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How safety management principles can support you during COVID-19
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The many challenges that organisations are facing as a result of COVID-19 are resulting in a number of operational changes. Effectively managing risks related to and resulting from these changes is vital to maintaining the safety of Australia’s aviation industry.
If your organisation has an existing Safety Management System (SMS), you should use your existing procedures and requirements to ensure that any changes and the associated risks are appropriately managed.
If your organisation does not have an SMS, you can still apply the safety management principles detailed here and in the reference material to support you to make informed, risk-based decisions.
The key aviation safety concern during COVID-19 is not necessarily the virus itself but instead the many operational challenges organisations are facing and the resultant large number of changes that are being implemented. COVID-19 has triggered numerous challenges for aviation organisations, each of which has the potential to impact the effectiveness of existing safety risk controls. Examples include:
- financial challenges
- significant reduction in passenger loads
- changes to the kind of work undertaken (e.g. shift to cargo operations in lieu of passengers)
- technical issues as a result of aircraft being ‘parked’ for long periods
- significant reductions in flight crew and other staff activity
- human performance impact on crew and other employees of stress associated with possible lost work or other personal circumstances
- adapting to operations under changed regulatory requirements (exemptions)
- crew being unable to access simulators for training and currency requirements
- staff being unable to conduct normal training activities
- limitations on availability of specialist personnel due to travel restrictions e.g. technical specialist only available interstate or overseas
- loss of suppliers/contractors that may have ceased activities/operations due to the pandemic.
Where an organisation has an existing SMS, you should utilise the management of change procedures to consider each change, identify any relevant hazards, assess the risk and implement appropriate mitigations. Given the potential for a large number of changes occurring within organisations, it is also important organisations consider the cumulative effect of interactions between the changes being implemented.
Organisations may also need to consider and balance risks other than aviation safety risks, such as the public health risks associated with COVID-19; these too can be captured through the management of change process.
Where an organisation does not have a documented SMS or management of change procedures, you may consider following the six-step management of change process:
- Step 1: Communicate and consult
- Step 2: Develop the case
- Step 3: Conduct risk assessment and planning
- Step 4: Prepare the plan
- Step 5: Implement the change
- Step 6: Ongoing monitoring and review.
While the dynamic nature and rapid evolution of COVID-19 may result in a compressed timeframe for the implementation of changes, the same basic six-step process can be applied no matter how quickly a change needs to be implemented. Also, see specific considerations when conducting management of change in response to COVID-19.
- Step 1: Communicate and consult
Effective communication and consultation ensure the success of the change. Communication and consultation should continue throughout all steps of the change process; initially, the organisation must identify the key stakeholders that need to be consulted, both internally and externally. Typical stakeholders involved would include staff, CASA, as well as public health authorities, clients and contactors etc.
Organisations may not have experience in dealing with some of the necessary stakeholders, such as public health authorities, and should seek guidance as early as possible. Also, public health authorities may be State or federally based and have varying requirements. Organisations operating across state borders should ensure they remain in contact with the relevant agencies throughout the COVID-19 pandemic.
ICAO has reinforced the importance of cooperation, collaboration and communication among all relevant parties to ensure the best outcomes for the aviation industry. It is recommended that organisations keep CASA informed of their changing activities both during pandemic restriction and as operations resume. Where there is a regulatory impact, organisations should engage early with CASA to outline the issues and develop a safety risk mitigation plan, which requires CASA approval, to support changes to operations or authorisations. An example of a return-to-service change that may require regulatory involvement could be operating new aircraft types on routes. This may require changes to an organisations AOC (approval), which can take time.
- Step 2: Develop the case
Often changes made in response to the pandemic have been forced on an organisation and the justification or case for change will simply be to permit operations to continue. Despite this, organisations should ensure they clearly understand the challenge that is causing a change, understand what it will mean for their operations and what the scope of each change will be.
