End to End Implementation (IP)

The FAA estimated the time it takes to implement the SMS a long time ago when performed in-house without experience. That number was calculated by project managers (PM) who divided the SMS into components and elements using standard PM tools. That number was 1340 hours to get the SMS to the starting line, the line where you can start to actually use the SMS. The starting line represents the place where you've been trained, have developed your manuals, have established a reporting protocol and filled the key safety management positions. You have built your hazard registry, identified what constitutes a hazard for your operation and have required full participation from line personnel. You have selected key performance indicators to track and determined what types of data to collect. Executive management, middle management and line personnel have bought in to the premise that SMS is a tool that can assist the operation manage risks. A tool that must be properly designed and used correctly for it to be useful. That's my job.

So it is, after 20 years of working with operators of all shapes and sizes, I've learned a few things that should make your journey down the SMS rabbit hole much less painful and costly. I can deliver exactly what you need to get your stamp of "acceptance" from the FAA, but much more important than that, I can show you how to use it so that it does what it's supposed to do: Improve your hazard awareness, assist you manage risks levels to an acceptable and reasonable level, help you build a cohesive team of like minded people who believe striving for continuous improvement is a worthwhile endeavor. That is well worth the effort despite the fact that nothing is perfect and that humans are prone to make mistakes and errors on a routine basis. Do yourself a favor and start at the beginning of your journey by exploring your culture. Learn everything you can about it so that you can see where the issues are, before you tackle SMS. You'll need to dissect your operation to make sure you have the requisite Safety Culture, (Informed, Just, learning, reporting, flexible) you will want to tackle that first. Inserting an SMS into a dysfunctional operation is like putting lipstick on a pig and hoping that might help. It won't.

As you can see, a complex project requires a detailed plan that ensures everything gets done on time and on budget.  The first thing to plan for is,  things never go to plan, so its important you build in some flexibility and reality into your implementation plan. Having done hundreds of detailed implementation plans, they really are an essential tool to use when it comes to adopting SMS, but the simpler they are the better. Complexity truly is SMS's number one enemy. We learned during the airport pilot project that some operators were literally paying hundreds of thousands of dollars for something that could have been completed at a fraction of the cost if they only would have had experience and a detailed map to follow. 

The well developed SMS Implementation plan includes everything you see below, which explains why a full End to End implementation can take three years and hundreds of thousands of dollars if you've never done one before. Experience matters here, because once you've done a few, you will start to see where you can save time by simplifying the entire process. In terms of delivering a conforming SMS framework that the FAA will accept, it can take 1340 hours or it can take 160 hours, entirely dependent on who does it. Building the SMS framework, sometimes referred to as the standard, though it's not technically a standard, is the easy part. 

1. Project Charter-Formally defines purpose, objectives, scope, authority and objective: Part 5-conforming operational SMS.
2. Scope Statement-Defines what's included—and excluded, manuals, training, SRM, assurance, promotion, DoC support.
3. Work Breakdown Structure (WBS)-Breaks the project into manageable tasks and divides SMS into components, elements and implementation tasks.
4. Gantt Chart-Shows tasks, durations, dependencies and milestones over time.
5. Project Schedule-Establishes dates and sequencing, kickoff → gap analysis → development → training → implementation.
6. Milestone Chart-Highlights major completion points, manual approved, training complete, SMS operational.
7. Critical Path Analysis-Identifies tasks that control the project's completion date and shows what must be completed before training or implementation.
8. RACI Matrix-Defines Responsible, Accountable, Consulted and Informed and designates AE, Safety Manager, department managers.
9. Stakeholder Analysis-Identifies affected parties and their needs, (AE, DOM, DO, Chief Pilot, Employees, FAA).
10. Communication Plan-Establishes who communicates what, when and how, weekly implementation meetings and status reports.
11. Risk Register-Identifies project risks and mitigations, training delays, unavailable personnel, document approval delays.
12. Issue LogTracks problems requiring resolution, missing procedures, organizational gaps, unresolved responsibilities.
13. Action Item Log-Tracks assignments and due dates, client provides organization chart.
14. Decision Log-Records significant project decisions, reporting system selected, Safety Manager role established.
15. Change Control / Change Log-Controls changes to project scope.
16. Resource Plan-Identifies people, time and other resources required, management interviews, employee training time, onsite days.
17. Budget / Cost Tracker-Tracks planned versus actual costs- travel, consulting hours, training, software.
18. Requirements Traceability Matrix-Connects requirements to deliverables/evidence.
19. Gap Analysis-Compares current state against required state, existing operation vs. Part 5/AC 120-92D.
20. Deliverables Register-Lists everything the project must produce SMS manual, ERP, forms, training, risk tools, records.
21. KPI / Performance Dashboard-Shows project status and performance, % complete, overdue actions, training completion.
22. Lessons-Learned Log-Captures what worked and what didn't, used at project closeout and future SMS improvement
23. Project Closeout Report-Documents completion and handoff, confirms implementation and transfers SMS to client.

That is what I call a robust implementation plan and to be frank, it's too much. My last airport IP was 96 pages long. The local FAA inspector read it and was impressed, but asked for a simpler version. I concurred and it was accepted on the spot. Instead of a 95 page IP, I now do a 25 page IP that evidently is what they wanted all along.

Whether you are required to adopt SMS by regulation or peer pressure or business competition, you will want to get as much benefit from it as you can. Whether you spend $6,000 or $250,000 you want your money's worth. I can deliver a conforming SMS fully implemented into your operation that gets you to the starting line in about 30 days. That's not a high functioning, fully mature SMS, that's an FAA "accepted" SMS that got you to the starting line. And, as part of my service, I provide you with 12-months of  my Collaborative Management Program (CMP) that holds your hand and is the equivalent of hiring a full time safety officer. After that first year, you will have a three-ringed binder full of data, reports, investigations, that anybody would  conclude from, you have an active SMS and are working towards continuous improvement. 

The CMP is a support tool, it assist you manage your SMS, but it still requires your participation and input. So, after your first year you may very well decide I don't need John holding my hand anymore and tackle SMS on your own. That's our goal after all. Unfortunately, on the flight side of things (91, 135) operators are staffed to the bone and many of my implementation clients decide they want to stay in the CMP longer. That's entirely OK with me, I love what I do, but because that support program is fairly labor intensive, I need to charge for it should you want to continue.