Introduction – the drivers for a total system approach
The aviation sector comprises a great many organisations and individuals, all providing a range of different but highly interdependent services. Aviation system 'components', in terms of activities and categories of service providers, are part of this complex socio-technical system. Given that an acceptable level of safety is a key desired outcome from this complex system, all regulated providers of aviation services or products (hereafter referred to as 'service providers') should ideally implement compatible safety management processes. This facilitates effective interoperability between individual SMS which in turn reduces the risk of safety gaps or overlaps, and clarifies responsibilities regarding hazard identification and risk management. It is also a proven and effective way to detect potential hazards and mitigate their consequences at all levels of the aviation system and at the earliest possible opportunity. In addition, it ensures that all actors "speak the same language" when it comes to safety and safety management, thus supporting the effective and efficient delivery of acceptable levels of overall safety performance. Read more
From an overall safety system perspective, the service providers in the aviation sector at the 'higher consequence' level in terms of risk exposure should be encouraged and supported to adopt a total system approach, and to link their safety management systems. Service providers whose activities are exposed to this higher level of risk include those who undertake tasks such as:
- Initial design of aircraft, engines, propellers, and aircraft components, software, and changes thereto
- Production of aircraft engines, propellers, and aircraft components
- Operation of aircraft
- Aircraft continuing airworthiness management and maintenance
- Airspace and air traffic management and operation of associated systems
- Operation and maintenance of air navigation facilities (including approach facilities)
- Operation and maintenance of aerodromes
- Fitness and competence of aviation personnel (flight crew, cabin crew, maintenance engineers, etc…)
Many interfaces and interdependencies exist among these activities/categories of service providers, some being more tightly coupled/connected than others. It is not always apparent where some of these interfaces exist, or where recognising and making these connections will deliver benefits in terms of both safety performance and business efficiency.
The degree of interaction influences the extent of integration required in terms of information flows, management structures and interfaces. It will also help to assure that the appropriate level of oversight by the regulatory authority is implemented where SMS is a requirement. There are benefits to be gained here too in that the level of oversight can be minimised where the inter-active SMSs are shown to be working effectively to deliver good safety performance.
Among these aviation system 'components' there is a wide range of diverse aviation activities such as commercial air carrier operations and general aviation, as well as different sizes of the organizations and other entities that operate in the system. Each of these have their own specific risk profile. These factors, too, need to be considered when developing, implementing and operating an effective SMS and identifying where links ought to be established within the total system.
There are a number of institutional, cultural, regulatory and practical aspects that require due consideration with regard to systems safety (total system approach). For example:
- What are the sub-systems that need to be considered within the total system (how far to reach out from the front-line or 'higher consequence' level)?
- How relevant and important is each of these sub-systems to the safety of the total system performance? (e.g. How critical is the sub-system? Who has responsibility for the performance of the sub-system? What is the direct contribution that a failure within a sub-system may have to the risk of an aircraft incident or accident?)
- How to best manage the dynamics of the overall system?
- Is the service provider of a sub-system in a position to understand their contribution to the safe operation of aircraft? Has the aircraft operator retained appropriate safety accountability and responsibility?
Examples of issues that need to be considered, and where a total system approach should be implemented include:
- The fact that as the design, manufacture, operation and maintenance of aircraft have matured and contribute less now to the accident rate than in the early development of commercial aviation, we have seen human performance become a more dominant contributory factor to safety performance.
- A provider of MET services will provide a forecast with a defined level of uncertainty, but is unlikely to be aware of the SMS requirements relevant to the use of this forecast, (Ref: ICAO Annex 19 Appendix 2 SMS framework).
- The need to recognise the full impact of the introduction of new technologies on modern operations, including the implications for training.
- The move towards competence based training, which requires the acquisition and assessment of a wider range of safety data to assure the training is relevant and effective.
One of the biggest drivers for a Total System Approach is the introduction of the Single European Sky (SES). Here almost more than anywhere else there will be a need for the areas of airworthiness, OPS, FCL, ATM and airports to work in complete harmony in order to ensure the effective and safe deployment of SES. This is a particularly challenging task as a number of regulatory changes have to be scheduled, developed and become applicable by 2018. The implementation within Europe of the SES involves a wide range of diverse organisations, as well as the wider introduction of new operating processes, such as collaborative decision making.
