Manuals - A Critical SMS Element
One of the major tenants of your SMS is the Safety Policy. Your employees need to know how to accomplish their assigned tasks in a safe manner and your policies provide this information for them. The information is normally contained in your company manuals. Some examples might be your SMS manual, your General Operations manual, your Emergency Response manual, etc.…
There is an old saying I have heard from the FAA Inspectors over and over in my career and that is to, “Say what you will do and DO what you say!” The average person cannot memorize all the steps of each task required of them, so management provides manuals for them to consult. 14 CFR 135.21 covers manual requirements. It states in part that “Each certificate holder, other than one who uses only one pilot in the certificate holder's operations, shall prepare and keep current a manual setting forth the certificate holder's procedures and policies acceptable to the Administrator. This manual must be used by the certificate holder's flight, ground, and maintenance personnel in conducting its operations.”
You are probably saying to yourself - we already know this, so why write about it? Well, I can give you example after example of safety issues that I investigated that would never had been an issue IF the person(s) involved read and followed the policy and the procedures associated with them in their manuals.
Take for example, a safety report I investigated where an aircraft’s wing was damaged when towing it to a parking spot. During my investigation, I determined that there was no need to update the policy and procedure regarding our towing procedures, they were very well documented. I concluded that had the individual involved followed the procedures step by step, the aircraft would have been towed and parked without incident.
This leads to a critical part regarding your company manuals - Each person must take responsibility for knowing which manuals they need to use when performing their tasks. Additionally, they must know the contents of those manuals. While you are not expected to memorize each word, you do need to know where to turn when you have questions about a policy or how to complete a procedure.
Your company also has the responsibility to maintain each manual with the most up to date policies and procedures. This is accomplished through the Safety Risk Management aspect of your SMS. Anytime a triggering event occurs within your operation, your SMS requires you to evaluate the change for any hazards. 14 CFR Part 5.51 tells us what those triggering events are. It states that a certificate holder must apply safety risk management to the following:
Implementation of new systems.
Revision of existing systems.
Development of operational procedures.
Identification of hazards or ineffective risk controls through the safety assurance processes in subpart D of this part.
There is typically someone within the company assigned the task to keep each manual up to date. In larger operations, there might even be a Technical Publications Department that handles the entire manual system. I consider the person or department responsible for the upkeep of manuals as one of the most critical parts of an operation.
The biggest problem I have experienced in my career within an operation is controlling the changes and updates to a manual. It is critical that all updates to your manual system are handled by one individual or department. You should never allow changes to be made to the “source document” by anyone other than the person or department directly responsible for the maintenance of that manual. This avoids confusion within the manual and ensures all updates have been properly vetted and approved before being published.
In this day and time, there should never be a time when an employee says they did not know how to perform a task or where they need to look to remind themselves the procedures to do the task. Initial and recurrent training should always include a section on the manuals associated with the tasks that are assigned an employee. The manuals should be easily accessible by those needing to consult them. Digital manuals allow an employee to have almost constant access to their policies and procedures. They should be read and consulted often.
Baldwin offers a Document Management program which many of our clients take advantage of. We provide template manuals which an operator can use to start their operations. They, of course, need to be customized with your own policies and procedures. We act much like a Technical Publications Department would act. We keep track of all your changes and notify you when they have been incorporated into your manuals. If you do not have the manpower to keep up with your manual changes, consider giving Baldwin a try!
Remember, your manuals are a critical part of your SMS! Keep them up to date! Read them and consult them often. Use them to, “Say what you will do,” and then most importantly, “DO what you say!”