To Do or Not To Do?

Recently I attended an NBAA Maintenance Managers meeting. One of the subjects on the agenda was SMS or safety management systems. As this is a fairly recent subject in aviation's regulatory world, I attended the meeting to see what's new, if anything. The presentation was made by John Davisson of SMS4Aviation LLC. Some of what follows is from this seminar.

ICAO initiative
SMS is the result of an ICAO initiative to standardize aviation safety throughout the world. One can clearly see the benefits associated with this, although I, for one, do not think regulations create a safe environment; rather actual safety better stems from an established culture within an organization. Although member countries were required to have implemented SMS by January of this year most are noncompliant, including the U.S. Currently the FAA considers SMS programs voluntary, with the expectation that this will be regulated in the next three years. This is where the "to do or not to do" comes in.

With ICAO document 9859 mandated and FAA A/C 120-92 a prospect, aviation safety management systems may no longer be an option. Currently Canada, Australia, many European countries, and New Zealand mandate SMS, or are in the process of doing so. And the new ICAO Annex 6, Part II provisions will direct business operators flying internationally to meet SMS standards by mid-November 2010.

Countries taking it seriously
Our northern neighbor and overseas countries are serious about this. Take France. Five years ago it created a safety oversight directorate (DCS) responsible for air safety and security and overseeing all civil aviation stakeholders. In order to better harmonize and standardize working methods, it further formed the civil aviation safety directorate, (DSAC) fully responsible for the entire safety domain, from regulations to field activities, of civil aviation in France. Those familiar with French regulatory bodies will recognize the DGAC as having those powers. This new body has concurrent powers and, in a perfect world, they are supposed to work together.

In 2008 the DSAC performed 7,721 oversight inspections relating to activities of maintenance personnel.

I bring this up because all ops, 121, 135, and 91 operators, operating aircraft above 12,500 pounds will have to have an SMS if they are to operate in an SMS established country. If there is an incident or accident in one of these countries, while not certain, it may be possible the operator will be in violation for not having an SMS.

Not just flight operations
Simply, the purpose of SMS is to identify and mitigate safety risks. Its goal is to promote continuous improvement, and build on the existing safety culture within a flight organization. This is not exclusive to the flight end of an operation. Rather it is supposed to permeate throughout the organization, including maintenance. In fact, it has been put forth that a maintenance director would make an excellent safety officer because of his or her attention to detail and overall knowledge of the operation.

Two important considerations should be noted: SMS will not prevent accidents. Only a positive, fully imbedded safety culture will.

If you have an implemented SMS policy and have an occurrence you are more likely to violate a provision of insurance coverage, thus more liability. This does not seem right, but when you think about it and how insurance works, I think you will agree.

So, as you can see, there are reasons to do an SMS and reasons to hold off on doing it. Hopefully this sheds some light on the subject and points you in the right direction.

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