Part 135s Talk Safety; Security

International Issues in SMS Implementation
Don Arendt, manager of FAA’s Flight Standards SMS program office, recently addressed concerns about operating abroad without an International Civil Aviation Organization (ICAO) recognized and accepted SMS program at the Air Charter Safety Symposium in March. Comments Arendt, “A lot of the misconceptions are really a misunderstanding of the international requirements themselves.”

ICAO’s top-level requirements for SMS are: a systematic approach to safety where providers are responsible for establishing an SMS, and states are responsible for acceptance and oversight of providers’ SMSs (ICAO Annex 6, Part 1).

According to ICAO, the FAA has two roles: to have a requirement or a regulation, and to have an acceptance process, says Arendt. Currently there are no FAA-authorized procedures to accept or approve an SMS. “This is largely because we are not ready; we don’t have the training in place, or the guidance in place, and we don’t want a patchwork of approved SMSs, and then have to come back and try to collect them all,” he says. “It takes a long time to make a rule, and we want to make the right rule.” The ICAO document 9859 (Safety Management Manual) provides detailed guidance and standardization for implementing SMS, and is available free for download at www.icao.int.

In terms of recognition and approval of foreign operators, which was the primary concern regarding SMS at the Air Charter Safety Symposium, Arndt says as of now, an ICAO-approved or certified SMS is a misconception. “ICAO does not work with individual operators,” he says. “No one will get an ICAO-approved SMS because ICAO doesn’t do that.”
“In the U.S., we have SMS pilot projects in place and are working towards a formal voluntary system. Since we don’t have standards in place, we’re not imposing any restrictions on other countries based on the lack of an SMS. Foreign countries don’t have standards for their own operators, and they are not likely at this time to put requirements on us; we know of none that have so far.

“I have talked to Transport Canada officials on SMS and they have guaranteed us that at this time, they haven’t completed their standards and are in no position to put requirements or restrictions on other countries, particularly the U.S.

“You may have heard that you have to meet EASA (European Aviation Safety Agency) requirements for SMS; that cannot be true right now because EASA doesn’t have any requirements for SMS. An EASA representative has told us recently that they do not have restrictions on operators due to lack of an SMS, nor do any of their member states.”

Arendt insists that operators let him know if they do have problems with a foreign state due to lack of an SMS. He can be reached at FAA’s Flight Standards Service SMS Program Office, 703-661-0516; or by e-mail at don.arendt@faa.gov.