Organisations implementing exemptions (also known as alleviations) into their operation are required to comply with the applicable regulations and any COVID-19 exemptions (where applicable). Organisations are required to ensure that applicable exemptions are treated as a change and are implemented and managed effectively to ensure continued safe operations. To make full use of exemptions, organisations may need an approved safety plan.
The large number and rapid implementation of changes in response to these challenges make effective management of each individual change essential. Organisations need to consider the case for each change individually and the cumulative effect of all pandemic-related changes. Maintaining an up-to-date change log (or change register) capturing the key details regarding each change will support organisations in understanding the cumulative effects of their changes.
- Step 3: Conduct risk assessment and planning
Each change introduced in response to a pandemic challenge has the potential to alter existing risk controls or introduce new hazards into an organisation and must be effectively managed. While some changes may be necessitated by changed regulatory requirements, organisations may have more discretion with other changes; in these circumstances organisations should also consider the risk associated with not changing their operations. Organisations should engage with all relevant stakeholders to ensure that any potential solutions are assessed to ensure the hazards/risks that they may introduce are appropriately assessed and managed.
In addition to considering the aviation safety risk associated with change, organisations will also need to consider other risks such as those to public health. This may be a risk that organisations have previously not considered and as such, changes to SMS risk management procedures, such as consequence descriptors, may be necessary. It is acknowledged that most Australian aviation organisations will not have suitable public health subject matter experts as part of their staff, therefore organisations should rely on the guidance and recommendations published by government public health agencies when making decisions around public health risks. Noting the dynamic nature of COVID-19, the guidance issued by public health authorities can change regularly and with little notice and organisations should remain up-to-date with the latest advice and update their risks assessments accordingly.
Organisations will need to consider the risk across aviation safety and public health and seek to implement solutions that provide an optimal balance between aviation safety and public health risks. In support of these decisions CASA has issued Cabin Safety Bulletin 21 which includes specific considerations for cabin crew in balancing the use of PPE from a public health (for crew and passengers) and an aviation safety perspective.
In considering different risks organisations should maintain an effective and up-to-date risk register which captures in sufficient details the risk associated with all changes.
- Step 4: Prepare the plan
Each change must be supported by an appropriate level of planning, but each change does not necessarily require a full, formal project plan. Such planning should be documented and could include timings, tasks to be completed such as process development of training, and the broader communication intent. At a minimum, planning should ensure that any mitigation identified to address risks is implemented prior to the change occurring.
Organisations may make use of a simple change template that would allow the standardised planning and documentation of minor changes within the organisation. Such templates could be useful during the pandemic to allow changes to be planned and recorded quickly and effectively where a full project plan may not be appropriate.
- Step 5: Implement the change
The pandemic has resulted in some changes being implemented rapidly with little warning. To maintain the safety of operations, organisations must ensure that appropriate change management is conducted prior to implementing changes. Poorly considered and planned changes have the potential to introduce additional aviation safety risks.
To ensure the success of rapid frequent changes, organisations may have to find new methods of supporting changes including how the change is communicated or trained. For example, where previously face-to-face training or crew meetings may have been utilised to convey key messages, organisations may not accept the risk of having many staff in a single place at once. Instead organisations could make use of easily accessible technology such as online video conferencing tools to conduct virtual classrooms or team meetings.
- Step 6: Ongoing monitoring and review
Operations during COVID-19 could result in changes to an organisation’s assurance and audit requirements. Organisations may be operating to changed regulations (due to exemptions) and new procedures. Organisations must ensure the compliance and suitability of new requirements. This can be achieved through audit/assurance activities, data analysis or safety reporting. Existing safety monitoring may also need to be adapted to the operational changes.
The overall impact of the organisation’s changes may be that previously approved internal audit plans may no longer be relevant. Operations or activities that have been stopped may not require auditing oversight whereas changes to existing process may require a new focus. Safety committees (where established) should review audit schedules, consider any organisational changes and ensure the schedule continues to reflect the organisation’s priorities.
