ORLANDO – As airports and FAA begin to get their arms around the concept of a safety management system, the National Air Transportation Association has taken the lead in bringing SMS to airport-based
businesses. In late March, NATA held another of its Safety 1st
management system workshops, which incorporate risk management and safety as core values. Since its inception, the Safety 1st SMS
program has been a living document that has evolved with new regulations and user feedback. Not only can the NATA SMS program assist a company in enhancing its safety initiative, but with FAA’s insistence that it will comply with ICAO Annex 6 by January 2009, it could soon become mandatory.
NATA defines SMS as “a systematic, comprehensive program for the management of safety risks. The program integrates operations and technical systems with financial and human resource management for all activities related to aircraft ground operations.”
Further, NATA states that “for the first time aviation business will be able to measure safety and monitor improvements. SMS is a data driven, business approach to safety management.”
Taking a ‘work in progress’ approach to SMS helps the program evolve as needed in terms of a company’s particular safety needs as well as heeding the FAA’s call for safety management programs, says NATA. “When we wrote [the SMS], we knew there would be several renditions of it,” says Amy Koranda, NATA director of safety management.
SMS contains many documents that can be instrumental in establishing a company’s safety management system. If there’s an area that is particularly lacking, NATA asks users what they can be doing better. They can add or subtract parts of the program as they see necessary.
One of the key additions to the system has been the gap analysis survey. Currently consisting of 54 questions, the gap analysis survey asks safety managers to answer questions regarding a company’s current safety policies and to classify each risk category in terms of importance. For example, what are the immediate implications if the risk category is not included in the current safety program? Could non-compliance result in injury or death?
The survey helps a safety manager plan future initiatives by requiring a set target date for completing the corrective action and also indicating where — when completed — the written documentation will be located for future reference.
One feature that users have found particularly helpful is a reference guide to FAA Advisory Circular (AC) 120-92. The survey has a column for identifying which section of the FAA A.C. they are satisfying with the successful completion of each question. [Question 1: Is there a policy statement by top management that defines the safety goals of the company? Successful completion of this question in part satisfies section 4.2A of the Advisory Circular.]
Value to Part 135s
According to Russ Lawton, NATA director of safety and security, it’s beneficial for charter companies to start their SMS programs now, because FAA is eventually going to make it a requirement for all Part 135 operators. “The FAA said that they will comply with ICAO Annex 6 by January 2009,” Lawton says. “By people signing up with an SMS effort now, they will get out ahead of the curve. So when it becomes mandated by the FAA, they’ll already be working on it or have it in place.”
Comments NATA’s Koranda, “I was at the AEA [Aircraft Electronics Association] conference presenting the business side of SMS and the gentleman who got up to speak from the FAA said that we have a regulatory responsibility to mandate this by January 2009.”
Lawton suggests that the industry could see a Notice of Proposed Rulemaking (NPRM) as soon as early 2008 that will make it mandatory for anyone who holds an operator certificate. “I would suspect that in 2008 we would see an NPRM that would make it a requirement,” Lawton says. “What kind of a period it would be, I don’t know. Whether to have it implemented by 2010 or what, that is kind of being debated by FAA now.”
With Safety Management Systems gaining in popularity and talk of regulation by FAA, the program is not without its fair share of skepticism within the industry.
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