Regular public transport operators are

undergoing a transition to the proposed

CASR Part 119, which will mandate safety
management systems for passenger
transport services using aeroplanes or
rotorcraft, and some categories of cargo
transport. It is envisaged that this will
incorporate therefore not only Australias
current 48 high and low-capacity regular
public transport (RPT) operators, but will
also include some additional 400 charter
operators. Flight Safety editor, Margo
Marchbank, in the first of a series of articles
on SMS implementation, gives an overview.
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I dont believe in safety rst, but safety
always, says CEO of Toll Aviation, Trevor
Jensen. If you say safety rst, then its very
easy to say, OK, weve considered safety,
now we can get on with the job. Whereas,
if safety always is the culture, then you
dont move away from it. Toll Aviation is
one of three pilot organisations working
closely with CASA on the implementation
of safety management systems (SMS) in
the transition to Part 119. SMS have been
on the radar for over ten years, and many
proactive RPT operators, recognising that
they are a critical part of doing business,
already have robust SMS in place. Theyve
been mandatory for certied aerodromes
since January 2007, and aerodromes with
international ights even earlier, since
2005. (Further in this article, there are case
studies of two very different aerodrome
SMS experiences. See page 12.)
NOT SAFETY FIRST,
BUT SAFETY ALWAYS
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Phase 1 Phase 2 Phase 3
Safety Policy, Objectives and Planning
Management commitment & responsibility
Safety accountabilities of managers
Appointment of key safety personnel
SMS implementation plan
Gap analysis
Documentation
Third party interface
Coordination of the emergency response plan
Safety Risk Management
Risk assesment & mitigation process Reactive Proactive/predictive
Hazard identication process Proactive/predictive/hazard
identication
Safety Assurance
Safety performance monitoring & measurement Reactive - incident & accident
vestigation

Internal safety investigation
The management of change
Continuous improvement of the safety system
Safety Training & Promotion
Training & education Key personnel All safety critical personnel All safety critical personnel
Safety communication
SMS IMPLEMENTATION PHASES 2009-2011
There are four major components to the required SMS:
Safety policy, objectives & planning
Safety risk management
Safety assurance, and
Safety training and promotion.
As part of the phased implementation of CASR Part 119, CAO 82.5
(HCRPT) and CAO 82.3 (LCRPT) were mandated in January 2009,
requiring operators to implement an SMS according to a staggered
timeline. These phases are depicted below.
Toll Aviation has a eet of 12 aircraft: two French ATR 42s; 10 Metros (eight
3s and two 23s); and three 737s contracted from Airwork NZ. And, on any
one day, they may also contract up to 50 aircraft. The company employs
115 people: 38 pilots (ten on the ATRs and the rest on the Metros); 42
engineers; 12 ground staff; and the remaining 23 in nance and admin.
Although Toll is not a CAO 82.3 or 82.5 operator, they have chosen to
implement an SMS meeting the standards and timeframes associated
with HCRPT operation. Their Metro operation is based around a number
of bank runs to centres such as Cairns, Townsville, Mt Isa, Moree,
Coolangatta and Mackay. Then there are the freight services one ATR
ies out of Brisbane to Bankstown, Melbourne
and Adelaide, while the other does the reverse
leg Adelaide to Brisbane, at the same time. The
Metros also y the Adelaide to Melbourne route.
Trevor explains that their Monday to Friday
roster appeals to many pilots for whom no
ying on weekends is a lifestyle choice. He
is very much aware of the competition Toll
faces from the major airlines, in attracting and
retaining pilots. The minute the major airlines
want pilots, we lose them, he explains, with
up to a 50 per cent turnover in the good times,
so part of the companys risk assessment is the
pressure this places on maintaining standards.
However, the current economic downturn has
a positive side decreased airline recruitment
has meant less workforce attrition. The
downturn has given us time to put our SMS in
place with a stable workforce, he says.
