outback, he can obtain remote access to our server 24/7,’ Geoff explains.

He estimates that the initial certification process, involving five months of manpower and downtime cost EPS about $50,000; with ongoing audit costs (around $12,000 annually) and annual registration fees for the three certifications of another $12,000. But Geoff argues, ‘ It wasn’t too long ago that the only

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FSA JULY–AUG 09

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thing that mattered was the hourly rate. Over the past two years we have seen a change in tender requirements, and acknowledgement that tenderers have some form of quality, OH&S and environmental policies and procedures in place. And more recently, you not only have to provide evidence of such systems, but also any external certification. Anyone who chooses not to go down this road soon will be behind the competition.’ For EPS the additional certification brought direct commercial benefit: a few months after certification, EPS secured

a government contract, competing against other major operators. While price accounted for a percentage, other factors such as quality and environment were an issue. Their success, Geoff says, could be attributed to the fact that EPS was the only operator with a certified system which covered all three aspects, giving them a high score in that component of the tender.

Over the next couple of years Geoff believes the reliance on providing evidence of a safety management system will increase significantly. Additionally, a far greater emphasis will be placed on a company’s SMS as a measurement of their performance, rather than simply on their price.

SMS & AERODROMES
SMS & AERODROMES

Just as the current SMS Phase 1, 2 & 3 requirements are a transition to CASR Part 119 – SMS requirements for Australian aerodrome operators followed a similar transition. CASR Part 139 (safety standards for Australian aerodromes) came into effect in May 2003, with a 1 November 2005 deadline for aerodromes with international operators; and 1 January 2007 deadline for all other certified aerodromes. Keith Tonkin, of Aviation Projects, outlines case studies of two very different aerodromes which implemented new SMS.

NORTHERN PENINSULA AIRPORT (YNPE)

BACKGROUND

Northern Peninsula Airport (NPA, formerly Bamaga/ Injinoo Airport) is located on the northern tip of Cape York Peninsula in far North Queensland. Like many remote communities, the five Aboriginal and Islander communities of the Northern Peninsula area rely heavily on air transport for access to medical and other essential support services. The airport is therefore a critical element of community infrastructure.

To provide for an expected increase in operator capability, the airport was prepared for certification in late 2007, and received its aerodrome certificate early in 2008. A critical condition of certification was assurance by the Northern Peninsula Area Regional

Council, which managed the airport, that they would provide adequate resources and funding so that the aerodrome would meet regulatory requirements.

Not only did the SMS satisfy one of the requirements for certification, but importantly, it was a way of being proactive by identifying existing and potential issues and the resources and management actions to address them.

and the resources and management actions to address them. SMS DEVELOPMENT The airport management had limited

SMS DEVELOPMENT

The airport management had limited knowledge of how to develop and implement an SMS. So after first looking at the principles and methodology of an SMS in the CASA-developed SMS template, they participated in a workshop to identify risks to the safe operation of the airport. These risks and their associated treatments were documented in a risk register and treatment plan, in MS Excel format. By using Excel, which is readily available, local airport management staff could view, manage and manipulate the register document easily.

SAFETY ALWAYS

it was proactive by identifying existing a way of being and potential issues and the
it was
proactive
by identifying
existing
a way of being
and potential
issues
and the resources
Some of the issues identified in the development of the
SMS, and actions taken to rectify them are as follows:
and management actions to
address
them.’

1. Emergency callout – Limitations because of fixed- line and mobile phones meant that the airport manager (who also does the refuelling) was not always contactable for callout by emergency services such as the Royal Flying Doctor Service (RFDS). A satellite phone was therefore provided to the airport manager.

2. Frequency confirmation – Although a Unicom service was available, limitations associated with staff availability and radio equipment, as well as significant frequency congestion on the large CTAF(R) shared with nearby Horn Island Airport and other airports in the Torres Strait, led to the decision to establish Northern Peninsula Airport as a separate CTAF(R) and to install a combined AFRU/PAALC. This process will be concluded with the August 2009 amendment of ERSA.

AD-HOC OR UNFORESEEN RISKS

As with any aviation activity, despite the intention to proactively manage safety risks, unforeseen risks requiring reactive management action occur from time to time. Some incidents which occurred at NPA, and how these were managed to minimise future risks are as follows:

1. ‘Near miss’ – A light aircraft landed short of the runway while conducting a circuit to land, due to failure of the throttle cable. The subsequent emergency response revealed some opportunities for improvement in relation to call out procedures, telecommunications systems and response vehicle capabilities. The airport manager reported these issues, which were discussed with airport management and other stakeholders for consideration and implementation. Results were recorded in the risk register and treatment plan.

2. Pavement failure – ground water infiltration of the runway pavement required urgent repairs to be carried out at short notice. This required closure of the airport for a number of days on several occasions, with implications to RPT operators,

emergency services etc. A full engineering design of pavement repairs & additional drainage was commissioned immediately. The pavement repairs were carried out in accordance with the engineering designs provided. The results of these activities were recorded in the risk register and treatment plan. Further drainage & runway pavement upgrades are scheduled when funds are available.

STAKEHOLDER CONSULTATION

All of the above issues required engagement with stakeholders to ensure that they understood and accepted the risk treatments being implemented, and that an acceptable level of safety would be maintained. These stakeholders included aircraft operators and agents, council staff, local community members, regulatory authorities, suppliers and customers.

Sometimes change can bring about unintended consequences, so during the development of risk treatments, stakeholders were asked for their input regarding potential impacts to their activities, including operational implications, amended procedures, most appropriate means of communication etc.

Stakeholders received information concerning the treatment actions which had been determined, through email broadcasts to user groups, newspaper articles, telephone, fax, industry publications and newsletters, NOTAMs as well as AIP/ERSA and other information sources.

