Safety Management

Setting the Standard

This is me coming up for breath. I've been in the deep-end of airport operations for the last 10 months or so and I'm only just getting my head above water. I think (or at least hope) I've achieved a lot over the last couple of months but very little has been blog-worthy. However, over the last week or so, I've been swimming in that lovely little pool called Wildlife Hazard Management. And while I was re-writing my airport's Wildlife Hazard Management Plan, I stumbled across something I thought worthy of a share.

A long time ago, I wrote about integrating wildlife management and safety management with (as always) a focus on risk management. Well, I want to take this a little further.

The Wild Side of Risk Assessment

The crux of my previous post was that the risk assessment of wildlife sits within the risk assessment of safety and that they may use different techniques. The SMS-level might use a standard risk matrix (or not) and the wildlife risk assessment might use a different technique such as the Paton bird risk assessment model.

The Risk Management Process

The two techniques are really just tools within the fairly standard risk management process. As the global standard puts it:

RMProcess

I think that some of this stuff most of us do well but there is a step we've been missing. It's that dark green one - evaluation.

In Practice

Here is how I see most risk assessment processes going:

  1. We identify the risks - in this particular case bird species at or likely to be at the aerodrome
  2. We calculate a consequence and likelihood score for each species
  3. We assign each species to a risk category according to the model used
  4. We treat the risk - we think of stuff to do to address the identified risks

And all that sounds great but there is, to me, something missing. We might very well devise risk treatments that are sound and effective. We might even target those species that appear high up the list (let's call that, risk ranking, which doesn't appear in the standard). But how have we actually decided to do those things?

In Theory

Well, good ol' ISO 31000 defines risk evaluation as:

(The) process of comparing the results of risk analysis with risk criteria to determine whether the risk and/or its magnitude is acceptable or tolerable

and notes that:

(It) assists in the decision about risk treatment

So what are risk criteria? Again, ISO 31000 says that risk criteria are:

terms of reference against which the significance of a risk is evaluated

Damn it ISO, buddy, you went a bit circular there. So what do I think the risk criteria are?

I look to the note above, they guide you in the decision making process. You set up parameters, before hand, that tell you what to do with risk assessed at the various levels you've set.

Here's an Example

I've just put together the risk assessment framework I intend to use at my airport. I'm basing it on Paton but extending it to land animals as well. I describe the calculation of consequence and likelihood and then outline (via a matrix :( ) the calculation of the final risk level.

And then...

I define what must be done for each risk category/level.

Even before I've looked out the door to see what birds I have at the airport. These requirements are now set in stone. It holds me to a standard and allows for variations in the real-world context, which will occur, to be managed in a consistent and almost predictable way.

This standard allows my bosses, my airlines and my team to know what is expected if we encounter a situation where a species is assessed as "extreme" or "very high" or "negligible".

And for me, those standards are:

Wildlife Evaluation Criteria

Applying the Standard

Now, I go and look out the door. I, with the help of a qualified ornithologist or biologist, look at the environmental, operational and historical contexts and come up with a list of species. We score them and categorises them and then we have to do what the above table say we are going to do.

Any species assessed as "extreme" get their own plan (luckily none of them for me at this stage). Those at "very high" get general strategies that target them (for example, I will be implementing a short-grass policy to reduce my kite numbers) and so on.

As things change, I can also change my strategies with confidence as I have a standard to hold on to should I wish to drop strategies or introduce strategies.

And I think this is a good thing. Yes, you might get pinned in a corner and have to act in some cases but that is the point. You will be held accountable anyway and not setting a standard will not protect you if it all goes pear shaped - touch wood.

Wildlife Management & SMS Integration

I may have suggested a couple of weeks ago that I was not going to carry on with material from my Indonesia trip in June but I really wanted to share this fictional case study with you. In order to highlight the interaction between strategic level SMS risk management and the more operational level risk management found in wildlife management plans, I developed the case study below. Its not really based on anything I've seen in action but more based on how I would approach the problem if anyone put me in charge. Background

Some sources put the cost of bird-strikes at $1.2 billion dollars per year. This makes wildlife hazard management a very important task for modern airport operators. It is however, a very big issue to tackle with a great deal of variety in operating environments, wildlife species, aircraft types and resources available.

This means that a single solution or prescriptive standard can not solve this problem. Instead, we turn to risk management as a way of reducing the chance and severity of wildlife related incidents to an acceptable level. PKPS 139 requires all airport operators assess the risk relating to bird and animal hazards and to implement controls to manage the risk. Even before any formal risk management process starts every operator already has people observing the wildlife on the aerodrome and reporting strike in accordance with the regulations. In SMS terms, major wildlife hazard management activities are usually initiated by safety assurance activities such as internal audits and investigations.

Strategic SMS Risk Register before Review

Beginning at the Top

In this scenario, an internal safety audit has identified a general increase in the numbers of birds on the aerodrome, plans for a garbage dump nearby and a couple of costly bird-strikes as concerns requiring formal risk assessment. The Safety Manager presented the audit’s report to the CEO and the CEO tabled the report at the next Safety Committee meeting.

The Safety Committee initiated the risk management process at the strategic level by reviewing its previous wildlife hazard risk assessments found in its risk register. The review found that a formal hazard management plan (operational risk management) was required.

Strategic SMS Risk Register after Review

As per the review, the Safety Manager engaged a qualified ornithologist with airport experience to develop a comprehensive management plan. This plan began with a full assessment of the wildlife on and in the vicinity of the airport and the environment on and off the airport. This assessment resulted in the identification of more specific hazards including each animal species – see below for an example of this type of risk assessment based on the model published by the Australian Aviation Wildlife Hazard Group. This assessment allows for the planning of allocation of resources to the most critical areas – for example, the grassed and wetland areas are more important than treed areas and ibis and galahs require more attention than quail, tern and swallow.

