argus pros special release 2012 sms audit results audit results...argus pros is an experienced...
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A B O UT AR G US
ARGUS International, Inc. (ARGUS) is the industry leader in providing specialized aviation services to companies that manufacture, finance, operate, maintain, and market various aviation products and services, as well as to the end-user of these same services. With a global footprint and unparalleled expertise, ARGUS can provide the aviation marketplace with the information needed to make educated decisions and manage risk effectively.
PROS 6021 South Syracuse Way, Suite 302 Greenwood Village, CO 80111 USA
pros.aero +1 513.852.1010
PRISM AN ALY SIS OF THE ARGU S PR OS AU D IT R EC OMMEND AT IONS F OR SA FETY M ANA GEMEN T
Each year, ARGUS PROS audits a significant number of operators from both private and commercial flight operations. All aspects of
the flight operation are reviewed during each audit, to include the organization’s safety management system.
This report is a summary of those audit results, compared to the ARGUS Platinum Standard or IS-BAO, in the measure of safety
management effectiveness. These audits follow a “systems” and “process” methodology, and are not exclusively focused on
compliance.
The goal of each audit is to seek evidence of effective and efficient operations and
industry best practices, including implementation of a safety management system
(SMS) as defined by FAA AC120-92A or IS-BAO.
The objective of this report is to highlight those recurring problem areas found in
SMS implementation and execution. This widened aperture will help operators
focus their efforts on common deficiency areas cited by auditors, and use this
information to improve their own SMS implementation and execution efforts.
PRISM, a wholly owned subsidiary of ARGUS International, Inc., is an industry-leading provider of Safety Management Systems (SMS) solutions, an FAA recognized certification consultant and is designated by IBAC as an IS-BAO Support Services Affiliate. ARGUS PROS (Partners and Resources for Operational Safety), a wholly-owned subsidiary of ARGUS International, Inc., is a worldwide leader in performing on-site safety audits for commercial air carriers, corporate flight departments, charter operators, helicopter, and special purpose aircraft operators. ARGUS PROS is an experienced quality and safety assurance provider, and committed to supporting and enhancing safety initiatives for operators worldwide.
A R GU S P R OS S P EC IA L R EL EA S E
2012 SMS Audit Results
REV 04/2013
Top SMS Recommendation Areas
58%- Risk Assessment
45%- GOM
38%- SMS Training
36%- IEP
26%- ERP Documentation
S MS AU DIT R ES U LTS 2012
UNDER ST AN DING THE AN ALY SIS AND THE R E SULT S
A total of 73 audits were analyzed spanning the period from January 1, 2012 to December 31, 2012.
The figures contained in this report represent analysis of operators that had deficiencies in a particular SMS focus area. For
example, 10 (14%) of the 73 operators audited had a weakness in the area of Emergency Response Program (ERP) Go Team. Even
though an ERP is placed under the umbrella of SMS, the results of this report are separated into SMS elements and ERP elements.
The majority of the 2012 audit findings point to deficiencies in Risk Assessment and General Operating Manuals (GOM). Risk
Assessments help identify, evaluate, mitigate, and validate current risks in the operation. They can also determine gaps in policy
and procedures when a change is made, such as adding a new aircraft to the operation. This is known as “change management”
and is a process needing improvement in many operations according to audit results. A GOM defines the policies, procedures, and
organizational structures to accomplish company goals. It must be accurate, up-to-date, and consistent with other manuals in
order to prevent miscommunication and confusion.
S MS AU DIT R ES U LTS 2012
SMS Audit Results 2012 [email protected] +1 513.852.1010
BRE AKD OWN THE SAF ET Y MANAG EMEN T SY ST EMS RECOMMEN DA T ION S
SMS Audit Results 2012 [email protected] +1 513.852.1010
S MS AU DIT R ES U LTS 2012
R ISK ASSESSMEN T – 58%
SAMPLE AUDIT RECOMMENDATIONS:
It is recommended that the company continues to develop the Flight Risk Assessment tool and implement it.
The SMS should include a change management process and be implemented.
GUIDELINES:
A risk assessment should be performed when it is determined there is an elevated level of risk
Risk assessment is appropriate when there is a change in the mission, operating environment, procedures, etc.
