SMS Implementation and the Challenge of Transformational Change

Safety Management. Safety, in the context of Indian civil aviation and more specifically to the evolution of safety management, is now firmly linked to effective implementation of a Safety Management System (SMS), mandated by the International Civil Aviation Organisation (ICAO). Operational and business excellence is today synonymous with effective implementation of SMS. India appears divided on SMS issues — its reluctance to take definitive steps, is in sharp contrast to well-developed aviation markets.

Safety Culture and Public Apathy. The Air India (AI) Boeing 737 accident at the Mangalore table-top airport in 2009 resulted in total aircraft hull loss and fatalities to most of the passengers. It brought home starkly that much improvement is required to harmonise SMS benchmarks to international standards and best practices. The investigation into this accident has identified unintended failures that involve two stakeholders namely the regulator Directorate General of Civil Aviation (DGCA) and the service provider (AI). A classic case of an organisational accident that points to shortcomings in the safety culture of both the stakeholders. This was an avoidable accident. It reflects the shortcomings of civil aviation department to harmonise safety culture and SMS to international best practices. Sadly, it also reflects the apparent apathy of the common citizen in demanding accountability and high safety standards from aircraft operators. But this accident was back in 2009 and eight years have passed by. SMS awareness is no doubt increasing, even though the pace is still slow and patchy at best. If the pace has to pick up, it is key for the DGCA to embrace SMS first and lead by example. After all they are the aviation safety regulator of India. Also, operators need to voluntarily come forward to embrace SMS within their organisations. It really does take two to tango for the safety culture to spread all over.

Safety Downgrades and National Image. The repeated down-grading of Indian regulatory authorities on Significant Safety Concerns (SSC) by ICAO and the US Federal Aviation Administration (FAA) must have alerted the Indian Ministry of Civil Aviation (MoCA) on the need to implement internal changes driven by the imperatives of globalisation. The delay in implementing these changes was one of many reasons for downgrading in the past. With the ICAO scheduled to visit in November 2017, the DGCA would do well to evaluate the effectiveness of SMS implementation through a gap analysis and subsequent corrective actions.

The repeated downgrading of India by international civil aviation authorities and the constant media attention that these events have attracted has resulted in an image of India, as a country of low safety expectations. Singapore, Japan and the European Union are some examples of countries that had imposed restrictions on Indian aircraft operations in the past.

Safety Performance. Safety performance of general aviation (GA) has a long way to go to match international benchmarks. The civil helicopter accident rate indicates a trend of 5.87 per 1,00,000 flight hours (last 10 years), against a target rate of 1.9 per 1,00,000 flight hours. The safety performance of fixed-wing GA aircraft also needs significant improvement to match global standards.

It is with a view to improve safety performance that the BAOA (Business Aircraft Operators Association), has coordinated the visit of the IBAC (International Business Aviation Council) to the DGCA, on February 9, 2017, and hosting the first Safety Workshop for Business Aviation in India, on February 10, 2017. IBAC is expected to present the merits of India adopting the IS-BAO (International Standard for Business Aircraft Operations), as one of the means to implementing ICAO mandated SMS.

IS-BAO

The IS-BAO, as a safety standard, is rapidly gaining acceptance globally by civil aviation regulators. It is considered the Gold Standard in Safety. The standard is well known in developed aviation markets such as the US, Canada, Europe and Australia. Over 700 aircraft operators globally are certified to the IS-BAO across various stages, under a registration/certification process overseen by the IBAC (International Business Aviation Council), whose office is co-located with the ICAO in Montreal, Canada. Hence, wider adoption of the IS-BAO by India would raise the safety bar to an international benchmark, of acceptance globally.

IS-BAO has three stages — IS-BAO Stage 1 denotes that the physical elements of SMS is set up in the organisation and understanding of SMS is in place. Stage 2 denotes SMS has started functioning and running within the organisation. Stage 3 denotes the organisation has a mature and well entrenched SMS system in place. DGCA would be assisted by IBAC accredited third party auditors in taking operators through the IS-BAO stages.

The implementation of SMS in India is yet to mature. A collaborative approach between the DGCA and GA operators would be necessary to tackle the significant challenges posed by transformational change.

