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The FAA’s new SMS mandate—what does proactive safety mean for all operators?Posted 2/5/2015

 

the new FAA SMS Ruling

As you’ve likely heard, the FAA recently announced a final rule requiring air carriers operating under 14 CFR part 121 to develop and implement a safety management system (SMS) to improve the proactive safety of their aviation-related activities. This means that airlines must submit their specific plan to the FAA within six months and then—once it’s approved—to implement the plan by January, 2018.

As most of you are aware, nearly every domestic airline has already adopted a SMS long ago—most of which are homegrown.

So, the big questions remain:  Why the need for a new regulation? Why now? And how does this final rule affect part 91, part 135 and part 139 operators?

It’s all about proactive safety, folks. A subject so important that we named our business after it!

The Need for More Proactive Safety

The first thing I’d like to address is what the new rule is designed to achieve. For starters, the new rule adds some significant new requirements and raises some important questions, which should be addressed by everyone in aviation. It also builds on a lot of safety technology systems and programs that many airlines already have in place. And, it’s consistent with the International Civil Aviation Organization’s (ICAO) standards. On top of that, it supports recommendations from the National Transportation Safety Board.

As FAA Administrator Michael Huerta explained in early January, the new rule is, in the most general sense, aimed at improving safety and mitigating or controlling risk factors—proactively. Huerta said, “In the past, our focus in improving safety was to study the cause of past accidents. But we all know our ultimate goal is to prevent accidents from happening at all. That is where safety management systems come in.”

Huerta went on to say that a SMS helps ensure safety by providing airline companies with “ . . . a structured approach to look at data from airline operations. This data can help identify patterns and trends that could possibly lead to a problem. But having this information enables the industry to take action before there is a problem.”

But is there a safety problem? The answer is yes.

The FAA’s Office of Accident Investigation and Prevention identified more than 100 airline-related accidents (from 2001 through 2010) for which causal factors could have been identified and mitigated if Part 121 carriers had an effective SMS.

Per the ruling: “This is a significant improvement over current ‘reactive’ safety action emphasis, which focuses on discovering and mitigating the cause of an accident only after that accident has occurred.”

Why the FAA SMS Ruling Now?

So, given the obvious benefits of a structured, data-driven approach to eliminating hazards to aviation, and the fact that most airlines have already voluntarily established some type of SMS, why is the government moving to mandate adherence to the new rule? The answer is simple:  the FAA needs to have 100-percent compliance and consistency.

As airline industry expert John Goglia blogged over a year ago: “There’s no way to garner the full benefits of SMS by depending solely on volunteer adoption. For one thing, a lot of entities just won’t do it voluntarily.” So the rationale for the new ruling is to make SMSes more standardized and, therefore, more predictably and consistently safe.

Those airlines that have volunteered to incorporate an SMS into their operations are showing some very impressive results. (Administrator Huerta said the FAA is receiving data from 96 percent of airlines at present.) What’s more, the industry is growing so big and diverse that the FAA can no longer afford to monitor industry safety operations as effectively as it once did. The budget and manpower required to do so simply outstrip their capabilities.

All Aviation Operators Are Affected

What is the trickle-down effect for Part 91 and Part 135 operators? Will the FAA require them to develop their own SMS? Likely so. In my opinion, it’s only a matter of time before the FAA will mandate SMS for other areas of aviation, including Part 91 and Part 135. After all, ICAO does so for domestic carriers traveling internationally.

Designing and implementing a SMS will be costly for the airlines—to the estimated tune of $224.3 million. But it’s not nearly as costly for Part 91 and 135 operators who wish to implement similar SMS best practices.

A ballpark figure for smaller operators with one to two aircraft could run somewhere in the neighborhood of a few thousand dollars. (It’s double that for larger operators.) And the good news is that Part 91 operators do not need to hire additional manpower solely to run a safety program—your existing crew can pick up the extra duty involved, especially if you have a leadership/mentorship program in place and someone willing to take on extra duties. If you do happen to lack the necessary internal resources to get your SMS started, you can outsource the role to a knowledgeable contractor who can help you avoid some of the pitfalls and potholes.

Be Proactive

I think we all would agree that it’s very advantageous from both a cost and safety perspective to have a system in place that can proactively identify threats BEFORE they have a chance to wreak havoc with an airline or operator’s reputation for safety.

Whether you manage an airport, a flight department, a maintenance organization, or any other aviation service, implementing a “best practices” SMS is a good idea. For starters, it will create a positive work environment culture, since you’ll be relying on your team to provide input and information. You’ll become more efficient, which eventually leads to dollars and cents savings. And, most important of all, you’ll operate more safely.