I have served as a Part 119 director of safety for multiple FAA Part 121 supplemental carriers. I recall asking myself the question, “Does my carrier really need to be part of a voluntary SMS program? We have enough safety measures in place already! We do not need another means for the FAA to come in and fine us.” We made a cursory effort at implementing a voluntary program at multiple carriers I was with, but it did not seem anyone was fully committed to implementing one.
The inevitable did happen, and the FAA announced they would move from a voluntary compliance program and require the Part 121 carriers to implement a fully functioning SMS program. We were informed if we did not comply by the deadline we would not be allowed to continue to operate. They had my attention and that of the other required management personnel.
So, what is an SMS? FAA Order 8000.369 says a 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.” I was a part of a management team at a start-up all-cargo carrier at the time. Reluctantly, I began preparing our carrier. In addition to completing the requirements for certifying an airline, we had the added pressure of certifying the airline with a fully functioning SMS in place. I had serious doubts if we could pull it off.
We began with a good gap analysis of what we already had in place as compared to the new 14 CFR Part 5 regulations. The FAA provides you with a gap analysis form to guide you through. Once we had that completed it was on to developing our implementation plan. This is the time to think through the timing and logistics needed to get your SMS program up and running. Someone once told me when discussing the beginnings of their SMS “You don’t know what you don’t know!” I found this to be the case for me. We dug in and broke it down, with the FAA’s help, and we were able to come up with a plan.
I began to see the true benefits of having a Safety Management System (SMS). Once I realized that an SMS was just an organized way of seeking out hazards and managing risks within my carrier, it all made sense. I had been overthinking and over-complicating SMS in my mind all along. One of the big keys was remembering that my carrier was not a Delta, American or United. I did not have the resources they did, but I didn’t need them because according to the FAA we could scale our SMS to the size of our operation.
With the guidance from our local FAA FSDO (Flight Standards District Offices) team, we put together an SMS that was acceptable to the FAA, allowing us to complete our certification. There were some frustrations along the way but in the end I became a believer in, and proponent of, the FAA’s 14 CFR Part 5 SMS program. Our local FAA inspectors were fair with us and I felt we were in a true partnership. In the end I wish I had put more effort into the voluntary SMS program when I had the chance.
What was the reason for my reluctance to start an SMS? For so long I, along with many others, felt the FAA’s compliance philosophy was the “Gotcha” mentality - catch us doing something wrong and fine us. I felt they did not want to get to the bottom of a safety problem and truly fix it. However, several things eventually changed my mind. “The proof is in the pudding” as they say. Ultimately, actions by my local FAA inspectors and statements by top management at the FAA won me over.
Former FAA Administrator Michael Huerta made a few statements regarding the FAA’s new compliance philosophy with the SMS program I saw in action with my local FAA inspectors. This statement has stuck with me through the years, so much so, I used it when I trained SMS at my past carriers. From an Aviation Today article dated October 6, 2015, former administrator Huerta stated “The FAA’s compliance philosophy helps the FAA and industry to use critical thinking to work smarter and more efficiently to get to the bottom of potential safety problems. It’s about finding a problem, fixing a problem, and making sure it stays fixed.” The article went on to say that “The FAA wants safe operators, not operators who inadvertently make a mistake and then hide it because they are afraid they will be punished.”
“What other proof do you have that the FAA’s new compliance philosophy with the SMS program works other than your own experience?” you may be asking. In the same Aviation Today article quoted previously, they used a statistic that is truly amazing. “Based on cooperation and trust, [the SMS program] encourages an open and transparent exchange of information and data between the FAA and industry. The Commercial Aviation Safety Team (CAST) successfully used this approach to reduce risk in U.S. commercial aviation by 83 percent over 10 years, according to the FAA.”
So, back to my original question, “Should your non-Part 121 operation start a voluntary SMS?” A resounding YES is my answer! No matter the size or type of your operation it really is as simple as “finding a problem, fixing a problem, and making sure it stays fixed”.
Remember, SMS is a regulatory requirement for U.S Part 121 carriers but still voluntary for Part 135s, MROs and Training Organizations. There is no time like the present! Baldwin Safety and Compliance is ready to assist you to take that next step towards completing the FAA Safety Management System Voluntary Program (SMSVP).
References:
FAA links to obtain a basic understanding of what an SMS is:
Aviation Today article: https://www.aviationtoday.com/2015/10/06/faas-compliance-philosophy-signals-safety-evolution/
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