Mandating SMS worldwide is only the first step in making air transportation safer. Robert W. Moorman explores the training component that involves risk.
While the concept of safety management systems (SMS) has been around aviation for years, some integral elements of the approach to managing and assessing risks may not be well known. Risk assessment, analysis and management are three key elements of the four-pillared SMS, which are being implemented by airlines, training houses and independent fixed and rotary aircraft operators.
The Euro Control-funded Skybrary, with input from the Flight Safety Foundation and ICAO, defines risk assessment as an engineering-related evaluation to determine whether “the achieved or perceived risk is acceptable or tolerable.” [The definition is based on ICAO Doc. 9859.]
Good risk assessment comes from good data gathering and analysis, and being able to effectively manage the risk via education/training. How to go about evaluating risk as part of an overall SMS program is still evolving.
“What usually is taught is how to look for hazards and do the reactive risk assessments through the use of a probability versus consequence matrix,” said Mark Millam, vice president Technical, Flight Safety Foundation (FSF). “If an airline finds that there is a confusing procedure, like an airport taxi instruction that leads to a near runway incursion, a safety report is used and a risk assessment is done to determine whether procedures must change.”
Millam said the assessment determines if there is probability that the procedure will confuse other crews. The airline could then change the procedure and monitor the results of the procedure change “until they know the issue is fixed or the probability of it happening has been reduced to an acceptable level.”
Being proactive or predictive on risk assessment and management “requires several sets of data and looking for probable outcomes,” he added.
Airline employees are often trained on assessing and managing risk through an airlines’ overall SMS training program. The same applies to independent aircraft operators of fixed and rotary wing aircraft.
“Proactive and predictive (training) is often learned through greater information sharing between stakeholders,” said Millam. The US Aviation Safety Information Analysis and Sharing System (ASIAS) is one example, he added.
One way to determine the effectiveness of an airline’s SMS program (and its parts) is through a safety and cost benefit analysis. But determining the cost benefits of an SMS program and its various parts is challenging.
Training houses and other aircraft operators employ methods to assess and manage the level of risk associated with a particular flight. Skyborne Airline Academy, a start-up based at Gloucestershire Airport in the UK, requires all student pilots, whether in the aircraft or simulator, to complete a Flight Risk Assessment Tool (FRAT) test to assess the level of risk associated with a particular flight.
Any risk higher than Grade 2 must have a mitigation strategy to lower the risk to an acceptable level. Skyborne’s ‘Significant Six-Key Threats’ are reviewed at the end of every pre-flight briefing. Risk factors assessed as ‘high’, and the related mitigating factors are discussed with the instructor during the pre-flight briefing to ensure that the student pilot is aware of the mitigation factors and how they should be applied. The test is rated by color, with green as low risk; amber, in which mitigating strategies must be included in the flight, and red, which only allows the flight to go ahead if approved by the chief flight instructor.
“We want our students to develop the mindset of avoid, trap and mitigate,” said Ian Cooper, chief operating officer, Skyborne Airline Academy. “If you can’t avoid, trap it and mitigate the risks.”
Example: If a mid-air collision is considered to be a threat because the flight is to take place in congested airspace, then the threat is discussed between student and instructor. The threat can be avoided with a good lookout and/or a traffic awareness system in the cockpit. Vigilant aircrews can trap a threat by spotting an error before it becomes a serious problem, said Cooper. Better situational awareness, briefings before and after flights, and workload management are ways to better manage risk.
FRAT applies both to fixed and rotary-wing operators, and several EMS helicopter flight departments use risk assessment and management as a way to enhance the safety and efficiency of their operations.
All Helicopter Air Ambulance (HAA) operators are required to have their pilots complete and sign a FRAT test prior to accepting an air medical mission. FRAT is part of the FARs and Operations Specifications (AO21) requirements for Air Ambulance operators.
“With the demanding pressures placed on pilots in the aeromedical industry, measures need to be in place for risk assessment/recognition and ultimately risk management/mitigation,” said Kerry Berg, Aeromedical Committee Chairman, Helicopter Association International (HAI). If the risk exceeds a pre-determined threshold, the pilot must decline the flight. The FRAT test considers fatigue, stress, duty time, number of flights flown already and the pilot’s personal experience and time in the current aircraft. Whether another pilot declined the same flight is also factored into the decision to go or not go.
Training houses, universities, associations and governments offer courses in risk assessment, analysis and management. The genesis of risk related instruction grew out of the SMS requirements and standards for Part 121 carriers outlined in ICAO Annex 19. A first amendment to Annex 19 requires the states to manage risk from a civil aviation perspective.
Early adopters of SMS include Transport Canada, CASA in Australia and the European Aviation Safety Agency (EASA). Part 121 US-based air carriers were required under 14CFR, Part 5 to have a SMS system in place by March 2017.
While there is no specific need for training, Annex 19 stipulates that all personnel be trained to perform their SMS duties, according to Nancy Rockbrune, head of Safety Management Systems for the International Air Transport Association (IATA). Rockbrune is IATA’s representative on the ICAO Safety Management Panel, which created Annex 19.
“IATA’s role is to help our members facilitate a safety management program,” which includes risk assessment, analysis and management elements, said Rockbrune.
Rockbrune works with regulators to make sure they don’t put an undue burden on airlines to implement SMS. “An SMS system needs to be effective and prescriptive,” she said.
