National Transportation Safety Board (NTSB) vice-chairman Bruce Landsberg is concerned that the current guidance and regulations surrounding safety management systems (SMS) may not be the best fit for small operators, especially those involving a single pilot. Landsberg, one of the scheduled speakers at NBAA’s Single-Pilot Safety Standdown on the eve of BACE in Las Vegas, noted that the Safety Board has made a number of recommendations for SMS, particularly for Part 135.
“We've felt like if there had been a little more oversight and a little bit more introspection on the part of the organization, crashes could have been prevented,” he said. But one of the challenges with that, Landsberg added, “And I've been outspoken about this, is the FAA has a predefined view of how SMS should work.”
While the four components of SMS— safety policy, safety risk management, safety assurance, and safety promotion—are fine, he worries that the “process sort of breaks down…and the standard SMS process isn’t going to work very well” with the smallest operators.
Air carriers typically have upper management, a chief pilot, director of operations, line pilots, and perhaps maintenance personnel. “Everybody's sort of talking to one another and looking out for each other.”
But for small operators, those positions can all involve the same person. “The FAA’s answer up to this point has been scalability—what works on the big side, we can shrink it down,” Landsberg said. “But I'm not persuaded of that because as human beings, we're very poor self-evaluators and that's been tested many, many times. If I'm the CEO and also the pilot and the director of safety, do I ask myself questions and how do I answer? And do I lose arguments with myself on a regular basis? It doesn't quite work.”
Landsberg said that, collectively, industry and regulators need to be a little creative when it comes to small operators. “We have to figure out a way to get somebody else involved.”
He suggested some ways to make the necessary assessments that come with SMS. Operators can tap into data sources, such as engine data, to look for patterns. There are companies that can analyze such information, he said.
A mechanic could spot issues, or flight data monitors (FDMs) can shed light on trends such as altitude excursions, speed excursions, and non-standard approaches. “I think you need to have the ability to have an outside group analyze this, and it can't cost thousands of dollars to do that because the small operators don’t have the margins for that.”
Landsberg further expressed concerns about the crash resistance of FDMs. The NTSB also has made a number of recommendations surrounding their use and “we’ve had a tremendous amount of success with [them].” They are helpful in quality assurance and preemptively looking for anomalies that could be used to highlight trends that could be corrected and enhance safety.
“We’d like to see that trickle down to the smaller aircraft,” Landsberg said. But the challenge there is, “in too many cases, they’re not really crash-resistant. The data cards don’t survive and that doesn’t help us very much.” Hopefully, he added, the operator is proactive and gets enough data off beforehand to start to identify problem areas.