RAAus SMS. How to best go about it?

[drifterdriver]

I thought it'd be beneficial to start a thread devoted solely to the topic of developing an SMS for RAAus (not whether we do or don't need one please).

 

 

[old man emu]

Please don't use the initials of a name the first time you mention it. Please state the full name, then abbreviate.

 

(Pedantic) Old Man Emu

 

 

[FlyingVizsla]

What about a separate thread for Flight Training Facilities (FTFs) developing their RAA supplied template into a Safety Management System (SMS)?

 

Sue

 

 

[drifterdriver]

Sorry OME. Next time I'll call it texting.

 

Nick

 

 

[Teckair]

What about a separate thread for Flight Training Facilities (FTFs) developing their RAA supplied template into a Safety Management System (SMS)?Sue

Yes that would be a good idea.

 

 

[John G]

I totally agree that we need to develop an RA-Aus Safety Management System (SMS) that is written professionally and takes into account our type of operations that addresses the safety issues our members are likely to face and not a CASA mandated system that is slanted towards commercial or charter operations.

 

I have passed on to the RA-Aus Board the names of companies that are expert

 

in the field; as opposed to someone that has experience in the mining industry and thinks that mining safety systems are readily converted to aviation.

 

One of the companies I have recommended has extensive experience developing SMS packages for aviation acceptable to CASA and tailored to specific sectors of aviation.

 

One company in particular, is headed by a current RA-Aus PE that lectures at university on development of SMS's and has a staff of experts with varying skill levels that can be utilised to develop a specifically tailored SMS for RA-Aus relatively quickly and sure to be acceptable to CASA.

 

 

[damkia]

www.casa.gov.au/sms

 

Starting point is already there - if we are working under the guardianship of CASA this would be a logical first step

 

 

[DWF]

I have asked RA-Aus Ops for a copy of the RA-Aus Risk Management Manual referred to in the SMS template sent to FTFs.

 

Thought it might give some clues on how to develop a SMS for my (very small) FTF.

 

No response so far, but it has only been a couple of days yet.

 

DWF

 

 

[turboplanner]

John, that sounds very promising.

 

The first action then would be to draw up a Request for Quotation, and get some prices.

 

That may sound a little simple, but the reason I wrote it is that there can be a lot of paid hours in there to complete the manuals etc - hundreds of thousands of dollars.

 

Your contact may be much more affordable.

 

Once pricing is in, that will probably determine whether a consultant is affordable, of a volunteer effort is needed.

 

Sue, no problem with that but I think sending out raw templates will created some difficulties. There is just too little detail to give you direction, and in any case a central system needs to be set up, or the standards will be different, and defended to the death all over Australia. Right now four different people looking at the template could go in four completely different directions, so the separate thread would need some co-ordinating.

 

Nick, if it comes down to a voluntary effort because consultants are not affordable, my initial thoughts were:

 

Get the CASA data first because some things will be mandatory, and it is aviation based. If it hasn't improved safety as some have suggested, then it's necessary to look around for some improvements which will.

 

The next step is to collect some data on SMS systems developed by companies which either:

 

• have maintained a low level of incidents
   
   
  
• have reduced incidents
   
   
  

 

 

You don't have to slavishly copy what they did, and the majority of it will be irrelevant to aviation, but the formatting and wording and means of addressing risk will be useful

 

The next step is a walk through the RAA-responsible activities, and one or two FTF's recording the activities

 

This recording provides data for the draft, and a basis for gap analysis. (I'll defy anyone to sit at their desk and pick all the gaps)

 

As the draft develops, each function is assigned a time element, such as: Immediate, Daily, Weekly, Monthly, Yearly

 

The completed document, sorted, will then automatically produce daily, weekly, monthly yearly checklists

 

(Immediate might be: Before first solo, assess student as satisfactory for Radio procedures, Engine Failure After Take Off, Forced Landing etc)

 

The analysis needs to be divided into functions:

 

Facility procedures (for example the same obligation to have safe parking and access as a retail establishment)

 

Instruction procedures

 

TIF procedures

 

Certificate Pilot procedures

 

There's a shitload of work there Nick to flesh that all out before starting on the manual and forms, so before getting excited about going down the volunteer trail, I'd like to see what the board members have decided to do.

 

 

[damkia]

TP,

 

It may be useful to look at high risk industries for some guidance on how to frame a SMS.

 

A few examples would be mining, oil/gas (offshore), and chemical manufacture.

 

A little more info (well written btw) on how to write an SMS for aviation by CAA (UK)

 

http://www.caa.co.uk/docs/872/SMSGuidanceForSmallNonComplexOrganisations.pdf

 

 

[djpacro]

It is not that hard to write, the hard part is implementing it and continuing to action it. So, it must be written by those who will implement it. By all means, get an expert to offer guidance and even do the typing.

 

It is just too easy to spend a lot of money on getting one written only to be used as a paperweight.

