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Managing safety, from prescription to performance

SMS | March 2, 2016

Author: Nik Chapman

When operating according to a standard that employs performance-based management systems like an SMS, QMS or FRMS, it is necessary to look beyond the prescriptive elements of the particular standard. Only seeking compliance with prescribed elements of statutes and/or standards is reaching for the lowest bar.

Instead, performance-based management systems encourage operators to dig deeper for system improvements that are tailored to their unique environment. Specific needs, which are interpreted by feedback (reactive and proactive) from performance-based systems, become as important as prescriptive elements. Essentially, they are required.

For example, the IS-BAO prescribes that an operator provide emergency procedures training every two years. However, hazard reports and operating conditions (revealed by the SMS) may warrant an increased frequency of emergency procedures training. This indicated need is as necessary as complying with prescribed training needs. In the case of an SMS, specifically identified hazards and their associated risks must be mitigated to a level that is “as low as reasonably practicable,” to ensure compliance with standards like the IS-BAO.

Performance-based systems require ongoing adjustment, clear feedback, and a willing culture. Operators must proactively identify hazards, weigh the risks, and consider and implement effective mitigation strategies. I have heard operators struggle with this challenge; this is what it sounds like:

When considering an online training program to support non aircraft specific topics: “I just need the minimum number of topics to comply with the IS-BAO.”

“We meet the evaluation process requirement for our fatigue management program; we have a spreadsheet that records duty time.”

“Let’s just add the topic to our training program, more training can’t hurt.”

Compliance does not equal performance. So how does one move from prescription to performance?

I believe that the bridge from prescription (lowest bar) to performance is best illustrated by three specific measures, namely: soundness, appropriateness, and effectiveness. Progressive attainment of each measure illustrates a mature performance-based system. Furthermore, the inherent feedback loop achieved through ensuring effectiveness keeps the system tuned.

Consider IBAC’s (2015) definition of these measures, specifically:

Soundness is measured to determine whether the operator has the necessary foundation for proactive safety management.

Appropriateness is measured to determine if safety activity is targeted to consistently manage the operator’s safety risks.

Effectiveness is measured to determine if the desired results are being achieved.

Achieving only prescribed elements in a performance-based system misses the intent of such a system. Alternatively, using prescription as a guide to develop sound, appropriate, and effective policies and processes will engender meaningful safety performance.


Nik Chapman is the Vice President Operations of He currently works as a regional airline pilot and is a published technical writer and editor.

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