As a safety professional it always captures my attention when an industry begins accepting (well in a “resistance is futile” kind of way) that a Safety Management System (SMS) is the most proven method to manage safety risk – though sadly only after a regulation is passed, a catastrophic event occurred – or both. Some enlightened companies will have already drank the kool-aid and found that not only does an SMS improve safety outcomes, but it also promotes organizational and operational excellence. In a nutshell: It’s good for the bottom line.
So back in 2018 the FTA published its PTASP Final Rule requiring companies operating under the federal UAFG program to incorporate an SMS by year end. (Translation: The [US] Federal Transportation Administration has published the Public Transportation Agency Safety Plan requiring companies operating under the federal Urbanized Area Formula Grants program to incorporate a Safety Management System by 31 December 2020.)
So somewhere around late 2017, or after the FTA’s rule was published, the head of safety and/or quality probably pointed to the safety manager(s) and said “Make it so No.1” (that’s what happened to me in 2004). They post the regulation (shall) guidance material (should), and provide webinars, training and presentations. Safety Managers will attend, read, discuss, design, plan, do, check, act, rinse and repeat (sound familiar?) The rules will be straight forward, but how do we start? Our company is different! How do we get everyone on the bus? How many clichés are in this paragraph? …but I digress.
In 2005, the International Civil Aviation Organization (the aviation sector of the United Nations) implemented the requirement for SMS in large carrier operations in all its member states. Over the years, it has been prescribed throughout the industry – airports, maintenance, design, training, etc. – and has been touted as one of the reasons for the very low accident rate world wide. SMS is not without its critics (a healthy activity), however if properly implemented, maintained and matured over time, an SMS will benefit companies not only with a lower rate of incidents and accidents, but a larger market share, fewer losses, and an improved ROI.
Since then, other industries have jumped on the SMS bandwagon whether regulated to or not. Sometimes the acronym is changed, but the general recipe has not. When a company commits to an SMS, they commit to a better organization and operational excellence – it’s not just about safety, it’s about managing risk – protecting people, the environment, assets and reputation, and thereby improving operations as you go.
So for you No. 1’s out there – your No. 1 challenge is leadership commitment to change. Yes it’s true. Without the commitment from the top to supply the leadership and resources to do what you need to do, you will at best comply to the new regulations, but you will not change the safety culture that is required to get and manage the information you need to understand and manage risk. And information is key – from staff and customer reporting, investigations, assessing risk, monitoring corrective actions, audits and inspections, managing contractors, and providing services to clients – its all part an integrated management system with Safety and Quality at its core.
Implementation does not happen overnight, but the vast majority of operators have what they need to begin. It’s about “knowing” not “guessing”, and “data” rather than “gut feeling”. Being able to demonstrate that your hazards and threats are known and controlled, being compliant to standards (the ones within the operation and from external requirements) and being able to prove it. And strangely enough, this will take effort – resources, organization, training, leadership, oversight. Unless you are a very small operation indeed, you need a software system that will not only collect the myriad of information that could be available to you, you also need the ability to trend that data to both find and manage risk as well as to provide your organization a transparent and single source of truth. Perhaps add in sustainability and environmental compliance, ISO, OSHA…? Perhaps integrate your contractors, suppliers, customer complaints and a host of other information? Now you’re cooking with gas! Risk exists throughout the organization, either directly (car hits lamp post) or indirectly (child runs out on the street being chased by her big sister after stealing the last cookie and car swerves to miss child hitting the lamp post) – well you get my drift.
Yes, every industry, company and operation is different, but the recipe for an SMS is the same regardless – it’s about ensuring that the required elements are fit for purpose, not the other way around. This applies to a donut shop, a nuclear power plant, and everything in between. SMS is not new, some of us have been through what you are going through now. Reach out for help.