 

 

[turboplanner]

One important segment I left out was the establishment of an Auditing/Compliance/ Enforcement team, so I'll put it here as a reference.

 

When you get involved with any Safety Management System you quickly learn that writing up a set of huge manuals which no one can absorb, and putting them on the shelves isn't going to cut it. The catch phrase is "you have to LIVE the legislation"

 

So the Manuals need to be smaller rather than larger, in simple language, and set out so all participants can read and understand them.

 

All the system, including the premises has to be audited and kept updated, and non- conforming behaviour can't just be ignored, it has to be addressed and corrected, with sanctions if necessary.

 

This will involve a lot of people, is not financially possible in my opinion, and so would involve volunteers. Self- administration really is self- administration.

 

To give you an example of another sport, where I had detailed experience, Speedway in Australia involves roughly the same number of participants as Recreational Aviation Australia Inc. We had about 30 tracks and 30 car classes, and on any weekend there would be about five race meetings involving in total about 300 competitors.

 

So for a start all 300 were funnelled into five locations.

 

Looking at each location:

 

About 5 Machine Examiners would thoroughly check every car in the class each belonged to before the race meeting started. Regularly faults would be found requiring a recheck, and occasionally a driver would be parked for the day. In the off season the Machine Examiner would check all new cars in various build stages, and often current cars/problem cars.

 

For the State there were about 30 Machine Examiners – 210 nationally

 

Behaviour and organization outside the track proper (the equivalent of Airside) was controlled by a Pit Steward who would form the cars up in Pit Lane and check that each driver’s safety equipment. The Pit Steward was re4sponsible to the Chief Steward.

 

For the State there were about 30 Pit Stewards – 210 nationally.

 

As the cars rolled on to the track the drivers came under the control of the Chief Steward, who had up to four Corner Stewards under his control. Among their duties was control of the behaviour of the drivers.

 

Of all the officials, this was the key group. Behaviour is an area where management will produce the biggest safety gain. As an example, at one stage a normally safe class started to have fatal accidents. Tracks had been recently converted to clay to suit the most popular Sprintcar class. The Association belonging to the class having the fatalities decided the cause was (a) the rougher tracks and (b) their narrow track dimension causing flips, so they widened their cars’ tracks, but the carnage continued.

 

After watching a video 20 or 30 times of one of the fatal accidents, I realised I was looking at the car of the driver who was killed passing another car ahead of him on the track while facing backwards. From there it was possible to rewind to footage earlier in the corner, and see not only a fight going on between him and the driver who killed him, but two pair of other fighting drivers as well.

 

I had a bit of a struggle getting this message through to the Association’s Chief Steward, but they tightened up on the behaviour and have not had a fatality in the past couple of decades.

 

Where the Steward system observes non-conforming behaviour the Chief Steward issues an immediate penalty which is usually disqualification, but can be one month, three months, six months, 12 months or life suspension.

 

For the State there are about 30 Chief Stewards – 210 nationally

 

There are about 80 Corner Stewards – 560 nationally

 

Due process is served by an appeals process to a volunteer Tribunal

 

For the State there are about five Tribunal members – 35 nationally

 

In the case of a serious crash we had a power and foam fire team, trained to handle a fuel tank burst

 

For the State there are about 120 fire crew - 840 nationally

 

So that’s a total of 295 volunteers for the State, 2065 nationally

 

For the picky, these are rough numbers out of my head for 20 years ago; both numbers and job descriptions might be different now, but would be basically the same.

 

Now if your head’s spinning at the task of raising this number of volunteers – about seven times the number of people who vote in RAA, this did involve a sport with an expectation of several crashes per day, was a competitor sport, and did not involve anyone getting in a car to drive from point A to point B looking at the scenery, but the safety level is better than yours.

 

You can’t directly transpose these jobs because, say in Victoria, all the activity was occurring at five known places on one known day.

 

Administering safety is more problematic when on any day of the week one or a few dozen are taking off and landing anywhere in the State, often from airfields or paddocks where the pilot is the only person there.

 

So I’m not in any way suggesting that you adapt something like the above network.

 

The task here is to develop an audit type network which is practical for the task, and train the volunteers who will audit, check compliance, and conduct enforcement as a safety net above the rather exposed current thin blue line of Chief Flying Instructor’s and their teams.

 

 

[turboplanner]

It is not that hard to write, the hard part is implementing it and continuing to action it. So, it must be written by those who will implement it. By all means, get an expert to offer guidance and even do the typing.It is just too easy to spend a lot of money on getting one written only to be used as a paperweight.

This is a very critical point. Most of us who have been involved in them over the years have screwed up and overwritten them, and people have ignored them until they were fixed.

 

 

[damkia]

This is a very critical point. Most of us who have been involved in them over the years have screwed up and overwritten them, and people have ignored them until they were fixed.