Risk mitigation may change company policy or create a new procedure
Define the complete risk assessment process in the SMS manual
G ENER AL OP ERA T ING M ANU AL – 45 %
SAMPLE AUDIT RECOMMENDATIONS:
The organizational chart in the GOM should reflect the current management structure.
The duties and responsibilities of the Safety Manager should be consistent between the Operations and SMS Manuals
GUIDELINES:
Contain accurate descriptions of a safety system
Contain an accurate outline of Safety Officer/Manager responsibilities
Maintain consistency with SMS manual
SAF ET Y M ANAG EMEN T SY STEM TR A IN ING – 38 %
SAMPLE AUDIT RECOMMENDATIONS:
The Safety Manager should receive formal training for the development and implementation of an SMS
Employee SMS training should be accomplished
GUIDELINES:
Annual safety training for employees is necessary
Training subjects may include: accident investigation, safety management system fundamentals, company safety
performance
Training options can include online, classroom, in house developed seminar
INT ERN AL EV ALU AT ION PR OGR AM – 36%
SAMPLE AUDIT RECOMMENDATIONS:
It is recommended that in-house auditors receive and document training.
Resolution of findings from the Internal Evaluation Program should include a root cause analysis and documented follow-
up when appropriate.
GUIDELINES:
The IEP should contain a documented process for: assigning responsibility, conducting audits, identifying and mitigating
hazards/deficiencies and a corrective action
IEP auditors should receive training in conducting audits
IEP should be conducted in accordance with the operator’s Safety Management System manual
SAF ET Y C OMMIT TE E – 26%
SAMPLE AUDIT RECOMMENDATIONS:
The Safety Committee should be structured to show old and new business, mitigation processes used to reduce identified
risks, and whether an issue is open or closed
Safety Committee should meet regularly and document minutes of the meetings
GUIDELINES:
Meeting schedule is established, meetings follow an agenda and are documented with minutes
Agenda items are IEP findings, hazard reports, risk assessments, etc.
Reflect open and closed items or suspense dates in meeting minutes
Membership should include management, and representatives from each functional area of the company
SAF ET Y P OL ICY – 23%
SAMPLE AUDIT RECOMMENDATIONS:
The SMS manual should include a letter outlining the safety policy, clearly describing safety as an operational priority, with
a non-punitive clause signed by a company executive.
Recommend enhancing the promotion component of the SMS by utilizing a campaign offering rewards for SMS
participation.
GUIDELINES:
A safety policy statement signed by an executive will help establish a positive safety culture and should be clear in its non-
punitive posture
Policy statement should be reflected in the GOM/FOM and SMS manual
Policy statements should be reviewed and updated periodically
A rewards program can help encourage personnel to adopt an SMS program
S MS AU DIT R ES U LTS 2012
SMS Audit Results 2012 [email protected] +1 513.852.1010
SMS Audit Results 2012 [email protected] +1 513.852.1010
S MS AU DIT R ES U LTS 2012
SAF ET Y M ANAG EMEN T SY STEM MANU AL – 21%
SAMPLE AUDIT RECOMMENDATIONS:
Conform the SMS manual to the processes they wish to pursue in their SMS execution. The SMS should be fully
implemented as described in the SMS manual.
GUIDELINES: The SMS manual should be:
A distinct, controlled document, or a defined part of a GOM
Reviewed and controlled by an assigned manager
Tailored to the operation (i.e. company organizational chart, risk assessment process, IEP process, etc.)
HA ZAR D R EP OR TIN G – 12%
SAMPLE AUDIT RECOMMENDATIONS:
A hazard identification process needs to be promoted throughout the organization in order to provide input to the overall
risk management program
Increase effort to educate and promote, to all employees, the importance of observing and reporting hazards, incidents,
and close calls
GUIDELINES:
Identify existing and potential hazards through a reporting system
Track hazards to prevent reoccurrence
Define a process for hazard identification and tracking
Communicate to employees that reporting is non-punitive
Promote reporting to increase participation
EM ERG ENCY RE PON SE PLA N DOC UMEN TA T ION – 26%
SAMPLE AUDIT RECOMMENDATIONS:
Recommend that on-site team members be identified in the SMS manual by official job position within the company and all
EPR documents be controlled
The Emergency Response Program does not contain guidance for dealing with in-flight incidents involving injuries or
serious medical problems suffered by passengers or crew.
