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The Safety Management System was originally designed for large manufacturing companies that typically had safety departments in place, so the transition to SMS protocols and procedures was relatively simple. When ICAO issued the SMS mandate in 2006 for specific aviation service providers, (airlines, airports and aircraft manufacturers) that group also had well established safety cultures, which should have made the move to SMS also relatively simple.
Unfortunately, SMS implementation for the airlines, airports and manufacturers was deferred and delayed, while the FAA figured out the best way to regulate the SMS. Part 121 finally received their regulation in 2015, airports in 2023 and part 21 manufacturers, part 135 and 91.147 operators not getting their regulation until 2024 with the expectation of full implementation being a 3 year process.
Not surprisingly, it was part 91 corporate operators who fly internationally, who were early SMS adopters out of necessity because ICAO member states (193) made it clear at the time, they would enforce the new mandate regardless of an FAA regulation. That is when we began planning and implementing SMS programs specifically for corporate flight departments, which are fundamentally identical to SMS for larger operators such as airports and airlines with the main difference being the physical size of the operation, the number of hazards identified and the number of employees needing to be trained.
After nearly 20 years of planning and implementing SMS, the results have been mixed, with some departments doing better than others in terms of utilization and achieving the goals of the program. The vast majority of small to medium sized part 91 flight departments and many part 139 airports are minimally staffed, which means their SMS is managed as an ancillary role on a part time basis, guaranteeing low data collection and analysis, which limits the overall value of the SMS.
The solution for small operators is to radically simplify the SMS protocols, procedures and especially the reporting process, which requires a steady stream of data (FRAT/FOQA/SOR/KPI) and that requires full participation from all members of the staff. That data stream needs to occur each day, so it's important you digitize your forms and use smart phones as a primary reporting platform. That information is then sent directly to your on site SMS coordinator who will review, analyze and mitigate as needed. The entire process is documented, monitored and regularly reviewed to ensure the SMS is effective.
Your onsite SMS coordinator will then spend about one hour per day, reviewing, tracking, monitoring for trends and sharing that information with everybody. To chip away at complacency, you should also be sending out a safety bulletin monthly at a minimum and hold regular safety committee meetings, which can all be done in-house with the right team, but it does require some time and effort.
For those operators who needed assistance, we developed customized support programs that eliminated the time and effort required to achieve a successful SMS. That program includes the following deliverables:
1. Ensure SMS training for all personnel (initial and recurrent)
2. Establish a reporting platform (smartphone)
3. Digitize SMS form to include, FRAT, FOQA, SOR, KPI, AAR
4. Send out a weekly Safety Officer Bulletin (SOB)
5. Schedule safety committee meetings quarterly and review
6. Investigate all Safety Occurrence Reports* and determine root cause
7. Generate corrective action, reports, recommendations as required
8. Liaison with onsite SMS-M to ensure compliance and effectiveness
9. Gatekeeper for department's ASAP when implemented
10. Provide quarterly IEP protocols and can perform annual SPA on request
* SOR includes SOP deviations, near hits, errors, suggestions, concerns, etc...
That's what a professionally managed SMS looks like and it really is a full time job.
As you can see, to fully benefit from an effective SMS you'll need to work at it, which means somebody in your organization will need some specialized training and the desire to build your program. The problem for most operators has always been data collection, generating reports and getting full participation, which can be a full time job. For the regulated groups (121, 135, 139, 21, 91.147), SMS is a full time job, which is why we have developed support options that remove the time consuming aspects of generating reports, corrective actions, investigations, training and other administrative requirements.
Being a small family owned and operated business allows us to provide robust SMS options at about one third the cost of other providers. Our experience in flight and maintenance operations coupled with SMS training and hands on experience, means we have a unique perspective that translates into affordable options. Below is a list of SMS programs we can provide:
SMS Project Management- Designed for airports and larger flight departments, it takes us about 125 hours to implement your SMS framework, that technically gets you to the starting line.
SMS Self-implementation Program- Designed for operators who wish to self-implement SMS using their existing staff and need implementation guidance, manuals and initial SMS training.
SAFE Program- Designed for small to medium sized flight departments who have implemented SMS but need assistance with SMS administration, documentation and training.
SPA- The safety performance assessment provides confirmation of conformity to the SMS standard and assist you get the full benefit from your program.
Safety Officer Bulletins- This service provides weekly safety bulletins designed to chip away at complacency. The service also provides annual SMS recurrent training.
SMS Initial Training- This program is 16-hours onsite and includes specific SMS manager, internal auditor training.
As part of our programs, we provide SMS support for the life of your program and will always be available to answer your questions, provide training to your new employees and send you new SMS information as it comes out, no obligation and no cost.
We are always happy to talk with you to customize your program and ensure you get exactly what you need regarding SMS. We will send you a detailed description of each program and can provide an RFP on request as well as provide references.
TOP 5 AUDIT FINDINGS
From hundreds of conformity audits we've performed, we know most operators are not fully benefiting from their programs for the usual reasons:
1. Staffing constraints leads to a Part time effort
2. Low participation from personnel
3. Inadequate training
4. Lack of resources
5. Lack of leadership
To be clear, minimally staffed flight departments can have an effective program, but education is required and you will need to simplify the SMS processes such as:
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 outside of aviation.
Since 2006, I've completed hundreds of SMS implementations following AC120-92, 92A, 92B, as well as provide implementation plans to airports using AC150/5200-37A. Additionally, I have provided dozens of confirmation of conformity audits and QMS audits for part 91 and 135 operators. My team and I continue to provide SMS management support services to dozens of flight departments, provide initial and recurrent SMS training, SMS manager training, internal auditor training and CRM training.
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