By profession now as OHS Advisor, I've been involved in the use and also the writing of one for the mining industry.

 

 

[turboplanner]

From what I'm hearing the Bowen Basin systems are some of the newest and best.

 

I've heard of a mine out near Clermont (Can't remember its name) which initially came under a lot of flack from the workers for being too tough/impractical (things like if the load to be lifted by hand exceeded the specified limit the operator had to drive all the way back to the site and get a helper, now has the lowest injury rate and the best production rate in the area.

 

 

[old man emu]

This is a very critical point. Most of us who have been involved in them over the years have screwed up and overwritten them, and people have ignored them until they were fixed.

The reason that systems are ignored is that those responsible for implementing them do only that. They don't monitor their application and review them with a view to improving them.

 

That means that if a procedure as written is impracticable, then those who it affects will ignore it. If those affected have input, then the procedure is more likely to be practicable and therefore not ignored.

 

OME

 

 

[nong]

I am expecting to charge $350.00, or more, per hour, for training in the Jab. After all, I will need to pay for the required four man safety committee, because no one in their right mind will volunteer. The hangar and parking will need to meet retail standards, such as a bitumen car park and disabled dunny. Lets call that $200k. I guess I could scrimp on maintenance to help pay for these new 'core' safety requirements. No biggie. We already force students to study "human factors", thus diluting their limited study time. Much more useful than discussing, say, how pilots get suckered into loosing control at low level.

 

 

[turboplanner]

Or you could try having a look around the parking area for any rubbish, building materials potholes etc which might cause injury to visitors or their children, where appropriate buy a $10 speed sign for the entrance, have a couple of warning signs put up (which you are currently obligated to do by the State Worksafe body anyway.

 

You may be obligated to have handicapped toilets now, or maybe since you are not offering a service which a person who needs a handicapped toilet can participate in (unless you offer handicapped controls) you may be exempted from that.

 

If you operate at night, you will require lighting in the car park (but you do now under Worksafe.)

 

You could contribute to fixing the current Human Factors syllabus, which in my opinion was written by an introverted diver, and put some real meat into the course, which you know will save lives.

 

Not much cost in all that; it's just a matter of how to approach your risks, which you may be doing very well now, in which case you may have to do very little.

 

But if you don't want to put your neck on the block for a guaranteed claim against you for negligence, a safety system is a safety net, your proof of duty of care.

 

 

[drifterdriver]

PS you'll have to go to the end of the long line of volunteers who've already offered to help with rewriting the exams and been knocked back.

 

 

[poteroo]

PS you'll have to go to the end of the long line of volunteers who've already offered to help with rewriting the exams and been knocked back.

Why stop at the exams? The rationale for most of the paperwork needs scrutiny - RAAus is fast becoming GA! happy days,

 

 

[old man emu]

These questions have to be answered:

 

1. Has the RAAus got a documented INTEGRATED management system that meets the criteria of ISO 9001:2008 Quality Management Systems - Requirements?

 

2. If such a document exists, was it prepared by a person or persons who had the education, training or experience in light aircraft operations/maintenance, as well as business operations? (In other words, was the writer "competent" in the area of aviation overseen by RAAus?)

 

3. If such a document exists, when was the last time an independent audit was carried out on the implementation, operation and monitoring of the various requirements in the document?

 

4. If any audits have been carried out, were they conducted by a competent management systems auditor?

 

Having read all the various threads dealing with the management of RAAus, I have the opinion that the answers will be:

 

1. No

 

2. Cannot be answered since the answer to Q1 is "No".

 

3. Cannot be answered since the answer to Q1 is "No".

 

4. Cannot be answered since the answer to Q1 is "No".

 

And there, my dear friends is the root cause of RAAus' problems.

 

OME

 

 

[turboplanner]

Just a precautionary note; the ISO 9001 system is based on commercial business, for example as a way of a government being able to assess that a supplier was qualified to supply the service to be bought.

 

I haven't checked whether it crosses over into non-trading organizations.

 

 

[old man emu]

Yes, ISO 9001 is most commonly used in commerce, but the principles expounded in it are equally applicable to an organization such as RAAus. Just because RAAus is not meant to be a profit making concern as a commercial business would be, it still needs to have guiding principles to operate efficiently. After all, RAAus is producing a product: the ability for each member to engage in recreational flying.

 

It is the inefficiency of management that has drawn RAAus into the mire it wallows in today.

 

OME

 

 

[turboplanner]

Or as I've just said on another thread split, their failure to do the relatively light jobs allocated to them.

 

 

[nong]

ISO was a financial disaster for the AUF. It was a scam designed to enable consultants to scoop a heap of easy dough, and they did.

 

Today, an operator in another field, told me that he spends one day per year carefully filling out all the safety system paperwork that is, supposedly, a daily chore. It has to be done carefully, to allow for such things as public holidays, but doing it this way does limit the damage to one wasted day per year.