Safety management systems

Safety management system (SMS) is a term used to refer a comprehensive business management system designed to manage safety elements in the workplace.

Description

An SMS provides a systematic way to identify hazards and control risks while maintaining assurance that these risk controls are effective.[1] SMS can be defined as:

...a businesslike approach to safety. It is a systematic, explicit and comprehensive process for managing safety risks. As with all management systems, a safety management system provides for goal setting, planning, and measuring performance. A safety management system is woven into the fabric of an organization. It becomes part of the culture, the way people do their jobs.[2]

For the purposes of defining safety management, safety can be defined as:

... the reduction of risk to a level that is as low as is reasonably practicable.

There are three imperatives for adopting a safety management system for a business – these are ethical, legal and financial.

There is an implied moral obligation placed on an employer to ensure that work activities and the place of work to be safe, there are legislative requirements defined in just about every jurisdiction on how this is to be achieved and there is a substantial body of research which shows that effective safety management (which is the reduction of risk in the workplace) can reduce the financial exposure of an organisation by reducing direct and indirect costs associated with accident and incidents.

To address these three important elements, an effective SMS should:

A safety management system can be created to fit any business type and/or industry sector.

Basic safety-management components

International Labour Organization SMS model

Since there are many models to choose from to outline the basic components of a safety management system, the one chosen here is the international standard promoted by the International Labour Organization (ILO). In the ILO document ILO-OSH 2001 Guidelines on Occupational Safety and Health Management Systems, the safety management basic components are:

Although other SMS models use different terminology, the process and workflow for safety management systems are usually similar;

  1. Policy – Establish within policy statements what the requirements are for the organization in terms of resources, defining management commitment and defining OSH targets
  2. Organizing – How is the organization structured, where are responsibilities and accountabilities defined, who reports to who and who is responsible for what.
  3. Planning and Implementation – What legislation and standards apply to our organization, what OSH objectives are defined and how are these reviews, hazard prevention and the assessment and management of risk.
  4. Evaluation – How is OSH performance measured and assessed, what are the processes for the reporting of accidents and incidents and for the investigation of accidents and what internal and external audit processes are in place to review the system.
  5. Action for Improvement – How are preventative and corrective actions managed and what processes are in place to ensure the continual improvement process. There is a significant amount of detail within each of these sections and these should be examined in detail from the ILO-OSH Guidelines document.

Safety Stack | Safety Management System Framework Project Model

Since most of the SMS solutions in the U.S. are specifically designed for the aviation industry; non-aviation independent projects are underway such as The Safety Stack | Safety Management System Framework Project, which was developed originally as an open source project that aids small businesses and organizations establish a base SMS framework. Frameworks such as this are designed to improve the way practitioners manage occupational safety & health and assist in complying with ever increasing safety & health regulatory standards. The Safety Stack SMS "Framework" is composed of the following key elements:

Non-aviation industry organizations in the U.S. find this open source, general purpose, SMS framework highly useful in the development of their own unique safety management systems since it can be downloaded, edited, extended & used freely.

Regulatory perspective

Implications

A SMS is intended to act as a framework to allow an organisation, as a minimum, to meet its legal obligations under occupational safety and health law. The structure of a SMS is generally speaking, not of itself a legal requirement but it is an extremely effective tool to organise the myriad aspects of occupational safety and health (OSH) that can exist within an organisation, often to meet standards which exceed the minimum legal requirement.

A SMS is only as good as its implementation – effective safety management means that organisations need to ensure they are looking at all the risks within the organization as a single system, rather than having multiple, competing, ‘Safety Management Silos.’[3] If safety is not seen holistically, it can interfere with the prioritization of improvements or even result in safety issues being missed. For example, after an explosion in March 2005 at BP's Texas City Refinery (BP) the investigation concluded that the company had put too much emphasis on personal safety thus ignoring the safety of their processes.[4] The antidote to such silo thinking is the proper evaluation of all risks, a key aspect of an effective SMS.[4]

Implementation

Adoption for industry sectors

There are a number of industry sectors worldwide which have recognised the benefits of effective safety management. The regulatory authorities for these industries have developed safety management systems specific to their own industries and requirements, often backed up by regulation. Below are examples from different industry sectors from a number of varied worldwide locations.