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The timing is also right for their SMS
for another reason. Toll Aviation arose
from three companies: Jetline, Jetcraft
and Jetcare, which have been aligned
into the one organisation over the
past 12 months. This consolidation
provided a good opportunity, Trevor
Jensen says, to work with CASA
on examining Tolls systems very
closely, as a prelude to establishing
an integrated SMS for the new
entity. An important rst step
was a thorough gap analysis.
Safety doesnt have to cost
money, Trevor explains, so Toll
used Survey Monkey (a simple y
tool for designing surveys
online, with the capacity to
then analyse the data), to
survey their pilots, engineers
and ground staff to see how
we as a group see ourselves.
Im not a salesman for
Survey Monkey, but its a
great tool which costs you
nothing. In a short time
we were able to come up
with results looking at
our compliance. This
analysis was revealing,
Trevor says. If you take
level 10 to be the level
we want to be for ICAO standards (International
Civil Aviation Organization), then for most items
we were hovering around six, but on hazard
identication, it was three out of 10.
He says that by conducting the survey and
analysing its results, they were able to be
more realistic. If we had asked ourselves, for
example, Do we have a hazard identication
system? we probably would have said,
Yes. But now, rather than just ticking the
boxes, digging deeper has identied the
weaknesses, so we know where weve got
to put our effort in. The process took Toll
Aviation three months, but Trevor says, it
gives us a very honest assessment of our
SMS readiness.
Having this data has also helped in convincing
the corporate group of the need to resource
safety management within the company
training, IT systems and so on. You can never
win an argument on emotion, but good data
can help you win.
Trevor and his team have now assessed all
the required elements, and established a
list of the tasks needed to put their SMS in
place, with the tasks allocated in a schedule
for phases 1, 2 and 3 of implementation. As
they write their manual, they can sign off on
each of these tasks. Toll is also part of the pilot
group trialling the new online SMS manual
authoring and assessment tool (MAAT).
When Flight Safety visited the company
headquarters in Brisbane, Trevor was about to
sit down with the CASA SMS project team to
begin populating the manual builder online.
In conclusion, Flight Safety asked him what he
felt were the key points of an SMS. Keep it
simple; safety has to be pragmatic, he replies.
Its not about having big manuals your SMS
documentation should reect how you do
your business. Make sure it reects what you
do. And in training and communicating about
safety, make sure the way you do it suits the
audience. Theres no point in having pages
of instruction, with the intent in the middle
of the document, if the guys dont want to
read nine pages. We have to understand our
audience a lot better, he says.
The
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The whole system is electronically based, and
with hyperlinks to the regulations, there is
always access to the source document (e.g. the
CASA, EPA or WorkCover websites). Clicking
on the link therefore takes you straight to
the most recent version. Every activity they
undertake has a safe work method statement
and risk assessment that identies hazards in
relation, not only to the activity, but the area
of operation, which may vary from day to
day. Were in the early stages of trialling a
new system, using a PDA/Blackberry, so that
you can download documentation when you
come back into the ofce. Or, in the case of
one of our pilots who may be ying outback,
he can obtain remote access to our server
24/7, Geoff explains.
He estimates that the initial certication
process, involving ve months of manpower
and downtime cost EPS about $50,000; with
ongoing audit costs (around $12,000 annually)
and annual registration fees for the three
certications of another $12,000. But Geoff
argues, It wasnt too long ago that the only
EPS HELICOPTER SERVICES
According to principal, Geoff Sprod, EPS helicopters are condent that
whatever SMS standards CASA introduces in the near future for charter
operators, they will be ready. On their website, Bankstown-based EPS
Helicopter Services Pty Ltd state their mission is: to provide a safe,
efcient, cost effective helicopter management service in support of
our clients strategies and objectives. It was this desire to maintain
an ongoing emphasis on safety, and to establish a point of difference
with competitors, which led Geoff and chief pilot, Paul Caristo, to
implement a quality assurance system.
EPS Helicopter Services own two helicopters, a Bell 206BIII Jetranger,
and their latest acquisition, a Eurocopter AS350SD2. They conduct
charter and aerial work activities that include pipeline and power line
surveys, banner towing, sling loads, re ghting and parachuting for
promotional events, to name a few.