SMS ONGOING MANAGEMENT

Airport management accepts that risks need to be managed proactively. They organise meetings of the SMS safety committee every six months or so to review the SMS and the risk register and treatment plan, so that planned actions to treat known risks happen; potential risks are identified and actions put in place to treat them.

The meeting also tables and considers reports and information from the previous period relevant to the SMS, such as ad-hoc reports or other information; and safety/technical inspection reports.

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FSA JULY–AUG 09

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SAFETY CULTURE
SAFETY CULTURE

Increased regulatory obligations as a certified airport under CASR 139, as well as status as a security-controlled airport under transport security regulations meant the community had to reconsider its approach to the airport. Improved maintenance of infrastructure and services, restrictions to access, more rigorous operational procedures and increased management involvement also required a prioritisation of funding and human resources, so the airport management met its regulatory requirements.

SUNSHINE COAST AIRPORT (YBMC)

BACKGROUND

Sunshine Coast Airport (SCA), owned and operated by Sunshine Coast Regional Council, is Australia’s twelfth-largest airport by passenger numbers. It supports jet RPT services operated by Jetstar, Tiger and Virgin Blue; numerous fixed and rotary wing training organisations, including Singapore Flying College; as well as aircraft maintenance and support operations. It is a security-controlled airport with screening requirements.

Sunshine Coast Airport is better resourced than Northern Peninsula Airport, but has its own unique issues because of its much greater scope and scale of operations, and its correspondingly more

complex compliance and reporting requirements. It is also approaching limitations in operational capacity brought about by an unanticipated increase in passenger numbers and the type of operations conducted at the airport.

INTEGRATION WITH OTHER RISK- BASED MANAGEMENT PROGRAMS

Because of the increased scope, scale and complexity of activities it conducts and supports, Sunshine Coast Airport manages a number of risk-based compliance programs in addition to the SMS. These include an environment management plan, a security risk management plan (part of the Transport Security Program), a workplace health and safety program and an asset management program.

As well as these statutory requirements, all significant projects undertaken at the airport involve a proactive formal risk management component.

Sunshine Coast Regional Council also requires all significant risks (including business continuity, financial and legal liability issues) to be managed as an outcome of the airport’s annual performance plan.

Managing these separate programs creates a significant issue. They do not all have the same risk criteria—likelihood and consequence descriptors, risk matrix, management and reporting actions required, level of acceptable risk etc. This disparity makes allocating resources effectively

level of acceptable risk etc. This disparity makes allocating resources effectively Photo: courtesy Sunshine Coast Airport

Photo: courtesy Sunshine Coast Airport

more difficult, and degrades the value of risk information communicated to some stakeholders. Working with
more difficult, and degrades the value of risk
information communicated to some stakeholders.
Working with the Australian Airports Association,
CASA developed an electronic SMS builder to
provide airports a simple means of compliance, and
a
consistent basis for assessment by aerodrome
SAFETY ALWAYS
inspectors. Unfortunately the risk criteria, such as
likelihood, consequence, level of risk etc did not
align with the council’s risk policy. Using the CASA
methodology, an ‘extreme’ consequence (multiple
fatalities) with a ‘rare’ likelihood, managed with
treatments that had limited effect resulted in a
‘low’ risk, whereas using the council’s framework,
Work is currently underway to integrate these risk
management programs, with a single database for
recording the risk register and treatment plan, so that
all risks managed by the airport can be identified,
assessed, treated, monitored and reviewed within a
single management program, using the same criteria.
This integration will make identifying, reporting and
managing risks more efficient, improve decision
making and resource allocation, and reduce training
requirements for system users.
TRAINING
a
similar scenario resulted in a ‘high’ level of risk.
(That electronic SMS builder is no longer available.
See MAAT below.)
There is a significant number of staff and contractors
who conduct operations at the airport, which
has necessitated a more formalised training and
induction program as part of the SMS.
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Council’s risk management database also did not
cater for aviation operational safety risk. For the
airport, this was measured financially as a cost/
revenue consequence, in safety outcomes and also
in terms of interruption to operations. So, in the
interests of simplifying compliance and program
management, the SMS is a standalone program using
CASA’s template until all risk-based management
programs can be coherently incorporated into the
council system.
Contractors undertake a formal induction prior to
conducting works on the airport, and are subject to
ongoing scrutiny for compliance.
In their induction, new staff members receive SMS
and associated safety management procedure
training. Safety management issues are discussed at
monthly staff meetings.
Risk criteria and risk assessment have to be uniform,
so that across council, various departments and
business units can communicate levels of risk
effectively.
Airside staff such as safety/reporting/security officers
and operational management staff also undertake
further training in safety procedures documented
in the aerodrome manual and standard operating
procedures manual.

For more information

Safety Management Manual

ICAO (2006). Doc.9859-AN/460 Second edition, downloadable from www.icao.int

Also SMS training material available from the ICAO website.

Safety management systems for regular public transport operations.

CAAP SMS-1(0) Civil Aviation Advisory Publication, January 2009

Integration of human factors into safety management systems

CAAP SMS-2(0) Civil Aviation Advisory Publication, January 2009

Human factors & non-technical skills training for regular public transport operations

CAAP SMS-3(0) Civil Aviation Advisory Publication, January 2009

Safety management – making it fit

Feature article Flight Safety Australia March-April 2002

Manual authoring and assessment tool (MAAT)

Online tool – email sms@casa.gov.au for more information

www.surveymonkey.com

Online tool designed to enable anyone to create online surveys quickly and

easily. Free (for up to 100 responses stored).

www.saiglobal.com

International quality certification body, which licenses accredited organisations with the internationally-recognised ‘tick’ across five main

areas: quality, OH&S, environment, information security and food safety.