Some years ago, the UKFSC’s recent Chief Executive, Ed Paintin, discussed in these columns the differences between Quality and Safety, and that should have been the end of the matter. Essentially he stuck to the regulator’s understanding of Quality’s purpose, in other words a small part of an organisation’s management to demonstrate regulatory compliance to the FOI.
And of course he was right, in that this is essential to a National Aviation Authority’s (NAA) oversight, and indeed the minimum that many airline managements want, to keep the FOI off their back. However, where JAR-OPS requires a ‘Quality Management System’ to deliver safe operations and airworthy aircraft, safety was quickly (but wrongly) seen as the proactive side of management which J AR Quality could never deliver. Try an accident and see how reactive safety becomes.
- it was minimalist,
- it was about adequacy rather than excellence,
- it was reactionary,
- its scope was restricted to regulatory matters,
- it ignored any Quality tool other than auditing,
- it ignored other management disciplines seen as essential in most other industries,
- it split Quality Assurance away from management,
- it confused QA and QC,
- it made integration with other commercial and regulatory processes difficult,
- it’s not what the rest of the world thinks of as Quality!
With a few honourable exceptions, it could have been so much more.
So some operators started to develop commercial systems that took full account of modern management requirements, and some started work on separate Safety Management Systems (SMS), in which the UKFSC became involved at least 10 years ago. Sadly, the concept of a single management system to deliver regulatory compliance to a number of different regulators (Ops, maintenance, H&S, financial, environmental etc, common in other industries) was seen as too difficult and futuristic, and not tried. In part, of course, this was sadly because individual inspectors were frightened that they’d lose control, of which there are still regular examples.
So we’ve come to the point where pressures beyond Europe, the J AA and EASA have brought about the changes to Annex 6, that require larger aircraft operators to have in place a working SMS by the end of 2008, and rightly so. We’ve come a long way from my days as an FSO, when I was told to go away and get on with it!
However, the road ahead is not that straight forward, in part because EASA operators have their new EU-OPS manuals as a priority, but mainly because EU- OPS has no Section 2. In other words there is no longer any specification for even a minimalist management system.
For some operators this might be the start of a new dawn, where they could have for the first time a single management system to deliver safety and excellence, reactive and proactive with full integration across the entire company. There are management models available for just this. ISO 9001:2000 contains many essential management disciplines, taken a la carte if you will, such as, perhaps, Planning, Supplier Management, and Change and Improvement, all of which have a direct impact on the delivery of a safe operation.
CAP 712, a specification for a Safety Management business model, and its companion CAP 726, are excellent but difficult and generally untried. In fact the Hong Kong CAD has made an excellent job of extracting the essentials from both. The big question, though, remains the same. Should a management system, designed for both profit and safety, be for the company’s use as a tool for safety and excellence, open to all regulatory oversight, or is it an expensive add-on to keep a regulator happy?
After all, are not compliance, air and ground safety, data management, green issues, security and so on, all processes that an operator has to manage? Is it vaguely sensible that the NAA should actually create barriers to effective process management by insisting each to his own micro- system? But it’s happening as, for example, the UK CAA currently tries to split Quality away from Safety.
EASA, however, has not missed the point, and an imminent NPA with a management specification for Compliance (let’s call it that) and Safety Management is eagerly awaited. Whether this will be a genuine management tool, where an operator can share process measurements with the NAA, yet use it at the same time for excellence and improvement, remains to be seen. As a minimum it has to deliver regulatory oversight, but as some airlines stagger into bankruptcy, it might also be the yellow brick road to safety and survival. Let’s hope so.