Change Management Made Easy

This article is intended to help rotorcraft operators in the management of any changes that COVID-19 may have caused to operation.  It contains a useful 6-step process to help make this task as easy as possible, and also invite to monitor safety performance to confirm or revise risk assessment and adjust action.

The change management process 6 steps are:

1. Structure your list of changes by phases of disruption.
2. Identify which change can create conditions that may affect the safety of your operations. 
3. Cross check your list of safety issues with the ones you potentially identified and addressed during previous crises.
4. Consolidate your list of safety issues with the ones identified in published guidance from EASA, national authorities and organisations.
5. Focus on the issues where a direct impact on operational safety.
6. Identify and address risk transfers.

COVID-19: An unprecedented crisis

The COVID-19 crisis has created a situation never experienced in Europe. Novelties and uncertainties worsened by the lack of comparable historical data have the potential to invalidate risk assessments based on normal operations.

Other large-scale crises such as the volcanic ash eruption in April 2010 of the Icelandic volcano Eyjafjallajökull had also severe impacts on aviation but for a much smaller period. The way risks have been assessed, mitigated and managed in the volcanic ash crisis is however inspiring. EASA provided at the time a framework of rules and guidance material to support a safety management approach to volcanic ash for the aviation community. Choice of actions was left to the operators based on local risk assessments. Because routes and operations, contexts and practices varied from operator to operator, so did the risks and the actions taken, although many were similar. Operators managed the situation and took the actions most pertinent for them.

The 2008 financial crash and 9/11 have also heavily affected aviation operations. We can learn from how the various phases including the return to normal operations were managed.

Return to Normal Operations (RNO)

In the current COVID-19 Return to Normal Operations (RNO), beside business-related aspects you are probably concerned about how to safely restart operations and ask ourselves questions such as are we facing new hazards and risks?  Have previously known hazards and risks changed? Are current mitigations still appropriate? Should we take action?

To help you answer these questions, EASA launched the EASA COVID-19 Return to Normal Operations project.

Management of change

RNO after the long interruption imposed by the COVID-19 crisis is a change that has to be managed as part of your SMS. As changes are not exceptional in aviation, you have probably performed Change Management before, for instance when introducing a new aircraft type in the fleet, installing new technologies on board the aircraft, hiring new pilots. Other examples are opening new routes or starting new operations, starting a business with a new customer, merging with another organisation, etc.

Managing the safety risks related to a change is a standard component of SMS, as specified in the EASA Operations regulation, ORO.GEN.200 Management system.

See also to the EASA Guidelines - The role of operators’ management systems in the COVID-19 recovery phase.

Managing the safety risks related to a change

The Management System includes implementing rules on Change Management, also called Management of Change. These require addressing possible negative safety impacts of a change:

AMC1 ORO.GEN.200(a)(1);(2);(3);(5) Management system states the following:

NON-COMPLEX OPERATORS — GENERAL

(b) The operator should manage safety risks related to a change. The management of change should be a documented process to identify external and internal change that may have an adverse effect on safety. It should make use of the operator’s existing hazard identification, risk assessment and mitigation processes.
 

AMC1 ORO.GEN.200(a)(3) Management system

COMPLEX OPERATORS — SAFETY RISK MANAGEMENT

(e) The management of change. The operator should manage safety risks related to a change.

The management of change should be a documented process to identify external and internal change that may have an adverse effect on safety. It should make use of the operator’s existing hazard identification, risk assessment and mitigation processes.

NON COMPLEX OPERATORS – GENERAL
(b) The operator should manage safety risks related to a change. The management of change should be a documented process to identify external and internal change that may have an adverse effect on safety. It should make use of the operator’s existing hazard identification, risk assessment and mitigation processes.

Describe how the change may affect the operational hazards and risks as documented in the Risk Assessment, Mitigation and Management components of your SMS.

Ask yourself questions such as:

• How does this change affect the safety of our operations, what new safety issues does it bring?
• Have hazards and risks previously identified in the SMS evolved (worsened) because of the change?
• Does the change introduce new hazards and risks not already addressed in the SMS?
• Are the risk mitigations in place sufficient or should we take action?

Note: ORO.GEN.200 only require addressing possible negative safety impacts of a change. Feel free to address also possible positive effects: changes can for instance offer opportunities to revise the business model or to perform operations or a different way. To analyse opportunities, you may for instance use a SWAT (Strengths, Weaknesses, Opportunities and Threats) analysis and matrix.

