At this time a safety management system created by an aviation service provider is still a voluntary program, applicable to airlines, repair facilities, and any other provider in the business, certificated or noncertificated. It is simply an amplified and detailed safety system that in an airline application covers many areas including but not limited to maintenance and flight operations. Below is how the NPRM defines what it is. If you work for any type of these service providers you are most certainly going to have to work with this kind of safety system and become familiar with how it works.
Besides setting out a way of doing business, what it really boils down to is a sophisticated data gathering activity, in the general areas of flight operations, maintenance, human factors, and communications. The theory is that by carefully analyzing data, problem areas can be defined and pinpointed and hopefully corrected before safety is compromised therefore preventing accidents. Designed to predict risk, it is also proposed and designed to share with other people.
The data to be collected is very important both to individuals and to the operator. How would it be collected, stored, and provided to other operators is a significant concern. At the same time, sharing of safety information is at the core of the SMS program. Most operators on the other hand have expressed reluctance to share their data. Why can’t this part of SMS be made voluntary by the participants?
Data gathering programs have been around in different forms for some time with different names. The legacy program was FAR 121.373 CAS or CASP, the Continuous Analysis and Surveillance Program. Mandated by regulation for all Part 121 and some 135 air carrier operations many years ago. One of its important features, among others, is the internal analysis of repeat discrepancy write-ups so that they can be analyzed, fixed, and not repeated, therefore enhancing safety. It is still a required process that all major airlines must follow and this data is available to the FAA.
You can only begin to wonder why we need so many safety programs and now another one. Also, of course we have Aviation Safety Action Plan or Partnership (ASAP), the Flight Operational Quality Assurance (FOQA) plan, and the big gun, the Air Transportation Oversight System (ATOS). These programs, like ASAP, gather data and do a good job of detecting problems that have already happened. The idea is to analyze them in order to avoid them in the future. SMS systems are designed to predict problems in advance. I would think that SMS will replace all of the old data gathering programs in time.
The FAA for the past 20 years or so has been seeking to saddle the industry with data gathering programs so that it can, among other things, look at them as a possible indicator of violations, and oh yes … to offer a safety system of sorts. The data only went to the FAA. … it was still proprietary for the most part.
There is little doubt that there is no way all the data can be analyzed by the current staff levels of the FAA in the AVR sections even with computer help. Perhaps by combining them into one SMS system they would focus the effort toward a more organized safety process. It could be made a simpler and more efficient regulatory mandate. Cancel CASS, ASAP, etc. and combine them all into SMS?
Brought to us by ICAO
Now, SMS comes along as the be-all-and-end-all safety program. We have to remember that this process was extracted and mandated to us by the International Civil Aviation Organization (ICAO), and of course our own Aviation Safety section of the FAA. EASA has recently published its proposed SMS rules for its repair stations. It becomes interesting to speculate how our domestic repair stations will cope with both EASA and FAA SMS rules … when the FAA finally gets around to publishing the rule.
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