Think of an SMS program as active safety management.
In November 2015, a chartered Hawker 700 stalled and crashed while on a non-precision approach to Akron, Ohio. The two pilots and the seven paying passengers were killed. NTSB determined the probable cause was “the flight crew’s mismanagement of the approach and multiple deviations from company standard operating procedures, which placed the airplane in an unsafe situation.” The safety agency also identified the operator’s “casual attitude toward compliance with standards; its inadequate hiring, training and operational oversight of the flight crew; [and] the company’s lack of a formal safety program.”
The NTSB, which I was part of at the time, noted that the operator did not have a Safety Management System (SMS). In citing the critical role that SMS can play, we wrote that SMS “has been recognized in the industry as an effective way to establish and reinforce a positive safety culture and identify deviations from [standard operating procedures] so that they can be corrected.” We concluded that SMS could benefit all Part 135 operators because they require the operators to incorporate formal system safety methods into their internal oversight programs. With that, NTSB recommended that FAA require all Part 135 operators to establish SMS. We reiterated that recommendation following seven other Part 135 crashes, which claimed 39 fatalities. We even placed the issue on our Most Wanted List. Congress apparently agreed with the our stance and, in 2020, mandated that FAA initiate rulemaking for Part 135 operators.
In response, last year the FAA issued the long-awaited notice of proposed rulemaking (NPRM). Since then, there has been a great deal of hand-wringing and complaining about what some view as an overburdensome requirement. Of course, this is only the proposed rule, and what the final rule will contain, or when it will be issued, is anyone’s guess. By government rulemaking practices, the public is invited to comment on the proposed rule, via a Notice of Proposed Rulemaking (NPRM). Before a final rule is enacted, the FAA must consider these comments and explain how it addressed them.
Many of the comments I have read are supportive, but some among the 200 total writers remarked on suggested changes for the final rule. I also ran across some interesting comments, such as one that referred to an “onerous task of implementing a Safety Management System and all the administrative functions that come with such a program.” Another referred to “FAA's over-regulation [that] smothers more and more small operators.” That commenter ended with, “When does it stop—when we all go out of business?”
For those who feel that SMS is onerous or over-regulation, here’s my advice: Just forget SMS.
Instead, think of it this way: The things that are part of a fully functioning SMS are the very things a professionally run aviation provider should be doing in the first place. Yes, you need a safety policy. Yes, a professional flight department should be assessing risks and mitigating those that are unacceptable. Yes, there should be safety assurance to verify that risk controls are effective. And, yes, the organization should strive to have a positive safety culture and actively practice safety promotion. Each of these components is a prescribed ingredient of SMS.
The late Don Arendt of FAA once told me that perhaps we should change the name of the Safety Management System to simply Safety Management. Don’s point was ingenious: The term Safety Management System makes people think the SMS is something they have or want. Safety Management, on the other hand, implies the active management of safety.
SMS provides a businesslike framework for actively managing safety. Consider the business approach that organizations use for managing their finances: They have a chief financial officer. Their financial accounting is in line with generally accepted accounting principles. They conduct internal and external audits. They report irregularities before they become major issues. Why do they do these things? Because finances are important to them. By the same line of reasoning, if safety is important, should not safety be managed by a similar process? SMS provides that very process.
Whatever you call it, a professional flight department does the things associated with having an SMS, regardless of whatever they call it. It is about doing the right things for those who rely on your company to provide the safe service for which they are paying. Why would you want to do anything less? As aptly stated in the NPRM: “As a fundamental matter, the flying public expects safe carriage from operators offering flight services for hire. Irrespective of whether an operator employs one pilot or a thousand, that company has the same responsibility to conduct safe operations.”
My biggest concern with mandating SMS is that some organizations will simply buy an off-the-shelf product to show compliance. Although consultants can be helpful in assisting to develop an SMS, the system needs to be customized for the organization. As acknowledged in one NPRM comment: “A properly functioning Safety Management System can be a tremendous benefit to all the stakeholders, but merely satisfying regulatory requirements is not good business for either FAA or industry.”
SMS needs to be scalable to fit the size of the organization. Certainly, the SMS for a two-aircraft Part 135 operator does not need to be the same as NetJets’ safety system. Even the FAA’s advisory circular on SMS (AC 120.92B) states, “An SMS does not have to be an extensive, expensive or sophisticated array of techniques to do what it is supposed to do.”
Documentation and record-keeping are key components of SMS. I once ran a small Fortune 500 flight department with two aircraft. We started the SMS journey by writing down the manner in which we intended to operate. This evolved into a flight operations manual that included our safety policy. It was jointly signed by the CEO and myself, as the aviation department manager. This satisfied the SMS safety policy requirement.
Before I arrived, corporate management would say they wanted to go to a certain town, and the pilots would dutifully comply. If there was an airport, they went. But, over time, we realized we were just blindly accepting risks. If you are going to accept risks, at least know what you are accepting. So, we changed. Before agreeing to go to a new airport or implementing a new procedure, we did our best to identify the potential hazards, followed by assessing the level of risk associated with those hazards. For those that were above our comfort level, we took measures to mitigate the risks. In SMS vernacular, that is the safety risk management component of SMS. The process provided us with quantitative information we could take to senior leadership to explain our decision-making. Instead of pushing back, they appreciated that we were looking out for their safety by taking a risk-based approach to decision-making.
Safety assurance means, among other things, making sure you are following your processes and that the risk-management controls you have implemented are effective. It also involves data collection and analysis to seek out anything of safety significance. Sources of data may include reports submitted to the company incident-reporting system, flight dispatch logs and crew duty records. For a small flight department, “most of the data/information-gathering for monitoring of operational processes will likely occur as a normal business process by the management personnel who are directly involved in the day-to-day operations,” states FAA AC 120.92B. Safety assurance also involves continuous improvement. When safety deficiencies are identified, they must be corrected.
The final element of SMS—safety promotion—involves cultivating a positive safety culture. It also necessitates effective communications. In addition to clearly communicating safety hazards, FAA states safety communications may be something as simple as periodic safety meetings and posting information on bulletin boards.
Some of these requirements may sound onerous. If you do not like the term SMS, just forget it. However, do not forget that the things that are associated with SMS are the things that a good flight department should be doing in the first place. It is about ensuring you are providing the highest levels of safety for those who are paying for your services. Now that is something not to forget.
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