6-step change management process

The 6-step process presented below is the same as the one described in the article COVID-19 SR Portfolio Safety Issue Assessment - Risk assessments based on previous normal operations are no longer valid (SI-5008) to efficiently determine which risk assessments need to be revised, published in the EASA Operations Community. 

This 6 steps aims to help you determining where a revision of risk assessment may be necessary, in order to focus your effort where it is the most needed. This process does not intend to supplement any SMS process already in place in your organisation. Its purpose is only to provide further guidance in the identification of the changes induced by the COVID-19 that may affect negatively the safety of operations, and therefore necessitate a revision of your risk assessments.

Step 1. Structure your list of changes by phases of disruption. 

Break the overall COVID-19 disruption period into phases that are relevant for your operations: these could be for instance the initial drop in operation and collapse in traffic, changes to operations, long term storage of aircraft, RNO with initial recovery and sustained growth, and the ‘new normal’. Risk management can be performed for the global COVID-19 period or for specific phases, for instance RNO.

Step 2. Identify which change can create conditions that may affect the safety of your operation. 

As identifying direct links between the change and operational hazards and risks might be complicated, start by identifying safety issues or ‘disruptors’ caused by the change that may affect safety. Consider issues such as for example:

• concerns about staying in the business or losing one’s job, etc.
• concerns about staying healthy (particularly on HEMS operations), etc.
• distancing in operational areas
• reduced personnel
• changes to traffic patters
• decreasing the frequency or postponing certain inspections, checks or maintenance activities
• operational measures such as flying with a mask
• lack of recency in pilots and other categories of staff which may affect competences

Think not only about issues induced by changes within your own organisation but also about issues arising from the changes faced by external organisations (service providers, suppliers) which may affect the interfaces which your own operations are relying on. 

Step 3 - Cross check your list of safety issues with the ones you potentially identified and addressed during previous crises.  

Other large-scale crises such as the volcanic ash eruption of the Icelandic volcano Eyjafjallajökull in April 2010, the 2008 financial crash and 9/11 had also heavily affected aviation operations, even though not to a comparable extent. We can however learn from these previous events, in particular which safety issues were identified during the various phases of disruption, and which actions were taken to safely return to normal operations.

Step 4 - Consolidate your list of safety issues with the ones identified in published guidance from the aviation communities.

Review your list of safety issues against the ones already identified in various published guidance or other relevant documents from collaborative organisations or Authorities, to serve as a basis or see what you could have missed.
Check safety promotion material, directives, guidelines, articles, videos, tutorials, discussions on social media, conference proceedings, etc.
The EASA Review of Aviation Safety Issues Arising from the COVID-19 Pandemic provides a list of generic COVID-19 safety issues that you can use to help you identify your own issues.
Check also the COVID-19 Rotorcraft Information page published the EASA Rotorcraft Community.

Step 5 - Focus on the issues where a direct impact on operational safety.

Analysing how the identified issues impact operational safety can be difficult, when there is a weak relationship between issues and operational hazards and risks, a significant ‘distance’ between any cause-and-effect relationship, complex causes-effects patterns or no relationship at all.
To consider all of the COVID-19 implications but to avoid a disproportionate level of work being spent on redundant risk assessments, focus your effort on the issues with a direct impact on operational safety. This is most probably where your risk assessment should be revised in priority.
Safety issues having direct impact on operational safety must be risk assessed, in order to determine quickly if any actions should be taken.

Step 6 - Identify and address risk transfers

Among the safety issues you may identify as impacting your risk assessments, one particular type of issues should not be forgotten: the multiple sanitary mitigation measures taken against the spread of the virus which can transfer the sanitary risks into an aviation operational safety risk. These should be addressed. For a complete list of these measures, refer to the EASA publication COVID-19 Aviation Health Safety Protocol and to European and national regulatory provisions from Health and Safety authorities.

