SMS: Pragmatic Needs for 3rd-Party Industry Standards
This business aviation blog post is part of a series on Safety Management Systems for business aviation.
In a previous post, we discussed the perceived need to implement a 3rd-party industry standard (e.g., International Standard for Business Aircraft Operations [IS-BAO], Air Charter Safety Foundation [ACSF], etc.) in order to implement a Safety Management System (SMS) effectively. Furthermore, we looked at the origin of the SMS requirement for International General Aviation in Annex VI, Part II, and the associated guidance found in ICAO Document 9859, 2nd Ed., and other state guidance material. Does the fact that operators can turn to this guidance for self-implementation of SMS render 3rd-party industry standards unnecessary? Not in the least. These standards, like ISO 9001, serve purposes ranging from the pragmatic to the idealistic through an overt commitment to higher standards and by raising the bar on performance. In this post, we will examine the association of SMS with 3rd-party industry standards and a few pragmatic reasons for implementation of those standards.
1. What are 3rd-party standards in terms of SMS?
Many of the 3rd-party standards used to assess aviation operations have an SMS requirement, which requires the audited entity to verify or prove that an SMS conforming to the said standard is in place or in some phase of implementation. It is important to note that while the operator’s SMS isn’t necessarily the sole focus of a 3rd-party standard audit, it certainly is, at the very least, a cornerstone of compliance. Even though many industry standards contain SMS requirements steeped in the ICAO guidance, they also contain other functional processes used to raise the level of quality, efficiency and safety in an operation. However, to come full circle, the SMS requirement, while not sufficient, is necessary for registration with the standard. The ACSF’s Industry Audit Standard (IAS) states its purpose as “…to advance on-demand charter and shared aircraft ownership industry standards and practices, and to promote the universal acceptance of safety management systems.” (Emphasis added by author). Additionally, the International Business Aviation Council (IBAC)’s IS-BAO states, “While the IS-BAO has been developed primarily to establish a common international standard for business aircraft and helicopter operations, it has an operator’s safety management system as its cornerstone.” (Emphasis added by author). Therefore, while 3rd-party audit standards address an array of functional areas in the operation, the SMS requirement is still necessary, and the operator must show conformance to this requirement for audit success.
2. What’s the pragmatic need – from the operator’s perspective – with respect to SMS and 3rd-party standards?
So, the question, “What is the payoff for purchasing and implementing an industry standard?,” may be burning in your mind. Pragmatically, it may simply be the addition to the registry list and the prized certificate of registration received for successful completion. In today’s “Who’s doing what with SMS regulation?” atmosphere, this prize may be the ticket for effortless entry into states that are actively enforcing the ICAO Annex VI, Part II, requirement. The United States Federal Aviation Administration (FAA), in Information for Operators (InFO) 11010, states under Annex VI, Part II, there is no responsibility for the state to accept or approve general aviation (GA) operators’ SMSs, and the operator must take responsibility for compliance with the ICAO requirement. Furthermore, InFO 11010 suggests a handful of 3rd-party industry audit systems to validate the SMS. It is interesting to note that in this InFO, the FAA suggests its own AC 120-92A for assistance in designing an operator’s SMS; however, it also states, “…the FAA does not accept or approve the implementation or continued operational performance of any operator’s SMS.” Therefore, for verifiable proof of SMS implementation, the operator must turn to one of the listed 3rd-party industry standards for verification.
Another benefit, pragmatically speaking, of some of these 3rd-party industry standards is facilitating SMS implementation through guidance that is more digestible and comprehensible. This is done through making the ICAO guidance more operationally relevant while still adhering to the performance expectations of the ICAO SMS model. For example, IS-BAO states, “The Safety Management Systems (SMS) standards set out in Chapter 3 are, in particular, consistent with the ICAO SMS Framework.” The ICAO framework to which IS-BAO text alludes is the infamous “Document 9859,” now going into its third edition. It is important to remember that the ICAO guidance is written to provide a theoretical foundation for SMS across a range of operator types. This means ICAO had to write guidance that would be usable by not only business aviation operators, but also the largest of airlines and the smallest of air tourism operators. Needless to say, specificity was not a luxury afforded to ICAO when drafting this document. Enter 3rd-party audit organizations, who can take some of the ambiguity out of the ICAO source and make it more relevant to operational reality, and you have an SMS standard that is more concise, easier to comprehend and, ultimately, more likely to be used.
Finally, pragmatically speaking, registration with one of these IASs can provide customers, including aircraft primaries, with a sense of assurance that the implementing organization is absolutely committed to safety and quality above and beyond the minimum regulatory standard. What is the end result? For charter companies, the registration could serve as a marketing tool to increase traffic. For corporate flight departments, according to IBAC, “Employees flying on company aircraft will benefit from knowing that the flight department meets professional safety standards.” Overall, the potential benefits for all segments also include a favorable light cast on the operation in terms of state regulators and insurance companies.
The perception that an operation has to purchase and/or implement a 3rd-party industry standard in order to effectively implement SMS is more common than not, leading one to believe that SMS is a proprietary product of one of those standards. However, as discussed in the last blog, SMS implementation guidance is available devoid of any industry standard through ICAO and other state guidance. However, there may be pragmatic benefits realized from implementing any one of these standards.
Later, we will examine some of the idealistic benefits of implementing a 3rd-party industry standard, as well as how to discern the ideal standard.
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