Species Specific Risk Register

From this point, the consultant works with the airport operator to identify potential risk treatments. These treatments cover a range of strategies including habitat control, feed control, harassment and reporting.

  • Habitat control – this strategy is targeted at the higher risk areas and species and includes longer grass in areas, filling in a number of ponds and the netting of potential nest sites.
  • Feed control – this includes efforts to minimise food sources such as removal of fruit trees, enclosed garbage areas, a mowing schedule to reduce grass seeding and a safety promotion campaign advising all airport users of the need to pick up rubbish.
  • Harassment – these efforts include a range of acoustic and visual harassment devises for airport reporting officers and a semi-irregular harassment schedule.
  • Reporting – two new reporting systems were proposed. The first consists of an external reporting system whereby significant wildlife hazards are reported directly to the aerodrome users’ safety/operations departments. These reports follow a standard format issued through the airside operations manager. The second system involves internal reporting of wildlife hazards according to specific risk-based triggers devised by the consultant. If during an inspection, the airport reporting officer notices a specific hazard in excess of these triggers, he/she submits a report to the Safety Manager. The regulatory requirement to report all strikes to the authorities continues to exist.

Monitoring consists of regular animal-counts typically carried out following the morning airport inspection. Tactical risk assessment consists of comparing this count results against the reporting triggers developed by the consultant (see above). Results below these thresholds are filed for future review.

These results plus records of wildlife strikes and any other report are reviewed annually along with the entire management plan. Deficiencies are identified and the plan amended as required. The results of these reviews are submitted to the Safety Committee by the Safety Manager.

More Information

There is plenty of information on the Internet on this issue. Here are a couple of links:

Good Management Practice

I was skulking around on the web the other day and I came across this blog post* featuring a Q&A with Rehbein AOS's Ben Hargreaves. While the post isn't talking airport safety, it does go into the role of airports in the regional/remote environment and it does mention a couple of good management practices. I like the discussion on the role of the airport in a regional community. Ben says that:

"(f)rom what I’ve seen, the most successful operators are those that understand the need for a bit of ‘joined-up’ thinking about how the airport fits socio-economically into the region."

This is very much pointed at the money side of the equation but has a very real impact on the resourcing of the aerodrome. And by resourcing, I not only mean people and equipment but also training and expert assistance. If resources are allocated on a revenue basis - i.e. only what the airport's own income can support - then more often than not, its not enough. Even the smallest aerodrome requires a certain level of attention by suitably training personnel with an appropriate level of equipment. Now, I can't say what that minimum level is but I will say that at many aerodromes I've visited, it has not been at the required level. I agree with the implication that those operators who see their airport as part of the bigger social and economic picture, will set more realistic goals and develop more suitable plans.

Further along, Ben mentions stakeholder communication. This is a fundamental aspect of an airport's safety management system. Most documented safety management systems I've come across stipulate the convening of a safety committee. Yet, very few have used these forums to develop strong channels for funnelling safety related information. Again, while Ben is talking more about economics and development, the quote below is equally pertinent to safety.

"In terms of techniques, there isn’t necessarily any right or wrong way of going about this. It really depends on knowing who your stakeholders are and the message you want to communicated (and always remember communication goes in both directions) as to how best to achieve it."

Its no surprise to me to see good advice coming from non-safety discussion. After all, a safety management system is mostly about systemic management - it just happens to be directed at safety. Nothing in safety management is unique to the concept of safety. Organisations have long been using policy, accountability, risk management, assurance and training to achieve all manner of organisations goals such as quality, production, financial control and public relations.

Recently, I've been supportive of airport operators seeking to leverage existing management systems to meet their airport safety obligations - as long as they keep the focus on aviation safety.

* I most definitely realise that Ben's blog post is advertising for some speaking engagement of his. I'm not endorsing or advertising that engagement, I just wanted to share his words with a bit of commentary of my own.

Aerodrome Reporting - in a Flowchart

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Aerodrome Reporting Flowchart - Landscape - v0.2 I like to sit at my computer and draw things, despite the fact that I'm no artist. A couple of weeks ago, I thought I would have a go at putting the various aerodrome reporting requirements, the procedures you might find in that section of the aerodrome manual, into a flowchart to help out anyone who is a bit confused by the various requirements.

It's not easy to get your head around the multitude of requirements especially when a small sentence in some other chapter of the Manual of Standards Part 139 might trigger a whole set of other requirements. To help keep the situation clear, I also added in the Transport Safety Investigation Act requirements, well some of them anyway.

So, I hope this flowchart helps - if not, let me know in the comments below.

Update - with the kind help of fellow Aerodrome Inspectors Darren Angelo and Danny Eatock, I've made a few changes to the flowchart. I hope they may it clearer. Let me know.

Indonesia, here I come...

I'm off to Jakarta next week to present a workshop on SMS to the Indonesian DGCA's SAG members from their Directorates of Airports and Air Navigation. It'll be my second trip to Jakarta and I'm really looking forward working with the Indonesians again - they are a great bunch of people, very friendly and polite. Anyway, I thought I would share the slides I'll be presenting - just for general interest's sake. I've had a go at translating most of the headings into Bahasa Indonesia using translated versions of their regulations and Google translate. I hope there are no major errors!

Some of the slides haven't converted as they will be shown on the big screen but I'm sure you get the gist.

Update - things rarely go to plan in Indonesia. In this instance, time was short and the direction of the workshop changed to focus on acceptable levels of safety and risk management. I also changed practical exercise around considerably as you can see in my post about it.