You all probably missed this but it will impact the whole business of aviation in the very near future. What is it? Well, it is a proposed new safety program called the Safety Management System (SMS).
As if we don’t have enough safety paperwork programs to burden our beleaguered industry, it looks like the paper-pushers at 800 Independence are now in the process of proposing a new one. They have published an advance notice of proposed rulemaking that we all know is the prelude to another rule making requiring something to be done.
It all started with the International Civil Aircraft Organization (ICAO) ginning up a broad mandate requiring all the members of the organization to establish a safety management system. The ICAO people say they require that member states establish such a safety management system by November of 2010. (And to think the member states pay to belong to this club!).Where does ICAO, a high class international social organization of sorts, get off demanding that huge sums of money be spent unnecessarily on such a safety management system? Why don’t the members object to this nonsense? And why does our FAA seem hell bent on following their lead down another rocky road of so-called aviation safety? To its credit, the FAA has filed a sort of objection called a “difference” or statement of noncompliance … whatever that means, while it works on a new safety rule. Why should it work on anything that ICAO requires? As far as I can determine ICAO merely suggests things to its members, it has no statutory authority.
Suffice it to say that our FAA is busy at work proposing to follow ICAO’s so-called mandate, (I don’t believe it’s even mandatory for the members as ICAO suggests) … notwithstanding the fact that we (FAA) already have numerous safety management systems already in place within our industry. Some are voluntary and some mandatory and some are private activities.
Not to be outdone by the foreign interests, our FAA will be busy following their lead so as not to be left out of this bureaucratic exercise, producing more paperwork, probably with a need for more inspectors to supervise this activity. We all know they don’t have the ability to supervise all the programs they already have and they admit it! We will need more front line inspectors to supervise and audit any new safety system and we don’t have enough to do the job now. No hiring is being done in the inspector area.
Now understand, this new safety system will be no small effort. If implemented by our busy FAA office of Aviation Safety, the detail and management labor will be substantial and necessitate a whole new internal effort on the part of not only FAR 121, 135, 125, and 91.1001 air carriers, but will include other certificate holders like FAR 141, 142, and 145 operations. In addition, others included are OEM aviation product manufacturers, applicants and employers, and product or service providers. Just about everybody in the game!
I don’t believe the mandate of the ICAO should extend to and include such product and service providers in our industry. These people have enough to do just keeping up with the existing FAA requirements. This is an aircraft club not some international type of FAA … or maybe that’s the point? EASA (European FAA for those in Rio Linda) is bad enough as it continues to grow in staff, regulations, and influence around the world. I have long predicted that EASA would take over our own FAA sometime or other. I may have to substitute ICAO in its place. If you want to see what ICAO is about Google it.
The new SMS
ICAO’s definition of SMS is: “A systematic approach to managing safety, including the necessary organizational structures, accountabilities, policies, and procedures.” — ICAO Safety
FAA goes on to say that an SMS provides a set of decision-making processes and procedures that a product/service provider would use to plan, organize, direct, and control its business activities in a manner that enhances safety and ensures compliance with regulatory standards.
SMS is a very sophisticated data gathering activity, in the general areas of flight operations, maintenance, certified repair stations, human factors, and communications.
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