The SMS Journey, Part 3

The easiest way to spool up your SMS program is to hire a company specializing in getting you up to speed quickly; just type “SMS for business aviation” in your favorite Internet search engine. These providers will take your existing manuals and procedures, make them SMS compliant and shepherd you through your first audit. 

Jim Hosey, president of Aviation Consulting/Auditing, offers some insight into the process when going this route. “A smaller flight department will need six months to a year to get started. A larger flight department can spool up in half that time because they have more people to handle the work. In either case, you can be at 100% in two to three years.” He recommends membership in the Business Aviation Safety Consortium (BASC), www.aviationconsortium.com, to streamline the process. Membership runs $5,000 annually.

You don’t have to use a consultant or vendor to start your SMS program; you can do it on your own. Fortunately, there is a lot of help available today to flatten the SMS learning curve. The National Business Aviation Association (NBAA) holds regular SMS Implementation Workshops, normally scheduled at its annual Business Aviation Convention & Exhibition.  See nbaa.org for more information.  FlightSafety International and the International Business Aviation Council (IBAC) have co-developed an SMS course designed for flight department managers and those tasked with developing an SMS.  See https://www.flightsafety.com/ for details.

I recommend you look at Advisory Circular 120-92B, Safety Management Systems for Aviation Service Providers. While this AC is meant for Part 121 certificate holders, the guidance is helpful for anyone getting started with SMS.

Phased Implementation
When IBAC first introduced the International Standard for Business Aircraft Operations (IS-BAO) in 2002, the acknowledged progression was to move from an entry level called “Stage 1” and eventually to “Stage 3.” Some operators thought that Stage 3 meant you were done and that from that point on you could coast. Of course, this isn’t true. You don’t need to follow the IS-BAO model at all, but you do need to implement your SMS with the idea it is a continuing process. AC 120-92B recommends a phased approach using four levels of implementation.

• Level 1 is for planning and organization. This is where you get everyone on board, identify what you already have and what you need. I recommend sending at least your safety officer to training. Hiring a consultant at this point can speed the remaining steps considerably.
• Under Level 2, you have in place a basic safety management system and will develop your safety risk management and assurance programs. Members of your organization should be able to identify hazards and unacceptable risks, know how to report these, and participate in teams designed to identify solutions and mitigate the risks.
• With Level 3, you will have a fully functional SMS and will be able to further use your safety risk management and assurance programs in a proactive manner.
• Level 4 is for continuous improvement. All required SMS processes are in place, and you will continuously monitor your SMS for the life of your organization.

“Certification”
If you are a U.S. commercial operator, you will need to prove you have a qualified SMS under 14 CFR 5. If you are flying internationally as a U.S. operator under Part 91, you will need to prove you have a qualified SMS under ICAO Doc 9859. The most effective way to prove your system is through an approved SMS auditor. This will provide more than just peace of mind; it should expedite international ramp inspections. If, for example, you are given a Safety Assessment of Foreign Aircraft (SAFA) under the European Union Ramp Inspection Program (EU-RIP), having an SMS certificate from an accredited auditor may satisfy many of the inspector’s questions.

With or without that piece of paper saying you have an SMS program, you should realize that SMS is never finished, it is a continuing process. Even after you have your operation in what appears to be “tip top” shape, realize that SMS will be needed to face the challenges sure to come.

SMS In Action
There is no doubt a SMS can improve your organization during the early implementation and development stages, but the benefits may prove even more valuable with the inevitable changes over time. In the many years since we considered our SMS fully implemented, we’ve used our program to face challenges as they occurred and even to anticipate them before they could become problems. Here are a few examples:

Our Hazard Identification and Tracking (HIT) program quickly became my favorite part as it slayed one problem after another. Everything from the way we towed our aircraft to the way we entered a VFR traffic pattern was improved. But it really earned its place in our arsenal the day I was called about a passenger slipping on our hangar floor.  The center of our hangar floor had an anti-slip coating, but on that day the ramp was covered in snow and the passenger decided to take a shortcut away from the center. The solution was to recoat the entire floor with the abrasive coating. The reason I was impressed was that the hangar manager, who felt somewhat responsible, didn’t think twice about filing the HIT report. I can imagine a few years ago the thought would have been to dismiss the incident as “one of those things” and I might not ever have heard about it.

