The International Civil Aviation Organization's (ICAO) recently introduced Safety Management System (SMS) annex says much about how the SMS concept is evolving.

Creating a new, dedicated annex—the first in more than 30 years—underscores SMS's aviation industry prominence. More telling, however, is how ICAO constructed the annex.

Annex 19's fundamentals were made up by transferring existing SMS provisions from six other annexes, including Annex 8—Airworthiness of Aircraft. The strategy symbolizes what is happening with SMS programs, and the understanding of them.

Much like Annex 19, individual SMS programs are finally being recognized as compilations of many existing standards and procedures that most commercial aviation operators have, supplemented with some new elements. Establishing them as extensions of existing programs, as opposed to costly initiatives that either introduce duplicative regulations or entirely new systems, is key to gaining acceptance among those—like U.S. repair stations—not yet required to have them.

Researchers at St. Louis University's Center for Aviation Safety Research (CASR), tasked by FAA to study SMS development and implementation, underscore the importance of creating rules that are both scalable and additive. “Such an approach would allow the smaller operators to either be exempt from all or part of the SMS requirements, or demonstrate compliance through more manageable means,” CASR reasoned in a 2013 paper that compares SMS standards to existing regulations. “Larger organizations would then simply leverage their full range of safety and quality assurance systems to demonstrate compliance.”

One of the report's goals was to make direct links between SMS standards and programs that industry either is required to have in place or can implement voluntarily. ICAO's standards and recommended practices (SARP) called for most industry service providers—including commercial airlines, maintenance organizations and aircraft manufacturers—to have these measures in place by 2009. Much of the world is there, but FAA is still working to establish rules for its operators.

FAA has issued draft SMS rules for Part 121 carriers and Part 139 airports, and has tasked a working group with recommending regulations for manufacturers under Part 21. An SMS requirement for repair stations is expected to follow, and many expect the manufacturing SMS rulemaking to serve as a baseline.

In the meantime, U.S. service providers are relying on FAA-issued guidance, including Advisory Circular (AC) 120-92, to build SMS programs. Using the AC as its baseline, CASR cross-checked U.S. service provider regulations—including Part 145—and approved volunteer efforts like the Aviation Safety Reporting System (ASRS) against the AC's list of 29 fundamental SMS components.

Unfortunately for repair stations, CASR's conclusion is that Part 145 is among the least effective of FAA's service provider regulations at translating into SMS elements. Specifically, the report found that two elements of Part 145—the training requirement in 145.163 and the service difficulty reporting mandate in 145.221—satisfies four of the SMS components. But both Part 121 and Part 135 address twice that number for their operators.

Mixing in voluntary programs and industry standards helps bridge the gap a bit further. For instance, an ASRS program satisfies three additional SMS components.

“Almost no one federal aviation regulatory part met all of the FAA requirements for an SMS,” CASR noted. “Aviation organizations may meet the overall SMS requirements when operating under a combination of several regulatory parts and industry standards.”

Any comfort that U.S. operators find from learning that they are already complying with SMS elements is often pushed aside by worries over documenting compliance of a piecemeal system, CASR found. AC 120-92 is clear in that dedicated SMS manuals are not required, though the guidance notes that operators “may find them to be a practical means of documenting their policies and procedures.”

Dedicated manuals offer advantages and drawbacks. On the plus side, having an easily referenced set of SMS policies and procedures both gives employees a centralized reference and offers the FAA a familiar format to approve, CASR noted. Among the negatives: creating largely duplicative documents is a resource burden, particularly for smaller operations.

A stand-alone manual also presents a more subtle challenge, CASR noted. “There is a risk that the SMS manual will become just another manual on the shelf, to be used only when there is a question regarding SMS or an audit, and may result in SMS processes being forgotten in its routine operations,” CASR's report reasoned. “Thus, the organization may not fully realize any business benefits that an SMS may provide, turning SMS into a cost burden.”

One alternative discussed at a CASR-hosted symposium is using a letter of compliance (LOC). An LOC has the benefit of being familiar to FAA but is much less laborious to produce and update than a full-blown manual. Plus, an SMS's elements can remain part of more commonly referenced documentation. “The use of an LOC would streamline the SMS approval, auditing and compliance process by providing a short and concise method of documentation that is in alignment with the current SMS framework,” CASR explained.

As part of its work, CASR conducted a survey to gauge general feelings on how far a U.S. repair station SMS mandate should go.

Among the survey's notable takeaways: 65.4% of the 440 respondents believe repair stations working on Part 121 aircraft should have an SMS, while 55.1% believe the same for facilities that service Part 135 operators.

Among those that work on transport category aircraft, which account for about 7% of the U.S.-registered fleet, 54.8% say they would “likely” voluntarily implement SMS, as would 42.2% of all respondents. Only 13% of the respondents already have SMS at their facilities.

While there is plenty of variety among U.S. airlines and commercial airports that have SMS rules in progress, those groups look homogeneous next to the 4,700-odd FAA-approved repair stations.

About 45% of FAA repair shops are textbook small businesses with fewer than 10 employees, while 9% boast payrolls of at least 200 people.

Further complicating the issue: Staff size does not correlate with the type of work done. The CASR survey, which was released last year, found that about 52% of the facilities represented handle some transport category work, yet 75% have fewer than 100 employees.

Despite the wide acceptance of SMS as a safety enhancement tool and growing view of it as having financial benefits (such as by reducing costly process-related errors), industry is not unanimous on whether maintenance providers should invest in SMS. Nearly 30% of the CASR survey respondents do not believe repair stations need SMS at all. And while many of these are likely smaller operations that are fearful of a cost-adding, resource-straining mandate, not all of the skeptics fit this mold.

In 2009, FAA solicited industry feedback on the practicality of SMS for operators. Rolls-Royce reasoned that service providers—MRO shops and production organizations, specifically—that are already required to follow an approved set of procedures do not need separate, stand-alone safety systems.

“The significant contribution each can make to safety is in the obligation to work to approved data, minimizing the likelihood of errors through shop floor discipline and inspection, and ensure safety through compliance with the design data and reporting of unexpected discoveries during production/maintenance activities,” reasoned the manufacturer, which also has a significant MRO presence. “Maintenance and production organizations do not, as a matter of course, have to demonstrate knowledge of the safety significance of individual aircraft systems, and should not be expected to judge the effect of errors or unusual events on the safety of the product—each is expected to report such issues to the design organization for a judgment of safety significance.”