Civil aviation

The International Civil Aviation Organization has recommended that all aviation authorities implement SMS regulatory structures.[5] ICAO has provided resources to assist with implementation, including the ICAO Safety Management Manual. Unlike the traditional occupational safety focus of SMS, the ICAO focus is to use SMS for managing aviation safety. Id.

The ICAO High-level Safety Conference 2010 recommendation 2/5 proposed the development of a new Annex (19) dedicated to Safety Management. The Annex was published in February 2013 and entered into force on November 14, 2013. The benefits identified of this approach included:

[6]

The United States has introduced SMS for airports through an advisory circular[7] and other guidance.[8]

The United States announced at the 2008 EASA/FAA/TC International Safety Conference that they would be developing regulations to implement SMS for repair stations, air carriers, and manufacturers. The FAA formed a rulemaking committee to address the implementation (known as the SMS ARC).[9] The SMS ARC reported its findings to the FAA on March 31, 2010. The Report recognizes that many of the elements of SMS already exist in the U.S. regulations, but that some elements do not yet exist.[10] A draft of what the US SMS rule might look like was proposed by one trade association that participated in the ARC.[11] Currently, the FAA is supporting voluntary pilot projects for SMS.[12]

The Federal Aviation Administration has also required that all FAA services and offices adopt a common Aviation Safety (AVS)Safety Management System (AVSSMS).[13] This is what ICAO calls a State Safety Program (SSP). An overview of the FAA approach to SMS may be found in the following PDF document.[14]

The Federal Aviation Administration published a Notice of Proposed Rulemaking (NPRM) for the establishment of SMS for air carriers.[15] That NPRM explains that it is intended to serve as the foundation for rules that would later be applied to Part 135 operators, Part 145 repair stations and Part 21 manufacturers. Id. Several U.S. trade associations filed comments in response to the air carrier NPRM, including the Aviation Suppliers Association (ASA) comments in response to the SMS NPRM.[16] and the Modification and Replacement Parts Association (MARPA)[17] Among these comments were arguments for developing separate SMS regulations for other certificate holders, in order to make sure that SM remains a usable tool for advancing safety (rather than a uniform but useless paperwork exercise). In addition, the Federal Aviation Administration has also filed a NPRM for SMS for airports,[18] which would be separate from the rules for SMS for air carriers (consistent with the arguments of the trade associations).

The European Aviation Safety Agency (EASA) began the process of implementing Safety Management System (SMS) regulations by issuing Terms of Reference (TOR) on July 18, 2011.[19] That was followed by a Notice of Proposed Amendment (NPA) issued on January 21, 2013.[20] The proposed EASA regulation would apply to repair stations,[21] but would have significant ancillary effects on other aviation industry sub-sectors.[22]

Maritime industry

The International Maritime Organization (IMO) is another organization that has adopted SMS. All international passenger ships and oil tankers, chemical tankers, gas carriers, bulk carriers and cargo ships of 500 gross tons or more are required to have a Safety Management System.[23] In the preamble to the International Safety Management (ISM) Code, the IMO states, “The cornerstone of good safety management is commitment from the top. In matters of safety and pollution prevention it is the commitment, competence, attitudes and motivation of individuals at all levels that determines the end result.”[24]

Railway industry

Transport Canada’s Rail Safety Directorate incorporated SMS into the rail industry in 2001. The Rail Safety Management System requirements are set out in the Railway Safety Management System Regulations.[25] The objectives of the Rail Safety Management System Regulations are to ensure that safety is given management time and corporate resources and that it is subject to performance measurement and monitoring on par with corporate financial and production goals.[26]

The effect of SMS in the rail industry has not been positive, as a 2006 Toronto Star review of Transportation Safety Board data indicated that rail accidents were soaring.[27] Critics have argued that this evidence should preclude the adoption of SMS in the aviation sector.[28] However, Transportation Safety Board data show that the accident rate in the rail industry has actually varied around the average over that 10-year period. Since the Toronto Star article was published, the accident rate has decreased. The Transportation Safety Board reported that “a total of 1,143 rail accidents were reported to the TSB in 2008, a 14% decrease from the 2007 total of 1,323 and an 18% decrease from the 2003–2007 average of 1,387” and also noted that, in 2008, rail incidents reported under the TSB mandatory reporting requirements reached a 26-year low of 215.[29]

The RSMSR has in 2015 been updated.[30]