In 2007, Paul was about a third of the way into putting the new companys
operations manual together, Geoff explains, when the pair decided,
Lets develop a fully integrated management system that would drive
the business, rather than simply having an SMS. Recognising that the
helicopter world is a highly-competitive market, and that the business
would benet from the security of ongoing contracts, they decided to
embark on securing SAI Global ISO certication. Ask any Joe on the
street, and they know what the symbols mean, Geoff explains, the
ve coloured ticks are the most recognisable QA symbols anywhere.
So EPS opted to undertake not only quality assurance (QA) (ISO 9001),
certication, but also environment (ISO 14001) and OH&S (AS 4801).
Their ve months of developing policies and procedures covering all
aspects of the business, including safe work method statements, risk
registers, risk assessments, staff training and induction, paid off. After
rectifying minor areas during the pre-audit check, they passed their
audit in October 2007, gaining their triple SAI Global certication. This
certication process ensures the system continually evolves with the
business towards best practice, and is reviewed with ongoing audits to
maintain certication.
MORE THAN TICKING THE BOXES
www.epsheli.com.au homepage
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thing that mattered was the hourly rate. Over
the past two years we have seen a change in
tender requirements, and acknowledgement
that tenderers have some form of quality,
OH&S and environmental policies and
procedures in place. And more recently, you
not only have to provide evidence of such
systems, but also any external certication.
Anyone who chooses not to go down this
road soon will be behind the competition.
For EPS the additional certication brought
direct commercial benet: a few months after
certication, EPS secured
a government contract, competing against other major operators.
While price accounted for a percentage, other factors such as quality
and environment were an issue. Their success, Geoff says, could be
attributed to the fact that EPS was the only operator with a certied
system which covered all three aspects, giving them a high score in
that component of the tender.
Over the next couple of years Geoff believes the reliance on providing
evidence of a safety management system will increase signicantly.
Additionally, a far greater emphasis will be placed on a companys
SMS as a measurement of their performance, rather than simply on
their price.
SMS & AERODROMES
Just as the current SMS Phase 1, 2 & 3 requirements
are a transition to CASR Part 119 SMS requirements
for Australian aerodrome operators followed a similar
transition. CASR Part 139 (safety standards for
Australian aerodromes) came into effect in May 2003,
with a 1 November 2005 deadline for aerodromes
with international operators; and 1 January 2007
deadline for all other certied aerodromes. Keith
Tonkin, of Aviation Projects, outlines case studies of
two very different aerodromes which implemented
new SMS.
NORTHERN PENINSULA
AIRPORT (YNPE)
BACKGROUND
Northern Peninsula Airport (NPA, formerly Bamaga/
Injinoo Airport) is located on the northern tip of Cape
York Peninsula in far North Queensland. Like many
remote communities, the ve Aboriginal and Islander
communities of the Northern Peninsula area rely
heavily on air transport for access to medical and other
essential support services. The airport is therefore a
critical element of community infrastructure.
To provide for an expected increase in operator
capability, the airport was prepared for certication
in late 2007, and received its aerodrome certicate
early in 2008. A critical condition of certication was
assurance by the Northern Peninsula Area Regional
Council, which managed the airport, that they would
provide adequate resources and funding so that the
aerodrome would meet regulatory requirements.
Not only did the SMS satisfy one of the requirements
for certication, but importantly, it was a way of
being proactive by identifying existing and potential
issues and the resources and management actions to
address them.
SMS DEVELOPMENT
The airport management had limited knowledge of
how to develop and implement an SMS. So after rst
looking at the principles and methodology of an SMS
in the CASA-developed SMS template, they participated
in a workshop to identify risks to the safe operation of
the airport. These risks and their associated treatments
were documented in a risk register and treatment plan,
in MS Excel format. By using Excel, which is readily
available, local airport management staff could view,
manage and manipulate the register document easily.