Until recently requirements, whether ICAO SARPs, or National regulations, have usually been developed entirely within domains. This could lead to contradicting views or approaches on issues closely related to, or having the potential to affect each other. The drafting of new or changed requirements now needs to be undertaken by experts in a specific domain who are provided with the support necessary to ensure they have an understanding of the impact ‘their regulations’ could have on adjacent domains. This will require all staff, whether they are developing the rules, or are involved in an implementing role, to adopt a different approach to their work and take a more holistic view of their working environment. Read more
Aviation continues to develop fast and changes are becoming more and more integrated across the domains. This therefore requires a more pro-active, cross-domain approach both in the development and operation of SMS, and in the preparation of new or amended regulations. There is a need for an integrated set of aviation technical/safety regulations that will be maintained for all aviation domains through a holistic approach.
The Total System Approach requires all aviation safety and technical regulations to be described in a coherent regulatory framework, preferably under one legal umbrella. Regulations can no longer be developed in isolation of each other because of the increasing interdependency between the different domains. For example changes to airspace design to enhance capacity, efficiency or environmental performance must take into account the regulations/procedures of the ATM, airworthiness (requirements for equipment), operations (what equipment is required or currently operated on board), training of staff (pilots and ATCOs) and the systems on the ground (airport and ATM systems) to ensure that overall safety performance is not compromised.
The development and introduction of a State Safety Plan provides a framework for an integrated total system approach and helps to facilitate the right conversations between the players in different domains.
In the European Union (EU), EASA and the European Commission (EC) having established the basic rules in the different domains, have more recently worked to harmonise the approach for the different domains via the "Authority" and "Organisation" requirements. This is possible because the legal basis for the different rules for each of the main domains is now common and the EASA regulations for safety management and the safety management systems have been formulated in line with the new ICAO Annex 19.
Support in the implementation of a Total System Approach
The implementation of a total system approach is best driven from the highest level. ICAO has facilitated this with its requirements for a State Safety Plan (SSP). The development and implementation of the SSP will lead to a state safety programme which will necessarily cover all of the aviation domains and drive discussion between them, identifying interdependencies and common factors. Read more
The implementation of a total system approach is best driven from the highest level. ICAO has facilitated this with its requirements for a State Safety Plan (SSP). The development and implementation of the SSP will lead to a state safety programme which will necessarily cover all of the aviation domains and drive discussion between them, identifying interdependencies and common factors.
The SSP will be implemented through the mechanism of the National (or European for EU member states) legal framework, and while Governments will be accountable, responsibility for oversight of its implementation and the achievement of its objectives on a working level will be discharged by the relevant National Authority.
A key factor in the move towards an effective total system approach will be the way in which future rule making tasks are managed. It will be important that:
- The introduction of all new regulations includes support to the stakeholders in the various domains because, for them, the new approach also requires a different way of managing and developing their systems and working processes, and indeed may require new working partnerships to be established.
- In order to stay in line with further EU and ICAO developments, stakeholders are engaged with rule making processes at an early stage of development. The earlier in the process this involvement takes place, the easier the implementation of new rules will be.
- Staff training and development is undertaken to establish and maintain an adequate, up-to-date level of expertise. This is also needed to enable the correct implementation of the ICAO Global Aviation Safety Plan.
- Experts are trained in the correct legalistic drafting of regulations (the "hard law" which has to be implemented) or in developing AMCs or GM which, whilst not mandatory (soft law), are a method by which one is expected to comply with the regulations. Whilst therefore these personnel are experts in their own field, they will need to be given support to ensure they have sufficient understanding and recognition both of the legal criteria to be observed in writing regulations, and of the need to consider the potential impact of their work on other domains and to liaise with experts from those domains accordingly.
Given the large number of changes taking place in the aviation industry, whether in terms of new technologies, new systems, new training methodologies, or new regulatory regimes, it is clear that the "Total System" approach will be fundamental to ensuring that safety performance continues to improve.