To date, the FAA has only developed advisory circulars for air operators (AC-120-92) and airport operators (AC-150/5200-37) on the subject. There is also some initial direction for FAA personnel in Order 8000.369, Safety Management System Guidance.
The FAA has filed a "difference" with ICAO acknowledging that the United States is not compliant with the 2009 regulations launch date requirement, but will be spending much time in the coming months considering SMS regulations and promoting the Safety Management System. ICAO has advanced four key components, or pillars, of a Safety Management System:
Safety policy. All corporate management systems must define policies, procedures, and organizational structures to accomplish their goals.
Safety risk management. A formal system for detecting hazards and managing safety risk is essential to keep risk at an acceptable level.
Safety assurance. After safety controls are defined, the operator must ensure that they are enacted and continuously used and honed to be effective in a changing environment.
Safety promotion. Promote safety as a corporate core value with practices that support a sound safety culture.
SMS goals include: identification of safety hazards; the implementation of remedial action necessary to maintain agreed safety performance; continuous monitoring and regular assessment of the safety performance; and continuous improvement in the overall performance of the safety management system. It is through the interaction and support of all employees and managers that these goals can be achieved.
SMS requires a solid "culture of safety." As part of this culture, an SMS practicing entity must develop and maintain an environment of trust and accountability. Further, the organization-whether it is an airline, a repair station, or an airport administration-should designate a senior manager as the "safety czar" if you will. This person is ultimately responsible and accountable for all of the safety programs within that enterprise. SMS requires that this individual must have control of the dollars and be empowered to provide the funding needed to support the SMS program. A robust Safety Management System absolutely requires employee participation in all aspects of the operation, including access to a non-punitive system for reporting safety issues.
United Air Lines Capt. Linda Orlady is the Air Line Pilots Associations' SMS director. She says, "Movement toward an effective safety culture may require some groups to modify their perspectives. Organizations, regulators, and employees must realize that human beings all make unintentional errors. A non-punitive reporting system must be designed to provide a method of finding systematic procedures, processes, and infrastructure that contribute to human error."
Just as all the FAA's regulated entities must establish written company policies and procedures in general operations manuals, flight operations manuals, and training programs, ICAO-and, inevitably, the FAA-will require that a Safety Management System be documented in a manual of some sort.
The expectation is that any FAA-certificated enterprise will be required ultimately to have adopted an SMS once regulations are in place. This expectation will extend not only to those regulated by FAR parts 121, 135, 139, and 145 of the federal aviation regulations, but eventually to Part 91 operators of corporate jets. Training organizations operating under parts 141 and 142 may eventually be affected.
The idea of an SMS is a good one to embrace whether required by the FARs or not. A legitimate question arises: should flight schools, academies, and aviation colleges and universities adopt a formal SMS system for their operations? Not only would a training institution's adoption of SMS expose students to a new industry safety process that is to be the future gold standard, but adherence to a formal SMS that is understood by all can only enhance safety for that academic organization.
With SMS, "That's an accident waiting to happen," may be forever removed from aviation jargon.
Wayne Phillips is an airline transport pilot with Boeing 737 and Falcon 20 type ratings. He is a B-737 instructor and operates the Airline Training Orientation Program at the Continental Airlines�Pilot Training Center�(www.b737.com). He is also a speaker for the AOPA Air Safety Foundation.
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