A good SMS program should have an Emergency Response Plan (ERP) that is well thought out and has been practiced regularly. We had such a plan but never practiced it until one of our audits flagged us for this. At our first practice, a line technician said there was no way he was going to remember the right words if he were contacted by the press so his plan would be to do the “Sergeant Shultz” routine, saying “I know nothing.” One of our pilots filed a Continuous Improvement Opportunity Program (CIOP) recommendation, saying we should give everyone a wallet card with the pre-approved statement. Along the way the team also thought it would be good to have key phone numbers on the reverse of the card.

We give everyone in our organization a chance to rate our “Operator Safety-Risk Profile” at least once a year and whenever we have changes in personnel or equipment. The form we use tracks operational things like our local airport’s approaches, technical factors such as problems with our aircraft, and human factors like the number of pilots or mechanics. Over the years we only had two instances of identified elevated risk. The first was when one of our pilots was medically grounded just as another quit and the second was when our aircraft’s operations were significantly curtailed due to a fleetwide limitation. In both cases we were able to proactively adjust our operations to accommodate the elevated risks.

You are not alone if you recoil from all the alphabet spaghetti.  HIT?  ERP? CIOP?  Those acronyms are purely optional; the important thing is the culture that goes along with them. A good safety culture fosters in everyone the idea they can report any problem without fear of repercussion. They should appreciate that no matter where in the organization they are, they can generate an idea to make things better and know that idea will be treated seriously.

Our SMS has proven itself time and again. It has made us all safety officers and has changed our mission-oriented operational culture into a safety culture.

If you don’t have an SMS program, you need one. It will take time, but you will reap benefits with each step. If you already have an SMS but you haven’t given it a thought since your last audit, you should evaluate your safety culture with the idea of making it even better.

Where To Find Additional Help
I recommend getting professional help when starting your organization’s SMS, but you could tackle it on your own. Here a are a few resources to get you started:

Title 14 CFR Part 5, Safety Management Systems for Certificate Holders Operating under 14 CFR Part 121.

Advisory Circular 120-92B, Safety Management Systems for Aviation Service Providers.

Annex 6 to the Convention on International Civil Aviation, Part 1, International Commercial Air Transport, Aeroplanes.

International Civil Aviation Organization (ICAO) Document 9859, ICAO Safety Management Manual.
FAA Public SMS Web site: http://www.faa.gov/about/initiatives/sms/specifics_by_aviation_industry…

ICAO SMS Training Web site: 
https://www.icao.int/training/pages/safety-management-training-programm…

Example Accountable Executive Safety Policy Statement
Your safety policy must include a statement from the organization’s “accountable executive.” Appendix 4 of AC 120-92B presents a flowchart to help you determine who your accountable executive is. The AC also provides an example policy statement:

The Executive Management of [Certificate Holder’s name] recognizes that an effective Safety Management System (SMS) is vital to the success and longevity of the Company. Therefore, the Executive Management is committed to implementing and maintaining a fully functional SMS and to the continuous improvement of the level of safety throughout [Certificate Holder’s name].

Executive Management of [Certificate Holder’s name] will establish specific safety-related objectives and will periodically publish and distribute to all employees those objectives and plans.

These safety objectives will be monitored, measured, and tracked to ensure overall corporate safety objectives are met. All employees and individuals in the company have the responsibility to perform their duties and activities in the safest practical manner.

[Certificate Holder’s name] Executive Management is committed to providing the necessary financial, personnel, and other resources to establish and maintain a fully functional SMS.

[Certificate Holder’s name] Executive Management is dedicated to establishing a confidential employee reporting system to report all hazards, accidents, incidents and safety issues without fear of reprisal.

Activities involving intentional disregard for FAA regulations, company policies and procedures, illegal activities, and/or drugs or alcohol may be subject to disciplinary action.

As a component of the SMS, [Certificate Holder’s name] Executive Management is committed to establishing, maintaining, and periodically exercising an emergency response procedure and plan that provides for the safe transition from normal to emergency operations.

Executive Management will convey this expectation to all employees through postings, intranet site, company newsletter, and any other means to ensure all employees are aware of the company’s SMS, their duties and responsibilities, and our safety policy.

This safety policy will be periodically reviewed by Executive Management to ensure it remains relevant and appropriate to the company.

[Signed],
Accountable Executive

The SMS Journey, Part 1: https://aviationweek.com/business-aviation/safety-ops-regulation/sms-jo…

The SMS Journey, Part 2: https://aviationweek.com/business-aviation/safety-ops-regulation/sms-jo…