In 2016, the FAA published a Supplemental Notice of Proposed Rulemaking (SNPRM) proposing an SMS requirement of certain certificated airports. Under the proposal, these airports would develop and implement processes and procedures to proactively identify hazards and mitigate unacceptable risk. In addition to safety risk assessment and management, the proposal would require these airports to also deploy confidential hazard reporting systems, provide training and orientation programs, and offer enhanced safety communications. Together, these elements form the building blocks to support an organizational culture that values safe practices.
According to Marcia Adams, a spokesperson for the FAA, a Safety Management System (SMS) is the formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of safety risk controls. It includes systematic procedures, practices, and policies for the management of safety risk.
“SMS is becoming a standard throughout the aviation industry worldwide,” she said. “It is recognized by the International Civil Aviation Organization (ICAO), civil aviation authorities, airlines, airports, and air traffic service providers as the next step in the evolution of safety in aviation. SMS is also becoming a standard for the management of safety beyond aviation.”
Ken Ibold, national SMS discipline Lead for RS&H and an airport planner said nearly 300 airports in the country may fall under this requirement.
“This is all about making safety a standard part of airport operations,” said Ibold. “Airports are already highly regulated and are extremely safe environments. But the goal of the FAA programs is to anticipate safety challenges before an accident happens rather than react to an accident by altering processes in order to not let them happen again.”
He said Part 139 Airport Operators will be required to update their Airport
Certification Manual to address the elements of Safety Policy, Safety Risk Assessment, Safety Assurance and Safety Promotion for operations within the movement and non-movement areas of the airport. Ibold likes the mandate because of its business-like approach to managing risk.
“An SMS plan is intended to not only reduce the probability of aircraft accidents/incidents on the airfield, but also help protect workers, passengers and visitors by creating a culture that values safe practices,” Ibold said. “It can be designed to integrate into the safety programs that airports may already have in place.”
Ibold said that SMS practices have long been present among other industries and has helped companies identify safety hazards before they lead to injury or damage.
“The International Civil Aviation Organization, (ICAO) the international version of FAA has been working on SMS since 2004,” he said. “Because the U.S. is a member state of ICAO, it has to follow their standards. Thus, the U.S. is compelled to implement SMS.”
Although Ibold believes the FAA mandate is a worthy endeavor, he said the difficulty will be meeting the requirements of the new rule while not sacrificing efficiency at the airports.
“The rules only say what you have to achieve but not how,” he said. “It will be up to the airport as to decide what processes and operations to put in place to meet the FAA rule. Every airport is different in terms of its operational environment. As a result there is so much variance it would be impossible to create a uniform template that addresses the safety concerns of every airport.”
Ibold said the FAA is aware of that challenge and has chosen to prescribe a methodology to address airport safety issues rather than develop a “one size fits all” plan.
“That strategy will mean that SMS will be individualized by each airport to address its own unique needs,” he said.
Some airports, such as Portland International, are already out in front of the SMS rules. According to Danny Garcia, senior manager, airside operations for Port of Portland, Portland International Airport, SMS has been on his radar for some time. He said that PDX has worked diligently over the last five years on safety risk management and its operational impact in order to capture both air traffic organization and airport requirements of the FAA rule. “We are now having to document and demonstrate it administratively, but we have always done the work,” Garcia said.
Still, he said that there are so many aspects to what the FAA is trying to regulate each airport will be a remarkably unique challenge.
“The difficulty will be making a rule that applies to each airport’s individual environment,” said Garcia. “The rule will have to be broad in nature so that each airport can have find out what works for them.”
Garcia said that establishing a timeline will be virtually impossible as his airport and he could never fully implement an SMS in 36 months as it will require changes to the airport’s management and organization structure.
“I appreciate that the FAA is shifting to a different format of a compliance structure that allows me to determine how to best comply rather than give us a straight rules-based specific methodology,” he said. “This gives me more latitude and at the same time more responsibility.”
Garcia believes it is the logical evolution of airport operations to take on more responsibility for regulations.
“It is a good business practice to have the right equipment and the right staff in place for safety,” he said. ”I think the challenge will be demonstrating to the inspector that we have all these processes operating now.”
For Ibold and others in the industry, the question is how the FAA will implement the new rules. Ibold said a previous FAA initiative, FAA order 5200.11, which addressed airfield construction projects, was originally issued with an effective date then amended to phase in over four years with a schedule contingent on airport size.
“The greater uncertainly will be how the FAA phases in implementation and to what degree,” he ask. “Will the schedule require larger airports to implement first followed by smaller ones?”
According to Adams, that will all be worked out over the next 16 months.
“The FAA is implementing the principles of SMS both internally and externally,” she said. “Externally we’ve supported numerous pilot studies to develop and implement SMS, participated in industry research including projects by the Transportation Research Board’s Airports Cooperative Research Program, and developed the SNPRM. The SNPRM comment period closed on September 12, 2016. The agency now has 16 months to adjudicate the comments and determine whether it will pursue a final rule.”
David Fleet, director of consulting of Faith Group in St. Louis, believes the new regulations provide an opportunity for airports to derive more value from their operations.
“So often airports look to the do the minimum to be in compliance,” he said. “SMS can serve as a proactive business management practice not only with the implementation of the new FAA rule, but also for the entire operation.”
Fleet believes the four components of SMS – safety policy, safety risk management, safety assurance, and safety promotion, are very much needed in the industry.
He said SMS is a proactive way to manage the airport because it creates the triggers that better enable you to use risk assessment. An example, he said, is an airport getting larger aircraft. Risk assessment provided by an SMS will help Operations understand what the impact will be on adjacent gates, vehicle service roads, aircraft taxi routes, as well as any impact it may have on the ARFF index.
“Overall, SMS allows you to better assess risk while encouraging the use of inspections because now you have the plans to make corrections,” Fleet said. “Proactive decisions are based on leading/lagging indicators that point to better training and orientation on safety hazards.”
“The FAA traditionally has been a reactionary agency,” Fleet said, “making regulations to events that have occurred already. This allows them to get in front of the risk curve.”
According to Fleet there were 31 airports that went through SMS pilot programs. He said that the FAA has done a good job of exploring the potential impact of the new regulations.
“The airports that were selected for the studies indicate that SMS will deliver favorable results to them,” he said, adding he also thinks that it is advantageous that the Advisory Circular and proposed rule will leave it to the airports as to how they will develop their individual SMS.
Ibold believes many airports will want to seek outside guidance on the SMS implementation from selected experts because the new rules will not include the FAA’s usual step-by-step requirements.
“There are not a lot of people who know how to do this and eventually the knowledge will catch up to the demand,” Ibold said. “Consultants will need to examine the airport’s current processes and figure out how those processes how do they already fulfill some of the requirement of SMS. Then they can turn their efforts to fill in the gaps.”
Fleet adds that airports will need proper training, more open communication, integrated technology systems and incentive programs to make SMS work, contributions he sees coming from the consulting community as well.
Regardless of where airports are in the development of their native SMS, both Ibold and Fleet believe implementation of the new rule with its guidance tools and periodic evaluations to ensure continued will go a long way to making airports even safer.
“This will make safety an on-going priority.”
