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The next step in improving aviation safety is to extend the SMS requirements in part 5 to additional organizations that play a critical role in the design, manufacturing, and operation of aircraft (i.e., part 119 certificate holders operating under part 135, Letter of Authorization (LOA) holders operating commercial air tours under § 91.147, and certain certificate holders under part 21).
These aviation organizations are in the best position to prevent future incidents and accidents because they are closest to the hazards, and they know the most about their operations.
The new regulation will incorporate AC120-92B as the SMS "standard" and generally follow part 121's part 5 to ensure standardization and conformity. The FAA will determine compliance to the regulation during onsite inspections.
The SMS can take up to 1380 hours to implement the basic SMS framework according to the FAA when done in-house with existing staff. In other words, the SMS represents a significant project management challenge, one that requires experience and a very specific skill-set to ensure conformity to the standard and more importantly, that you benefit from SMS.
Most small to medium sized flight departments, airports and maintenance providers have staffing constraints, and that means SMS planning and implementation will be highly disruptive to normal operations. And, once implemented, the SMS will likely be managed as a part time endeavor and as an ancillary role to existing responsibilities, which tends to increase workload, lowers morale and raises risks, just a few of the many challenges facing aviation service providers.
The major challenge facing part 135 is the same one facing part's 91 and 139, staffing constraints. Small operators typically manage their SMS on a part time basis and as an ancillary role, which impacts workload and ensures an underperforming program.
From hundreds of audits, we've learned most operators are not fully benefiting from their programs for several reasons:
1. Staffing constraints
2. SMS managed Part time and as ancillary role
3. Low participation from personnel
4. Inadequate training
5. Lack of resources
6. Lack of leadership
Since 2006, our approach has been to fully train all personnel before starting the SMS implementation process. Since SMS requires an established safety culture, providing the big picture early on ensures the operator is culturally prepared for SMS.
Implementing the framework does not need to be disruptive and distracting to normal operations so we recommend operators move quickly to establish that framework and start the training process early. Our Typical time frame for SMS framework implementation is 125 to 140 hours with 3 to 5 days onsite.
Once we complete your project, you are officially at the "starting line", which is where the real work begins. With our guidance and training, you are well on your way to achieving a robust and effective SMS that conforms to the SMS standard, while complying with the regulation. And, we will even provide you management support for 12-months so you can learn how to manage your SMS in-house with your existing team.
PART 91. Since 2006, corporate flight departments with international exposure have been required to implement an SMS per the ICAO SMS mandate. Some operators chose to pursue a quality management program such as the ISBAO, while the majority pursued a stand-a-lone SMS solution. Fast forward to today and many operators are now looking for SMS support that ensures standard conformity, but more importantly, ways to fully benefit from their programs.
For new operators looking to adopt SMS, we provide a fully conforming SMS that meets all industry standards and ICAO requirements in about 3-days. As part of that process, we provide training and 12 months of professional management, that once you see how cost effective it is, you'll likely stay in the program.
PART 139. The FAA publication date for the SMS final rule was February 17, 2023 and applies initially to 268 airports within the NPIAS. The other 276 airports will eventually voluntarily adopt the program over time, as the SMS becomes the industry standard.
We have a broad range of options for airports, from initial implementation planning, manuals and training, to turn key implementations, conformity audits and everything in between. Call or email us today for a detailed proposal.
PART 145. For MRO's, adopting and integrating the SMS standard into your operation should be easy if you already have a QMS such as ISO 9001 or the 9100 standard.
If you are starting from scratch, plan on a significant project that will take 1 to 3 years to fully adopt should you decide to "self-implement". In that case, we recommend you contract the initial implementation to phase 2 of the FAA maturity ladder, and then take over at that point.
You will want to avoid the disruption and distraction that is typical in the early stages of the SMS implementation process. We have a program that meets that goal and can be accomplished in roughly 10-14 days. For more information and a detailed proposal, call or email us anytime.
I retired from my flying career in 2004 and spent the next two years as an apprentice working for a company that specialized in SMS, QMS and EMS program implementations.
Since 2006, I've done hundreds of SMS implementations and confirmation of conformity audits and continue to provide SMS management support services to dozens of flight departments.
While, I have experienced SME partners I can call on when needed, for the most part my primary partner is the customer, who knows their operation better than anyone. My goal is to make your transition to SMS a simple process that is affordable.
John Davisson
Owner