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Some of the issues identied in the development of the
SMS, and actions taken to rectify them are as follows:
1. Emergency callout Limitations because of xed-
line and mobile phones meant that the airport
manager (who also does the refuelling) was not
always contactable for callout by emergency
services such as the Royal Flying Doctor Service
(RFDS). A satellite phone was therefore provided
to the airport manager.
2. Frequency conrmation Although a Unicom
service was available, limitations associated with
staff availability and radio equipment, as well
as signicant frequency congestion on the large
CTAF(R) shared with nearby Horn Island Airport
and other airports in the Torres Strait, led to the
decision to establish Northern Peninsula Airport
as a separate CTAF(R) and to install a combined
AFRU/PAALC. This process will be concluded with
the August 2009 amendment of ERSA.
AD-HOC OR UNFORESEEN RISKS
As with any aviation activity, despite the intention
to proactively manage safety risks, unforeseen risks
requiring reactive management action occur from
time to time. Some incidents which occurred at NPA,
and how these were managed to minimise future
risks are as follows:
1. Near miss A light aircraft landed short
of the runway while conducting a circuit to
land, due to failure of the throttle cable. The
subsequent emergency response revealed
some opportunities for improvement in relation
to call out procedures, telecommunications
systems and response vehicle capabilities. The
airport manager reported these issues, which
were discussed with airport management
and other stakeholders for consideration and
implementation. Results were recorded in the
risk register and treatment plan.
2. Pavement failure ground water inltration of the
runway pavement required urgent repairs to be
carried out at short notice. This required closure
of the airport for a number of days on several
occasions, with implications to RPT operators,
emergency services etc. A full engineering design
of pavement repairs & additional drainage was
commissioned immediately. The pavement repairs
were carried out in accordance with the engineering
designs provided. The results of these activities were
recorded in the risk register and treatment plan.
Further drainage & runway pavement upgrades are
scheduled when funds are available.
STAKEHOLDER CONSULTATION
All of the above issues required engagement with
stakeholders to ensure that they understood and
accepted the risk treatments being implemented,
and that an acceptable level of safety would be
maintained. These stakeholders included aircraft
operators and agents, council staff, local community
members, regulatory authorities, suppliers and
customers.
Sometimes change can bring about unintended
consequences, so during the development of
risk treatments, stakeholders were asked for
their input regarding potential impacts to their
activities, including operational implications,
amended procedures, most appropriate means of
communication etc.
Stakeholders received information concerning the
treatment actions which had been determined,
through email broadcasts to user groups, newspaper
articles, telephone, fax, industry publications and
newsletters, NOTAMs as well as AIP/ERSA and other
information sources.
SMS ONGOING MANAGEMENT
Airport management accepts that risks need to be
managed proactively. They organise meetings of
the SMS safety committee every six months or so to
review the SMS and the risk register and treatment
plan, so that planned actions to treat known risks
happen; potential risks are identied and actions put
in place to treat them.
The meeting also tables and considers reports and
information from the previous period relevant to the
SMS, such as ad-hoc reports or other information;
and safety/technical inspection reports.
. . . it was a way of being proactive by identifying
existing and potential issues and the resources
and management actions to address them.
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SAFETY CULTURE
Increased regulatory obligations as a certied
airport under CASR 139, as well as status as a
security-controlled airport under transport security
regulations meant the community had to reconsider
its approach to the airport. Improved maintenance
of infrastructure and services, restrictions to access,
more rigorous operational procedures and increased
management involvement also required a prioritisation
of funding and human resources, so the airport
management met its regulatory requirements.
SUNSHINE COAST AIRPORT
(YBMC)
BACKGROUND
Sunshine Coast Airport (SCA), owned and operated
by Sunshine Coast Regional Council, is Australias
twelfth-largest airport by passenger numbers. It
supports jet RPT services operated by Jetstar, Tiger
and Virgin Blue; numerous xed and rotary wing
training organisations, including Singapore Flying
College; as well as aircraft maintenance and support
operations. It is a security-controlled airport with
screening requirements.
Sunshine Coast Airport is better resourced than
Northern Peninsula Airport, but has its own unique
issues because of its much greater scope and scale
of operations, and its correspondingly more
complex compliance and reporting requirements.
