How to structure your centre’s SMS

A Safety Management System (SMS) in Adventure Centres include your safety culture and it also encompasses the documented system used to direct how you manage risk in your adventure centre operations. 

The content of your SMS documentation is driven by:

• the context and purpose of the operation – what is your centre’s function?
• the results of your risk and hazard management processes
• industry good practice and any legal requirements that may affect your business

To be effective and useful, your SMS must be driven by a strong safety culture and have regular reviews throughout the year.  

This section looks at structuring, documenting and reviewing your SMS

Structure

An SMS can be structured in a variety of ways. A common approach is to separate the policies from the operational procedures by using a Safety Management Plan and standard operational procedures (SOPs), forms and checklists.  The structure you use must suit the complexity of your operation and the amount of risk involved. It must also suit your work team and any external auditing requirements that may affect the business.

Safety Management Plan (SMP)

Your SMP is at the very heart of your SMS documentation. It describes your plan for managing and improving safety across your entire operation. It includes your health and safety policy, the safety processes and should reference all your operational documentation such as standard operating procedures (SOPs), forms and checklists.

The SMP is the document your adventure centre safety auditor will use as the basis for reviewing how you manage safety in your operation.    

Standard Operating Procedures (SOPs)

SOPs include detailed operational information that identifies risk for specific activities and describes how they will be managed in the day-to-day running of an operation. They may also sometimes called Activity Plans/Activity Management Plans. SOPs are the backbone of a safe environment for staff and clients alike. Once staff start to vary the SOPs that is when issues begin to arise. Differences in knots amongst staff can cause a visual check to be incorrect and result in a fatal accident.

SOPs tend to fall into two main categories:

• activity specific – How to set up and run the leap of faith. What to do when an accident occurs whilst hill walking.
• associated operational areas, e.g. staff induction or client pre activity briefs with risk acknowledgement forms.

Safety Forms & Tools

Safety forms and tools are used to gather, record, and provide safety information. They are often useful for ensuring that SMP policies are followed. They should also be referenced in the SMP.

Examples include staff induction checklists and staff training records, a booklet or whiteboard for hazard updates, staff meeting minutes, activity risk registers, risk assessments and management strategy forms (RAMS), trip reporting forms for activities such as Gaisce awards, incident/accident reporting forms, near miss reports, signage and client briefing videos.

Documentation

You need your staff to buy in! Involve your team as much as possible in the development of your SMS. Not only do they hold much of the information about safety, but the system must work well for them. Its a feedback loop and your staff are the eyes and ears on the ground with the best view of hazards that may need attention. 

Tools & Templates 

Forms and checklists and examples from operators and other sectors can and should be researched online and from sources such as governing bodies so that the solutions your business needs are met to adhere to the regulatory audit requirements. They are also useful for developing a SMS for all other adventure activity operations.

Deciding what should be covered by your SMS 

• know the purpose of your operation – does it vary for different participants or activities?
• know your legal requirements
• use risk management processes to ensure you focus your attention on the most important risks
• check good practice information from sources such as Mountaineering Ireland
• identify the specific activities and jobs within your operation e.g. watersports, guiding, high ropes operations
• Think of roles covered by outsourced freelancers, contractors, volunteers and trainees
• consider different locations where you undertake your activity – onsite or hikes offsite
• consider seasonal differences eg winter and summer risks vary
• look at the approach taken by other operators running similar activities. We are a community and an unsafe operation damages all our businesses.

The Devil’s in the Detail

Keep your system clear and simple but provide enough detail so that it’s useful. Your system needs to work well for your team and be tailored to fit the specific context of each activity that your organisation runs. It also shoiuld be dynamic and subject to regular review.

• Clearly differentiate your non-negotiable ‘must-do’ procedures from those where you allow greater degrees of individual judgement and initiative
• Describe what you will typically do (don’t include things that you won’t actually do)
• Use language that works for your team. Keep it clear, simple and consistent. K.I.S.S. (Keep it simple)
• Avoid large blocks of text – use bullet points, check boxes, maps, flow charts, images etc.

A diagram that shows the structure and components of your SMS is a useful  tool for communicating your system to your staff..

Document control

Your SMS documentation needs to be current and accurate to be safe.

