A drone safety management system (SMS) is critical to building a culture of safety in the organization. Safety expert Fred Roggero explains how to develop an effective SMS.
Don’t Fly Blind – The Four Pillars of Safety Management
By: Dawn M.K. Zoldi (Guest Contributor)
A solid Safety Management System (SMS) will drive an organization’s safety culture. A business-like systematic approach to managing safety risks, a SMS provides an organized way to set goals, make plans and measure a business’ performance. The International Civil Aviation Organization (ICAO) organizes the SMS concept around four pillars: policy, safety risk management, safety assurance and promotion. Safety expert, Fred Roggero (Major General USAF Ret.) President & CEO of , a customer-focused professional services company headquartered in McLean, Virginia, provides his perspective on these pillars below.
Policy. Policy consists of a written course of action that a company adopts for its operations or, as Roggero the former U.S. Air Force Chief of Safety puts it, “what you say you are going to do.” For SMS this means capturing safety processes and procedures. First codify who is the accountable executive. Who’s in charge? Who’s the accountable executive to praise when things go well or hold accountable when things do not?” Companies should determine if they have an in-house safety expert already, whether they need to hire someone or whether they will just accept the risk (*This last is the throw-away course of action!) The General quips, “Even if you have no accountable executive – or even no safety policy- you still technically have an SMS. It’s just not a very good one. Have fun explaining that to the FAA.”
Policy also outlines the safety practices to which the organization should adhere. At a minimum, good SMS policies incorporate relevant regulatory requirements. For Part 107 operations, the operational guidelines in Advisory Circular 107-2A (pre-flight checks, pilot fitness and equipment maintenance, etc.) should inform actual practice.
Safety Risk Management. Risk management requires an organization to take an in-depth internal look at its operations to identify potential hazards or risks and then build out mitigations. Managing safety risks lies at the heart of any SMS as it allows an organization to establish a structured and systematic way to:
• Identify the hazards and safety events to which it is exposed;
• Investigate and analyze them to identify and understand the risks; and
• Adopt ways to manage and reduce these risks to an acceptable level.
Roggero says, “Risk identification is about determining, in advance, “what can go wrong.” Will you be flying in or near controlled airspace, air traffic, other property that could be damaged, physical obstacles like trees etc? If the answer is yes to any of these risks, then determine how to mitigate them. For example, if there could be privacy issues because the operation will occur near a housing area, inform the residents that you will be flying.
Regularized training can also help mitigate risk. SMS training should educate people about SMS concepts, employee responsibilities within it and how to conduct required activities with competence. “There are a ton of great training resources available on SMS. The is one of them,” says Roggero, who has been a UAST member since 2017. UAST is an industry-government partnership committed to ensuring the safe operations of UAS in the national airspace system, supporting their safe integration with data-driven safety enhancements and collaboration among members of the UAS industry. UAST created must-read .
Safety Assurance. “Safety assurance is all about going back and making sure that the mitigations you put in place are actually working. This is where audits or pulse checks with your team come into play,” the General explains. Many businesses lack follow-through in the execution of safety policy. They often compound this error by failing to continually evaluate the efficacy of their safety programs or culture. If things are going well, this should provide reassurance that the SMS your team designed up to this point is working. If it is not working, fix it. “Seek information from your employees as to how your safety program is actually working – otherwise, you are flying blind.” Fight for feedback.
Roggero also advises, “If you say you are going to do something, do it.” If your policy says you capture lessons learned then have you captured them and put them back into your training program to prevent future errors? SMS is a continuous improvement process that requires revaluation and re vectoring over time. It’s never one and done.
Promotion. “Promotion requires communication, from the top to the bottom of any company, about safety” according to the General. Everybody must understand the safety goals, policies and practices and results related to your company’s SMS. This last may be surprising. Roggero encourages leaders to report out the results of audits transparently to employees, investors, current and prospective clients and other key stakeholders. “This will help a safety culture take root in your business,” he suggests. An organization’s highest level of management drives the cultural change required within the organization by not shying away from difficult conversations when operations could be improved. Leaders must not only talk the talk, but also walk it.
Building a Drone Safety Management System
If a UAS business implements these four pillars, SMS will become the core of its safety culture and this will eventually become the norm for people in executing the mission. An unsafe culture is one that risks potential loss of business and reputation; legal fees and damage claims; medical costs; lost of use of equipment and time of injured workers (loss of income); increased insurance premiums; and potential fines. “At the end of the day, though, safety is all about protecting people, which is any organization’s most precious asset,” says Roggero. A robust SMS demonstrates to your stakeholders (employees, customers, investors and regulators and the public) that you are serious about looking after their welfare while being safe, compliant and profitable.
Having an SMS is not just the right thing to do. It’s the smart thing to do.
Dawn M.K. Zoldi (Colonel, USAF, Retired) is a licensed attorney with 28 years of combined active duty military and federal civil service to the Department of the Air Force. She is an internationally recognized expert on unmanned aircraft system law and policy, the Law-Tech Connect™ columnist for Inside Unmanned Systems magazine, a recipient of the Woman to Watch in UAS (Leadership) Award 2019, and the CEO of P3 Tech Consulting LLC. For more information, visit her website at: https://www.p3techconsulting.com