It is also approaching limitations in operational
capacity brought about by an unanticipated increase
in passenger numbers and the type of operations
conducted at the airport.
INTEGRATION WITH OTHER RISK-
BASED MANAGEMENT PROGRAMS
Because of the increased scope, scale and complexity
of activities it conducts and supports, Sunshine Coast
Airport manages a number of risk-based compliance
programs in addition to the SMS. These include
an environment management plan, a security risk
management plan (part of the Transport Security
Program), a workplace health and safety program
and an asset management program.
As well as these statutory requirements, all signicant
projects undertaken at the airport involve a proactive
formal risk management component.
Sunshine Coast Regional Council also requires all
signicant risks (including business continuity, nancial
and legal liability issues) to be managed as an outcome
of the airports annual performance plan.
Managing these separate programs creates a
signicant issue. They do not all have the same risk
criterialikelihood and consequence descriptors, risk
matrix, management and reporting actions required,
level of acceptable risk etc. This disparity makes
allocating resources effectively
Photo: courtesy Sunshine Coast Airport
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more difcult, and degrades the value of risk
information communicated to some stakeholders.
Working with the Australian Airports Association,
CASA developed an electronic SMS builder to
provide airports a simple means of compliance, and
a consistent basis for assessment by aerodrome
inspectors. Unfortunately the risk criteria, such as
likelihood, consequence, level of risk etc did not
align with the councils risk policy. Using the CASA
methodology, an extreme consequence (multiple
fatalities) with a rare likelihood, managed with
treatments that had limited effect resulted in a
low risk, whereas using the councils framework,
a similar scenario resulted in a high level of risk.
(That electronic SMS builder is no longer available.
See MAAT below.)
Councils risk management database also did not
cater for aviation operational safety risk. For the
airport, this was measured nancially as a cost/
revenue consequence, in safety outcomes and also
in terms of interruption to operations. So, in the
interests of simplifying compliance and program
management, the SMS is a standalone program using
CASAs template until all risk-based management
programs can be coherently incorporated into the
council system.
Risk criteria and risk assessment have to be uniform,
so that across council, various departments and
business units can communicate levels of risk
effectively.
Work is currently underway to integrate these risk
management programs, with a single database for
recording the risk register and treatment plan, so that
all risks managed by the airport can be identied,
assessed, treated, monitored and reviewed within a
single management program, using the same criteria.
This integration will make identifying, reporting and
managing risks more efcient, improve decision
making and resource allocation, and reduce training
requirements for system users.
TRAINING
There is a signicant number of staff and contractors
who conduct operations at the airport, which
has necessitated a more formalised training and
induction program as part of the SMS.
Contractors undertake a formal induction prior to
conducting works on the airport, and are subject to
ongoing scrutiny for compliance.
In their induction, new staff members receive SMS
and associated safety management procedure
training. Safety management issues are discussed at
monthly staff meetings.
Airside staff such as safety/reporting/security ofcers
and operational management staff also undertake
further training in safety procedures documented
in the aerodrome manual and standard operating
procedures manual.
For more information
Safety Management Manual
ICAO (2006). Doc.9859-AN/460 Second edition, downloadable from
www.icao.int
Also SMS training material available from the ICAO website.
Safety management systems for regular public transport operations. CAAP SMS-1(0) Civil Aviation Advisory Publication, January 2009
Integration of human factors into safety management systems CAAP SMS-2(0) Civil Aviation Advisory Publication, January 2009
Human factors & non-technical skills training for regular public transport operations CAAP SMS-3(0) Civil Aviation Advisory Publication, January 2009
Safety management making it t Feature article Flight Safety Australia March-April 2002
Manual authoring and assessment tool (MAAT) Online tool email sms@casa.gov.au for more information
www.surveymonkey.com
Online tool designed to enable anyone to create online surveys quickly and
easily. Free (for up to 100 responses stored).
www.saiglobal.com
International quality certication body, which licenses accredited
organisations with the internationally-recognised tick across ve main
areas: quality, OH&S, environment, information security and food safety.