Measures such as wearing medical facemasks and social distancing can affect the work of pilots and of other staff.  For instance, wearing a medical facemask in the cockpit can affect crew communication, both verbal and non-verbal, as it is more difficult to speak and exchange information with the crew (talking louder, hand-free intercom does not activate right away, etc.), and facial expressions are less easy to identify. This affects Crew Resource Management (CRM). Wearing a medical facemask can also complicate installing the oxygen mask in the case of an emergency.  During flights and when dealing with passengers, wearing a medical facemask for a long time reduces the COVID-19 spread-out. On the other hand, pilots may experience an increase of stress and fatigue due to a prolonged discomfort (rubber bands pressed around the ears and under the headphones, reduction of sight around the nose, etc.) and excess of humidity under the facemask (sweating, reddening).

In case of conflicting risks and mitigations measures, risks must be compared and prioritised. Some helicopters have a physical separation between the flight and the passengers’ cabins (Plexiglas) which is a valid barrier against COVID-19 contagion and may allow the pilot to fly without the facemask. In case of an emergency, if passengers do not wear headsets connected with the intercom system, the pilot may need to open the sliding door in order to get in contact with them and to give the required instructions. In emergency situations with conflicting goals for which there are no SOPs, if you can’t refer to SOPs, use professional judgment and risk-based reasoning: what risk(s) is or are the most severe and which action is the most relevant?

Once the risk assessments being impacted/not valid any more have been identified, follow your standard Risk Management process in order to re-assess the risk and, where applicable, also the relevant mitigating actions to maintain the risk at the acceptable level required by the applicable regulation(s).

Refer for instance to material published by your national authorities and in the EASA COVID-19 website and the Royal Aeronautical Society (RAeS) publication Adapting helicopter operations to the new realities of Covid-19. Here are examples of issues calling for mitigations:

• Flying an aircraft after being in long-term storage calls for specific mitigation measures: refer to the EASA Guidelines for return to service of aircraft from storage in relation to the COVID-19 pandemic.
• EASA Guidance for helicopter operations in the light of the COVID-10 outbreak addresses operators and Competent Authorities and helps operators on the frontline to manage the risks during the current COVID-19 outbreak.
• The EASA Rotorcraft Committee (R.COM) has developed Recommendations for helicopter Ops during COVID-19. The recommendations splits operations into Low, Medium and Increased risk depending on the different type of activity and the people involved. 
• COVID-19 has created concerns about personnel wellbeing: refer to the Aviation Professional's Guide to Wellbeing developed by a group of experts to help people get through this challenging situation. 
• To address and compensate for lack of recency, a recreational General Aviation (GA) pilot should prepare the flight thoroughly, paying particular attention to weather and traffic, revise normal, abnormal and emergency procedures, consider making the first flight with an instructor, and debrief flights thoroughly.  The Rotorcraft COVID-19 Return to Flying Advice includes the excellent video by Mona Seeberger and EASA by GASCo tutorial Return to flying in the wake of COVID-19. The EASA Sunny Swift episode 24 - Return to Flight Precautions also provides good advice.

Addressing Interdependent Stakeholders' SMSs

A comprehensive change management plan must inform all stakeholders of changes that could impact operational safety. The bridging documents for interdependent stakeholders' SMSs should identify roles and responsibilities for safety critical positions, processes and procedures. For ongoing helicopter service contracts, bridging documents should exist between customers, contractors and subcontractors and, hence, they should be reviewed when changes are planned. 

Monitor your safety performance to confirm or revise your updated risk assessment and adjust action

Safety performance monitoring and measurement is the process by which the safety performance is measured through Safety Performance Indicators (SPIs) and checked against Safety Performance Objectives (SPOs). It is based on safety reviews and on trends reviews performed on a daily, weekly or monthly basis.

Use your SMS Safety Performance Monitoring and Measurement process to ensure that the mitigations remain effective and the risks acceptable, and that the overall safety performance remains in line with the objective. This may require regular continuous oversight activity by the safety assurance and compliance monitoring personnel.

Collecting and analysing occurrence data and gathering intelligence as the COVID-19 situation evolves is essential to detect any negative trend early and to adjust action.

Be cautious when building trends or any comparison of safety performance between the pre-COVID-19 period and the COVID-19 period, in particular consider the volume of traffic/work activity necessary to normalise indicators allowing comparisons.

Qualifying a change as an emergency? Activate your Emergency Response Plan (ERP)

A change requalifies as an emergency if requiring immediate action, including crisis communication if it may deteriorate the company’s public perception, image and reputation.

Accidents and serious incidents for instance, are typically emergencies.

To manage emergencies, activate your Emergency Response Plan (ERP), another standard component of SMS.