In the recently completed Island Express Helicopters (Kobe Bryant) accident report, the NTSB repeated for the fifth time its recommendation that the FAA require all FAR Part 135 operators to establish safety management system (SMS) programs. This recommendation, A-16-36, has been part of the Safety Board’s Most Wanted List for the last two years, and there’s no doubt it sincerely believes that SMSs will improve Part 135 safety. However, there was one troubling note back on page 43 of the accident report. After years of urging by the NTSB and the FAA, only 17 Part 135 operators have developed an FAA-approved SMS program. While 158 more operators have taken some steps toward an SMS, 1,765 other operators (91%) have not. Why not?
Allow me to offer some possible reasons based on my personal experience. I was the point person for my unit of the Air Line Pilots Association back in the 1990s when Flight Operational Quality Assurance (FOQA) was still a new idea. I conferred with pilots at United Airlines, USAir and Continental Airlines, the early adopters of FOQA, and with the FAA contractor, Universal Technical Resource Services (UTRS), to learn how the program should operate. A major obstacle to establishing a FOQA program was a lack of trust. My pilots were skeptical and my company, particularly its lawyers, was not impressed. It took the halving of a $5 million FAA fine to persuade the company to go along. Once we got under way, any breach of confidentiality or misuse of the data for punitive purposes could have torpedoed the program.
Later, during NTSB investigations, I encountered airlines that never got pilot cooperation on FOQA. I found other companies that had lost the confidence of their pilot groups because of alleged misuse of the data for punitive purposes. In short, introducing FOQA programs has been no walk in the park. And FOQA is only one of many sensitive trust-based programs that come under the SMS umbrella.
SMSs do have the potential to improve Part 135 safety. However, to obtain the manifest benefits of an SMS, I think you have to start with the people most affected, the pilots, and work from the bottom up. This is the basis of the safety culture we all want. When FAA Administrator Steve Dickson recently said the FAA’s approach to SMS for non-Part 121 operators will be non-prescriptive, I think he was on the right track. But the FAA’s current guidance to operators, AC 120-92B, and its guidance to its own inspectors in the Flight Standards Information Management System (FSIMS) is, to me, the very essence of prescriptiveness. The vast array of worksheets, checklists, fill-in-the-blanks policy statements and logic box process tools would stump an IRS auditor.
Could it be that SMSs, as currently conceived, are too complicated, too intrusive, too expensive and too time-consuming for small or medium-size operators? And is it too top-down? The essence of being non-prescriptive is to allow the recipient of the recommendation or guidance to find their own most workable solution to the stated problem. With nudging from the FAA and business aircraft organizations, Part 135 operators could become educated and develop their own SMS programs, including only elements they thought they could afford. As they grow and generate more revenue, they could expand safety programs to match the scope of their operations.
During the Colgan Air Flight 3407 accident investigation in 2009, the NTSB discovered that large numbers of airlines, including most of the regionals, did not have FOQA programs. Then-FAA Administrator Randy Babbitt undertook a call-to-action program that, among other things, strongly encouraged all airlines to begin to establish a FOQA program, and it worked. Even though FOQA was and still is a voluntary program, it became evident that for airlines, not having one would be unwise.
FAA Administrator Dickson now has the floor. With an approach similar to the one in 2009, he could start changing people’s minds about SMSs, and I hope he will. But please, let’s go lightly on the check boxes.
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