CHALLENGE OF TRANSFORMATIONAL CHANGE

Change Management. One of the reasons for poor implementation of SMS in India is the delay of the regulator as well as the GA/BA industry, to fully understand the nature of change involved in progressing from the concept of flight safety to that of SMS. This change can be said to be transformational, in that, a change is sought from a reactive response to accidents, to predicting accident trends, based on a positive safety culture that encourages openness in reporting potential hazards. In the Indian context, the change to an open and liberal safety culture needs nurturing by the civil aviation organisation as a whole. It would involve the implementation of a collaborative approach between the regulator, as well as the GA/BA industry, represented by the BAOA. Indeed, the BAOA would do well to expand the scope of its responsibilities to jointly work with DGCA and GA/BA operators to see India through this transformational change.

Challenges to Transformational Change. The single major challenge in bringing about the desired change is to get the DGCA and BAOA to effectively lead the change! John P. Kotter, the internationally acknowledged change management guru, says that “most major change initiatives generate only lukewarm results and most fail miserably”! He has identified the following eight steps that are critical to transforming organisations:

• Establishing a sense of urgency, examining realities and identifying opportunities. Example: Consider the IS-BAO Standard as an opportunity! The bulk of IS-BAO is SMS.
• Forming a powerful guiding coalition, by assembling a group with enough power to lead the change effort. The group must work together as a tea. Example: Dir Air Safety, DGCA, and President, BAOA could lead their respective organisations to implement SMS!
• Creating a vision to help direct the change effort and develop strategies to achieve the vision. Example: Recognise IS-BAO adoption, as the vision of the Indian regulator and GA/BA industry and set a global benchmark!
• Communicating the vision, using all communicating channels and teach new behaviors by example of the guiding coalition. Example: Collaborative approach as the new norm between the regulator and BAOA (on behalf of the GA/BA industry)!
• Empowering others to act on the vision, by getting rid of obstacles to change, including people and systems that undermine the vision. Example: (i) Change / convert Flight Safety Manual to SMS Manual in keeping with ICAO requirements. (ii) IS-BAO Manual and its SMS protocols to be adopted by both the DGCA and BAOA (on behalf of the GA/BA industry). (iii) Adopt the IBAC Audit protocols to standardize, evaluate and audit all GA/BA operators (fixed- and rotary-wing).
• Planning and creating short-term wins such as performance improvements and recognising employees involved in implementation from both organisations. Example: (i) Establish and concretise the collaborative approach between the DGCA and BAOA. Directer Air Safety and MD BAOA could be the key personnel of respective organisations to ensure success of targets. (ii) Demonstrate the success to ICAO during their visit.
• Consolidating improvements and producing still more change. Use the increased credibility to change systems and policies that don’t fit the vision. Example: (i) Collaborative approach to establish annual audit protocols based on the IS-BAO/USAOP (Universal Safety Audit Oversight Program of the ICAO). (ii) FOIs and Safety Managers could be trained together by a single establishment (for which the BAOA, will have to take the initiative and work with DGCA and operators). (iii) Hire employees who can implement the vision.
• Institutionalise new approaches by developing the means to ensure leadership development and success. Articulate the connection between new behaviours and success. Example: (i) Essential that follow-up leadership development and succession is put in place at the DGCA and BAOA; failure to do so will reinstate old habits. (ii) Relate behavioural changes of positive safety culture with increased feedback on hazards and its mitigation, etc.

CONCLUSION

The implementation of SMS in India is yet to mature. A collaborative approach between the DGCA and GA operators would be necessary to tackle the significant challenges posed by transformational change. The advice of John Kotter on the need for organisations to “Lead the Change” and his advice on the “Eight Steps Critical to Transforming Organisations”, are relevant advice to senior safety managers of the DGCA and BAOA.

The efforts of the BAOA to introduce the ISBAO, as one of the means to implement ICAO mandated SMS is timely. The IS-BAO is well documented and provides GA aircraft operators a meticulous protocol to implement SMS.

The author is a MITRE Licensed SMS Instructor and IS-BAO Auditor, based in Bengaluru. The views expressed are those of the author.