See also

References

  1. ↑ http://www.faa.gov/about/initiatives/saso/library/media/SASO_Briefing_Managers_Toolkit.pdf SASO Outreach, Spring 2009
  2. ↑ Transport Canada publication TP 13739
  3. ↑ http://flightsafety.org/asw/may08/asw_may08_p12-17.pdf Evans, Andy and John Parker. May 2008. Beyond Safety Management Systems. Pp. 12–17 in AeroSafety World.
  4. 1 2 http://sunnyday.mit.edu/Baker-panel-report.pdf Baker Report
  5. ↑ Implementation of the State Safety Programme (SSP) in States (November 13, 2008)
  6. ↑ Annex 19 (Safety Management Systems) Executive Summary
  7. ↑ Advisory Circular 150/5200-37 Introduction to Safety Management Systems (SMS) for Airport Operators (February 28, 2007)
  8. ↑ A list of guidance and supporting information can be found on the FAA website.
  9. ↑ http://pmaparts.wordpress.com/2010/02/17/can-you-implement-a-sms-program Blog Entry on the SMS ARC Progress: Can You Implement a SMS Program?
  10. ↑ Safety Management Systems Aviation Rulemaking Committee, Final Report
  11. ↑ http://pmaparts.wordpress.com/2010/03/17/a-possible-look-for-sms-regulations/ Draft Part 195 (Safety Management Systems).
  12. ↑ http://www.faa.gov/about/initiatives/saso/library/media/SMS_Brochure.pdf
  13. ↑ http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/reOrders.nsf/0/6aae93ff516cd6fd862571fb00661605/$FILE/VS%208000.1.pdf
  14. ↑ http://www.faa.gov/pilots/training/part_142/tcpm_conf_2008/media/Safety_Managemet_Systems_presentation.pdf
  15. ↑ http://www.gpo.gov/fdsys/pkg/FR-2010-11-05/pdf/2010-28050.pdf Notice of Proposed Rulemaking: Safety Management Systems for Part 121 Certificate Holders, 75 Fed. Reg. 68224 (November 5, 2010).
  16. ↑ http://www.aviationsuppliers.org/ASA/files/ccLibraryFiles/Filename/000000000572/2011-03-07%20ASA%20SMS%20NPRM%20Comments.pdf
  17. ↑ http://pmaparts.org/gvt/2011-03-07_MARPA_SMS_NPRM_Comments.pdf MARPA's Comments in response to the SMS NPRM.
  18. ↑ http://www.gpo.gov/fdsys/pkg/FR-2010-10-07/pdf/2010-25338.pdf Notice of Proposed Rulemaking: Safety Management System for Certificated Airports, 75 Fed. Reg. 62008 (October 7, 2010).
  19. ↑ http://pmaparts.wordpress.com/2011/07/28/easa-begins-the-process-of-implementing-sms-rules/ See Dickstein, EASA Begins the Process of Implementing SMS Rules (July 28, 2011).
  20. ↑ http://aviationsuppliers.wordpress.com/2013/01/21/european-sms-proposal-will-likely-affect-distributors/ See Dickstein, European SMS Proposal Will Likely Affect Distributors (January 21, 2013).
  21. ↑ http://hub.easa.europa.eu/crt/docs/viewnpa/id_199 See Notice of Proposed Amendment (NPA) 2013-01 (Jan 21, 2013).
  22. ↑ http://aviationsuppliers.wordpress.com/2013/01/21/european-sms-proposal-will-likely-affect-distributors/ See Dickstein, European SMS Proposal Will Likely Affect Distributors (January 21, 2013) (discussing the potential effect of the rule on aircraft parts distributors).
  23. ↑ http://www.imo.org/humanelement/mainframe.asp?topic_id=287 International Safety Management (ISM) Code 2002.
  24. ↑ http://www.admiraltylawguide.com/conven/ismcode1993.html The International Safety Management Code IMO Assembly Resolution A.741(18) – 1993.
  25. ↑ laws-lois.justice.gc.ca: "Railway Safety Management System Regulations"
  26. ↑ http://www.tc.gc.ca/eng/railsafety/publications-tp13548-267.htm
  27. ↑ Freight train accidents soar
  28. ↑ New rules for aviation safety a flight plan to disaster, critics warn
  29. ↑ http://www.tsb.gc.ca/eng/stats/rail/prelim-2008/index.asp
  30. ↑ laws-lois.justice.gc.ca: "Railway Safety Management System Regulations, 2015"
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