GUIDELINES:
The Safety Manager must maintain the ability to modify the ERP at any time
The ERP can be a stand-alone document or identified within the SMS manual
Every portion of the manual (handouts included) must be current via a revision control process
Go team responsibilities must be documented
Employees should be included
BRE AKD OWN THE EMERG ENCY R ESPON SE PRO GRA M RECOMMEN DA T ION S
S MS AU DIT R ES U LTS 2012
SMS Audit Results 2012 [email protected] +1 513.852.1010
S MS AU DIT R ES U LTS 2012
SMS Audit Results 2012 [email protected] +1 513.852.1010
BLO OD BORNE P ATH OGENS AND PE RSON AL PR O TEC T ION E QU IPMEN T (PP E) T RA IN ING – 16%
SAMPLE AUDIT RECOMMENDATIONS:
Recommend the on-site response team be trained in the use of the bio-hazard suit
Recommend the on-site response team be trained for BBP exposure
GUIDELINES:
On-site team receive bloodborne pathogens and PPE training and be offered the Hepatitis B (HBV) inoculation
In the case of a team member who refuses the inoculation, a signed, written waiver must be documented; without these
items on-scene access to an accident will likely not be granted by the NTSB
N EXT- OF-K IN N OT IF ICA T IO N AND F AM ILY A SSISTANC E – 15 %
SAMPLE AUDIT RECOMMENDATIONS:
The ERP should include trauma counseling to company employees in the event of an accident or other devastating event
Personnel responsible for notification of next-of-kin and family assistance individuals should be appointed and receive
documented training regarding their duties and responsibilities
GUIDELINES:
N.O.K. notification is accomplished by personnel such as HR or local law enforcement with follow-up by senior manage-
ment
Options for family transportation to the accident should be considered
The selection process, duties/responsibilities, and training of N.O.K. and Family Assistance personal should be documented
G O- TE AM– 14%
SAMPLE AUDIT RECOMMENDATIONS:
Construct Go-Kits or establish an alternate process for obtaining the kits
It is recommended that the ERP Go-Team have alternates assigned and trained
GUIDELINES:
If the company conducts international operations Go-team members should be required to maintain a current passport
Training and responsibilities of each Go-team member should be documented
ERP responders should also be cross-trained for other positions and/or alternate employees selected to fulfill their duties
in the event a key responder is unavailable
In the case of a team member who refuses the inoculation, a signed, written waiver must be documented; without these
items on-scene access to an accident will likely not be granted by the NTSB
S MS AU DIT R ES U LTS 2012
SMS Audit Results 2012 [email protected] +1 513.852.1010
E RP DR ILLS – 8%
SAMPLE AUDIT RECOMMENDATIONS:
Test, or drill the ERP. The Emergency Response Plan (ERP) should be exercised to identify potential problem areas.
GUIDELINES:
A drill should be conducted to verify the ERP will work properly, and include all appropriate personnel in the drill
All personnel with responsibilities in the ERP should be trained before the drill
N TSB ACC IDEN T IN VE STIG AT ION TR AIN ING – 7%
SAMPLE AUDIT RECOMMENDATIONS:
Recommend the on-site Go-team be trained in NTSB investigation procedures
GUIDELINES:
Designated on-site responders should have formal training in the NTSB party process and accident investigation
The NTSB Accident Investigation Orientation for Aviation Professionals course is available
COMPA RISON OF THE 20 12 v. 2011 SAFE TY MAN A GEMENT SYSTEM S R ECO MMENDA T ION S
2012
2011
S MS AU DIT R ES U LTS 2012
SMS Audit Results 2012 [email protected] +1 513.852.1010
COMPA RISON OF THE 20 12 v. 2011 EMERGENC Y R ESP ON SE PROGR AM RE C OMMEND AT IONS
2012
2011
S MS AU DIT R ES U LTS 2012
SMS Audit Results 2012 [email protected] +1 513.852.1010
SMS AN D ER P REC OMME NDA TION S 2012 v. 2008 -2011 COMBIN ED
SMS
ERP
S MS AU DIT R ES U LTS 2012
SMS Audit Results 2012 [email protected] +1 513.852.1010
SMS AN D ER P SUMMARY FROM 2008 -2012
SMS
ERP
S MS AU DIT R ES U LTS 2012
SMS Audit Results 2012 [email protected] +1 513.852.1010