Formal post-change reviews are useful in determining the success of any change. This is the area of management that is most often neglected as organisations tend to move on to the next task once a change has been implemented and seldom come back and conduct a robust review.
During the COVID-19 the need to review the effectiveness of changes is more important than ever. Many organisations will have implemented change more rapidly than they may have done previously which may have resulted in a compression of Steps 1-5 in the management of change process. The volume, pace of changes and dynamic nature of COVID-19 make it vital that organisations review the effectiveness of changes implemented and ensure they have achieved the desired success.
The need for a comprehensive change logs and records is also important as an organisation returns to more normal operations as COVID-19 restrictions are relaxed. A comprehensive change log will allow an organisation to understand what changes may need gradually repealing to enable it to return to a ‘normal’ state. It is important to note that some organisations may not return to completely ‘normal’ operations, that is, operations as they were before the pandemic. Again, an effective change log and risk register will allow an organisation to consider those changes that may become permanent versus those that are temporary once a new ‘normal’ is established.
CASA-issued exemptions around COVID-19 are finite; they have a documented end date and organisations should plan to ensure their operations will be compliant with the applicable regulations by this time. While this end date may vary depending on the submission of an approved safety case, each organisation has a date when their exemption will cease. Organisations should consider returning to normal regulatory requirements ahead of the expiry of the exemption requirement and ensure risk management principles are applied to the process.
The pandemic situation is likely to remain dynamic for some time and, while a reduction in restrictions may allow organisations to recommence operations, the possibility remains that reappearing infections may impact operations in the future. Organisations should capture lessons learnt from the initial ‘wave’ of the pandemic and incorporate them in procedures such as an Emergency Response Plan to improve future preparedness.
Organisations should also take the time as operations start to stabilise to ensure that pandemic implemented changes are suitable for future operations. The pandemic may lead to lasting change (a new normal) and some of the changes implemented at the height of the pandemic may not be optimal for ongoing operations – the quick fix developed during the pandemic isn’t necessarily going to be the best fix long term. As the situation stabilises, ensure the designed work is fit for purpose on an ongoing basis. This may require the (re)application of the six steps .
Approved safety plans
CASA has required organisations to provide a safety risk mitigation plan to extend the applicability of certain provisions in COVID-19 related exemptions. This approved safety plan is similar in intent to a safety case or other exemption justifications required by CASA but is temporary and specific in nature to COVID-19 related exemptions. For organisations that have an SMS, an approved safety plan is not an additional or separate requirement but instead is the documented evidence, approved by CASA, that demonstrates the SMS activities associated with the change/exemption have been appropriately managed to maintain acceptable safety of operations.
An approved safety plan would provide specific, documented evidence that an organisation had identified and implemented the appropriate change management necessary to operate under the exemption and that the associated risk management had been conducted in support of the implementation and ongoing activities associated with the change/exemption.
Safety management challenges when recommencing operations
Restarting operations or increasing activity following COVID-19 restrictions also has the potential to introduce new hazards and risks into an organisation.
Increasing activity should be considered a change even when an organisation is simply returning to what was once ‘normal’ operations. Organisations should follow the management of change procedures in their SMS (where applicable) to effectively manage their return to service or increasing activities. The additional challenges when recommencing operations, could include:
- operating aircraft that have been out of service for an extended period
- crew operating beyond normal recency requirements
- operating to aerodromes that have not been utilised for a period of time?
- operating unfamiliar routes/aerodromes – previous aircraft types withdrawn
- operating to new public health requirements e.g. masks. Understanding how these requirements interact with aviation safety requirements
- operating with contractors that have experienced staff turn-over
- dealing with dynamic and changing government requirements (e.g. State border restriction)
- working more closely with public health authorities to limit inappropriate movement of people
- human performance consideration of return to service.
As per changes during the pandemic, organisations should utilise the management of change procedures in their SMS (where available) or follow the principles in the six-step management of change process.