Torqued: The Case for Voluntary SMS for Small Operators

 - September 2, 2019, 7:00 AM

The safety benefits of maintaining a safety management system (SMS) in aviation should be well known at this point. An effective SMS provides an organization with a systematic approach to managing safety risks and making sound safety decisions. A functioning SMS begins with a commitment from the top of the corporation but engages workers at all levels of the company in identifying safety hazards so that their risks can be assessed, analyzed, and eliminated or mitigated. It will also ensure that risks are properly assessed over time and changing circumstances. Of course, the point of SMS is to reduce the potential for accidents or incidents but, in my experience consulting with airlines of all sizes, it also provides economic benefits unrelated to safety, such as improving efficiencies and promoting cost-savings.

But since the FAA doesn’t require SMS for corporate or Part 135 operators, I’m asked on a regular basis by these operators whether I think their company should voluntarily adopt an SMS program, whether the time and cost of adopting a program is worth the effort. Some have read something about SMS and are curious if they will soon be required by the FAA to have it. Based on the lengthy rulemaking process and the fact that there’s no rulemaking proposal out there, it’s pretty doubtful that any new SMS requirements would come out for operators in the next 5 or even 10 years. But some operators just want to know whether—and how—it could benefit them. A few Part 135 operators may have read the NTSB’s 2019-2020 Most Wanted List of Transportation Safety Improvements, which includes adopting SMS to improve the safety of Part 135 aircraft operations. 

The NTSB’s recommendation pertains to Part 135 air medical service, air-taxi, charter, and on-demand flights and recommends that Part 135 operators be mandated to “implement safety management systems that include a flight data monitoring program, and they should mandate controlled-flight-into-terrain-avoidance training that addresses current terrain-avoidance warning system technologies.” Clearly, the NTSB is strongly advocating for the expansion of SMS requirements to Part 135 operators. But the NTSB can only issue recommendations. It takes the FAA—or congress—to make them mandatory.

Most of the companies asking me about SMS these days are the smaller business flight departments and charter operators. The larger ones (those that provide non-medical transportation) have—to my knowledge—all adopted SMSs either because they are flying customers to countries abroad that require them to have an SMS or because they need an SMS to get a high rating from a charter rating service, or both. For example, if a Part 135 or business aircraft operator wants to fly to a European Union country, the charter company must have an approved SMS program that meets the requirements of ICAO (the International Civil Aviation Organization). 

In addition, to get a platinum rating from Argus, one of the major charter rating services, or qualify for IS-BAO (International Standard for Business Aircraft Operators) registration, an operator must have a functioning safety management system. Many charter customers—especially the major corporations—require a charter company to hold a platinum rating to contract for the air transportation of company employees. So, in terms of business competitiveness, a functioning SMS is highly desirable for many operators, and they have chosen to voluntarily adopt an SMS program.

At this time, the FAA’s SMS rule—14 CFR Part 5—applies only to Part 121 operators. So technically speaking, the Federal Aviation Regulations don’t require any company other than an air carrier flying under Part 121 to have an SMS. But the FAA has been encouraging Part 135 and other operators for some time to adopt voluntary SMS programs in advance of any rulemaking. Although voluntary, the FAA has an approval process, which lays out that a Part 135 operator satisfy the requirements for operating in EU countries. The FAA’s voluntary program tracks the Part 5 requirements for Part 121 operators so it’s likely that if Part 5 is ever expanded to include Part 135 operators, those with an approved voluntary program will be ahead of the game when it comes to compliance. 

I have been a big proponent of SMSs for years, decades really. Having been involved in aircraft accident investigations for virtually my entire working life, I have been to the scenes of far too many accidents that subsequent investigations have determined were caused by lax organizational processes and poor safety cultures. I have spoken to far too many victims’ families distraught to learn not just that their loved ones had died, but that the accident might well have been preventable.

A functioning SMS can create a safety culture that encourages employees to identify and report hazards that executives in their offices would never be aware of. SMSs provide a structured approach to safety risk management that can be a significant benefit to companies of all sizes, even mom-and-pop operators. Of course, a good SMS program is not a one-size-fits-all solution. Clearly, smaller, less complex operations can do with a properly scaled program that’s easy for a small operator to manage and yet provides safety benefits.

So, even if the FAA has not seen fit to mandate that Part 135 or business operators implement an SMS program, I would strongly urge operators—especially air ambulance providers who have had a challenging accident record—to voluntarily adopt one that meets the requirements of Federal Aviation Regulation Part 5.

Since SMS implementation for operators other than Part 121 air carriers is voluntary, companies have a great deal of flexibility in how they adopt a program. There are many resources for help getting started, including talking to professional associations your company may belong to. The FAA’s website is a good place to start to get some background on the SMS program.

Comments

I too am an SMS proponent. The thing to keep in mind is any functioning aviation department, corporate, 135 or 121 operator has and did possess some form of a safety management system long before IS-BAO ever came along. For the sake of starting somewhere, call some of the air carriers' mature safety programs (paid for in blood) the Platinum Standard - or a railroad's ISO-9000 - the same thing of a generation ago. There's about 6-8 things any professional operation can do to delete about 98% of aviation accidents:

1. Human Factors training.
2. An altitude awareness program.
3. An ECAP program (Enhanced Crew Awareness Procedures)
4. A high standard for checklist usage.
5. A high standard for taxi, takeoff and approach briefings.
6. A high standard for NOTAMs and weather dissemination.
7. A high standard for rest requirements, fatigue and distraction mitigation.
8. A high standard for ground safety and aircraft fueling operations.
9. Automation usage and standards.

You don't have to buy an expensive FOQA package or hire the best auditor in the business to actually achieve this stuff - or even be IS-BAO certified. Anyone can buy an IS-BAO certification and promise that they do it right. Often they don't, but will show you the plaque that says they do. An enlightened management that puts safety and their people first - can work that list and get a heckuva lot more bang than most will get from some hired gun service to blow in and write a manual and perform an audit for them - who thereafter declare themselves "safer". It doesn't work that way. There are so many auditors out there now it has turned into a race for the bottom, in my humble but highly accurate opinion. Buy in from the rank-and-file for best and safest practices requires management that walks it like they talk it.

Most GOMs, FOMs could be about 20-30 pages long. They're never that way. That's why most pilots, who tend to be a breed not large on bloated pontificating, don't read them. Most safety management systems can be taught in a couple of days - and reinforced thereafter with action.

Matt Nash
Chief Pilot
Hotel Aviation, LLC
Atlanta, GA

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