• keep track of page numbers, file name, version numbers and date  next review dates
• include the version number of the document in the title and only have the current versions in circulation
• use consistent and clear document names, including appendices. It should evolve clearly and in order
• clearly show when your documentation will next be reviewed – internally and externally. Whats the plan? Be time specific.
• state where your documents will be kept at your business (hard and electronic copies, back-up copies, archives etc). There is no point in filing them away inaccessible by staff for fear they will copy them!
• know how amendments will be made and tracked including who is responsible for signing off changes and preventing use of out of date versions with regard to SOPs etc

Create a section in your SMS that outlines:

• appendices 
• supporting documents and other items
• who must have access  to the files
• who is responsible for the documents
• where they are stored on-site
• when and how they are to be checked and updated.

Reviewing

Review your systems regularly, using in-house and external reviews from registered professionals. This will help your business to ensure that:

• over time, your systems are accurate and up to date
• your systems are outlined accurately in your safety management documentation. 
• your systems are aligned with industry good practice and any relevant legal requirements 
• you and your team have a strong safety culture and are ‘walking the safety talk’ 

Someone must have responsibility to ensure that reviews take place and any resulting actions are followed up. 

Even if you are not legally required to have an external audit, it is good practice to have regular external checks of your safety system. 

In-house reviews

In-house reviews cover all components of your SMS, including what you actually do in the field every day. 

This should be a systematic process but does not have to be done all at once, rather it should happen as part of a normal day and via a more formal ‘audit’ style processes. For example a manger led discussion at pre or post activity briefings, staff training, scheduled checks of specific parts of your SMS such as looking for accident trends or mid-season equipment checks. 

• Make a plan of what you will check. When, how and who is responsible for making it happen. SMART.
• Reinforce a safety culture that staff are personally responsible for following agreed safety systems
• Grow a culture where feedback is welcome on anything and everything. They wont get in trouble for identifying risk with a fellow instructor.
• Make sure that all concerns are addressed and the SMS is updated where needed
• Do regular reviews at a time that suits your operation e.g. larger audit style checks at quieter times in winter or on bad weather days
• Consider using a peer review e.g. a reciprocal safety system check with another operator. Team work!
• Encourage and take into account client feedback. They are experiencing the process and have a unique and valuable perspective.
• Factor-in learning from previous external reviews and technical advisor reports.

Involve your team but there must be someone responsible for the review, they must be competent for this role, experienced and be well supported by senior leadership. Owner operator businesses may use an external technical advisor. 

What to check

Your safety system checks should, over time, cover all aspects of your SMS and include:

• checking your systems against external measures such as activity safety guidelines recommended by governing bodies, audit standards and current legislation requirements
• triggers for an internal safety check including key staff changes, hazard changes, near misses, incidents, new or changed activities, changes to legal requirements
• observing your staff on the job. Are they following agreed procedures, and if not, why not? Don’t get lax.
• analysing your incident data with all staff to remind them of previous incidents, what actions were recommended, look for trends and ensure that correct follow-up action has been undertaken. Why do seemingly non risky activities such as orienteering have far more incidents than seemingly risky high ropes activities.
• checking SOP’s, forms and other similar safety tools. Are they correct, useful and being used as initially intended?

Documenting your reviews

Documenting your reviews is important. Use methods that suit the type of review e.g. keeping a copy of trip report forms, near miss forms, accident reports, or recording a more formal review of your staff induction system. Records should show:

• Who was involved in the checking process
• When and which areas of your centre’s SMS were checked
• How did the checking occurred e.g. by observing staff running an activity or by reviewing checklists and forms
• What actions resulting from the checks, and details on when and how they are followed up. Did you change your SOPs?
• When and how your operation was checked against external measures e.g. activity safety guidelines or an audit tool

External Checks

Use professionals in your business. External checks range from regulatory to voluntary audits, or using an external safety advisor to come and review a part of your SMS. Note that it is considered good practice to have an external safety audit even if you are not legally required to do so.  

To get maximum value out of an external check: 

• organise it well in advance and for a time that suits your operation
• select an audit provider that suits your needs and your operation
• contact your auditor early to ensure that you both have all the information you need, including their audit criteria
• Try to know the audit standard that you will be checked against and use it to do your own internal check before the audit
• know the key areas where you would value a professionals advice and ensure you draw on your auditor’s experience to get the answers you need to create a safe culture
• ensure that as many of your team are on-site as possible, especially key staff. Lets learn together.
• allow time for required follow-up actions and audit completion
• many of the components mentioned under ‘in-house reviews’ will apply here as well.