- My organisation already has an SMS described in the exposition that the CAA has previously accepted. Why do I need to submit an implementation plan?
- How is SMS different from QMS?
- What are the benefits of an SMS?
- What are the roles and responsibilities in the SMS?
- How much will it cost?
- What are the senior person training requirements?
- Is SMS suitable for a 'one man band'?
- What is the relationship between SMS and Worksafe / ACC?
- Will the CAA provide sample expositions?
1. My organisation already has an SMS described in the exposition that the CAA has previously accepted. Why do I need to submit an implementation plan?
Formal approval of an organisation's SMS is made in writing and includes an amendment to the conditions (Operations Specificiations, Approvals Specifications, Exposition Acceptance etc.) associated with the organisation's certificate(s). Expositions submitted to the CAA prior to Rule Part 100 coming into force, have been accepted on the basis of complying with the operating rule applicable at that time (e.g. QMS / OMS). All certificated organisations required to establish, implement, and maintain a system for safety management must submit an implementation plan including a proposed date for implementation and an outline of how this will be achieved.
For organisations that have been voluntarily operating a safety management system, the plan could take the form of a covering letter with the application form CAA 24100-1 stating the references to where the current system is described, that a gap analysis against the current AC100-1 acceptable means of compliance has been performed, with either details of any changes made or no change required, as appropriate.
The main difference is that, unlike QMS, a successful SMS is inherently risk-based and forward looking.
- QMS is about assuring compliance with standards and continual improvement.
- SMS is about identifying the hazards and associated risks that impact the whole organisation, and the control of these risks.
Both systems enhance safety and are essential and complementary management tools. You cannot have an effective SMS without applying quality management principles. Moving from QMS to SMS is shifting from rule compliance to safety compliance.
Safety: Proactive reduction of risks of accidents and incidents.
Financial: Provides for better resource allocation that will result in increased efficiencies and reduced costs.
Regulatory: Helps you meet many legislative requirements by integrating with other management systems (incl. HSW, CAA, etc.)
Business: Provides for more informed decision-making; strengthens corporate culture; demonstrates corporate due-diligence.
The Chief Executive: is responsible for establishing the SMS, allocating resources to support and maintain the SMS, and leading the safety culture for an effective SMS.
The Safety Manager: is a senior person responsible for facilitating and administering the organisation's SMS.
All staff: must be aware of, and understand their safety responsibilities e.g. identifying hazards and reporting them.
There will be some implementation costs (e.g. certification, training of staff, an electronic reporting system if used). Most of the costs for organisations will be in staff time for implementing and maintaining the SMS.
This, however, is scaleable to the size and complexity of the organisation.
Approval of an organisation's SMS is a CAA certification activity and standard fees and charges apply. Refer to Fees, Charges and Levies on CAA web site.
Part 100 requires training that ensures all personnel are competent to fulfil their safety responsibilities. The training should be commensurate with the size, nature and complexity of an organisation. Therefore each organisation should establish the training needs for personnel based on their safety responsibility.
To assist organisations develop training needs assessments for individual personnel refer to Element 12 in AC100-1 Safety Management.
The SMS rule provides for scalability of the safety management requirement, specifically rule
100.3(c) requires: the organisation’s system for safety management must correspond to the size of the organisation, the nature and complexity of the activities undertaken by the organisation, and the hazards and associated risks inherent in the activities undertaken by the organisation.
There are similarities between management system standards for occupational health (e.g. AS/NZS 4801, 4804), environmental management (e.g. AS/NZS ISO 14004) and quality management (e.g. AS/NZS ISO9001). This presents opportunities for integration with operational SMS in areas such as safety committees, hazard identification and risk assessment methodologies, safety assurance, and consolidated communication and safety promotion efforts.
The main point of difference between SMS and WorkSafe/ ACC is that SMS is focused upon operational safety (aircraft accident/incident) versus the latter where the focus is on occupational safety (harm to the person).
The CAA will not be providing sample expositions as the wide range of organisations and operations conducted does not lend itself to “one size fits all” sample manuals that are appropriate and applicable to individual organisations.
Organisations should look to embed the SMS documentation into their existing manual suite or within an associated safety manual, in the same way that some organisations currently document their QMS within a quality manual.