IATA offers member airlines a three-day risk management course. In the past three years, 479 people from 50 countries have taken the course. “IATA member airlines told us they have challenges with implementing safety risk management training on site,” said an IATA spokesperson. “So we created this course to fill the need.”
The course is taught by IATA personnel and held at several IATA training centers worldwide. The facilities are located in Miami, Montreal, Geneva, London, Frankfurt, Madrid and Singapore.
Elsewhere, risk-related courses are taught. The UK’s Civil Aviation Authority (CAA) offers a two-day course at London Gatwick Airport for approximately £900($1,152). The course includes: risk monitoring and safety performance instruction as part of an SMS system; understanding and identifying hazards; risk assessment methods; risk modeling; safety performance techniques; and learning about safety performance indicators.
Embry Riddle Aeronautical University (ERAU) taught SMS related courses long before SMS was mandated for most US commercial airlines. The Daytona Beach, Florida campus offers a Bachelors degree in Aerospace and Occupational Safety. In this program, there are several courses, which cover risk assessment and risk management. Introductory risk-related courses are taught at the freshman level (200-level). As students advance to the 300 and 400-level courses, the school offers a safety management course, which is basically an in-depth SMS course.
The regulatory mandate for Part 121 carriers to have SMS certainly played a role in the growing need and popularity of risk related coursework. “But also the general shift in safety from a reactive science to proactive applications as well as the predictive side played a role,” said Anthony Brickhouse, associate professor, Applied Aviation Sciences, director, Aerospace Forensic Lab, Embry Riddle Aeronautical University.
Embry Riddle Worldwide offers various risk analysis courses online, which vary in cost from $1,596 to $1,796. The courses range from Safety Management Systems or SMS Basics for Public Service Aviation; Aviation Law and Risk Management; Risk Management and Hazard Identification; and Airport & Aviation Risk Management and Hazard Identification. The courses vary from four to six weeks long.
Some major airlines provide training for certain elements of SMS. Aviation Quality Services (AQS), a unit of Lufthansa Aviation Training, which operates independently, offers risk management training at different levels and tailored to the individuals’ involvement in the Safety Management System (e.g. SMS for Safety and Quality Professionals, Risk Assessment Training and Advanced Safety Management System training).
Part 121 carriers in-house training departments typically provide risk related courses or farm out the task to larger training organizations. And there are other companies that provide SMS related training for smaller airlines, charter operators and repair stations.
“What we’re starting to see now are a lot of charter carriers operating under Part 135, said Mike Rioux, chief operating officer of JDA Aviation Technology Solutions, an aviation consulting firm that focuses on five lines of business, including training. “In the last six months, we’ve gotten a lot of queries about SMS and the various parts of it,” he added.
Some queries come from repair stations, which want to make sure that they are compliance with SMS regulations, policies and advisory circulars. Rioux said JDA trains an entire company in the SMS basics initially. A select group of those employees are tapped later for JDA’s more advanced train-the-trainer program, which dives into the specific risk related elements.
JDA is authorized by the FAA to teach and implement various aspects of SMS. The company is licensed by Bedford, Mass.-based Mitre Corporation, a non-profit, which manages federally funded research and development centers of various government agencies.
SMS is not new. However, certain elements, such as risk assessment analysis and management might require specific training. “Risk assessment is going to become more important,” said Rioux. “This training is not just for air carriers. It has applicability for the helicopter industry as well.”
Some software companies feed from the SMS trough. Anchorage, Alaska-based NorthWest Data Solutions provides risk analysis and management software programs. The company’s SMS Pro software helps companies obtain a mission risk assessment, evaluate the hazards and determine if the flight risk is acceptable. Clients include universities, flight schools, airlines and FBOs, as well as maintenance, repair and overhaul (MRO) facilities.
“The most important part of aviation risk management is that all employees understand the difference between a hazard and a risk and then act upon the risk,” said Christopher Howell, CEO of NorthWest Data Solutions. Hazards may have an acceptable risk but they still need to be assessed and acted upon, he said.
Risk management training should be commensurate with the level of responsibility for the SMS. “Try to understand what type of risk management training is required for different users,” continued Howell.
He cautioned trainers to avoid the “paralysis by analysis” scenario. Don’t document every risk. Come up with credible risk scenarios, he advised. He provided this link to two videos on teaching various aspects of SMS - https://aviationsmsinfo.asms-pro.com/watch-automated-computer-based-aviation-sms-training-course-videos
NorthWest Data Solutions was the first company to come up with the electronic flight risk assessment tool, FRAP, according to Howell.
Risk-related courses extend beyond the cockpit, flight operations and airlines. CAT found that various safety and risk-averse companies offer corporate and safety risk management courses as well as instruction on fatigue, security and crisis management. The aforementioned helicopter EMS operators also offer risk-related courses as a way to improve their overall safety record.
Even schools, which offer risk-related courses under the SMS banner, practice what they preach. UND Aerospace, part of the University of North Dakota, underwent a risk assessment and management process as part of its plan to transition to Piper Archers single-engine trainers from Cessna 172s. Part of that process included sitting down with personnel involved in maintaining, flying and managing the trainer fleet.
Under the SMS umbrella, student pilots, flight instructors, safety officers, academics and others are asked to review their basic responsibilities and principals of the flight department’s SMS and its risk-related elements. “The ultimate goal of proactive assessment is that you’re never outside of unacceptable risk,” said Brian Willis, director of Aviation Safety. “This is a protection for the university, student pilots and others involved in flight operations.
Published in CAT issue 6/2018