SMS Implementation and Practical Considerations for Business Aviation Operators
This aviation blog post is part of a series on safety management systems for business aviation.
There’s no easy way to implement an effective Safety Management System (SMS) that will serve your organization well. However, an effective SMS can result in tangible and worthwhile benefits, such as enhanced operational safety and regulatory compliance. In any case, all operators will eventually have to meet SMS compliance in order to operate internationally when this International Civil Aviation Organization (ICAO) requirement becomes widely enforced by ICAO countries. Thankfully, resources are available to assist in implementation, and a 3rd-party provider can help with this process.
1. Being aware of SMS-related operational issues
You can be denied entry into an ICAO country if you do not have an active SMS program. For example, France is currently looking for an “approved SMS” from charter operators (when requesting permits). However, no U.S. operator can actually comply with this, as the Federal Aviation Administration (FAA) is not yet in the business of approving SMS programs. Also, Bermuda has been requesting evidence of SMS for private non-revenue operators. The problem is that there’s no real definition of what a fully mature SMS program looks like, and it’s difficult for anyone to gauge whether you have an effective SMS or not. So, non-compliance issues are hard to predict.
2. Considering SMS implementation options
Successful SMS implementation requires more than simply writing a manual: It also necessitates implementing it successfully in your company. Strategies to develop and implement SMS processes and procedures can be found in ICAO’s Safety Management Manual (Doc. 9859, 2nd Ed.) FAA AC 120-92A also provides SMS development guidance. In addition, several 3rd-party organizations, including the International Standard for Business Aircraft Operations (IS-BAO) and the Air Charter Safety Foundation, have developed materials that meet ICAO SMS standards.
3. Carrying evidence of SMS
Operators should determine what evidence of compliance is accepted in countries of intended operation. While you are not required to carry your SMS manual onboard your aircraft, some operators do this as a means of providing additional evidence of compliance. In practice, if you’re ramp-checked in the European Union, Bermuda or elsewhere, showing IS-BAO registration will protect you and should satisfy inspectors’ requests to prove SMS compliance. We haven’t encountered a case yet where providing evidence of IS-BAO certification did not satisfy inspection authorities.
4. Avoiding problems and “negative consequence” shortcuts
If you specify on a permit application that you’re SMS-compliant and are found otherwise during a ramp check, you’ll have some explaining to do. Opting for an “off-the-shelf” SMS program may get you past an auditor or regulator. However, this is definitely not the best option and may open you up to legal liability. If you have an accident, and there’s something in your SMS that you have not executed, it could be more dangerous legally than not having an SMS at all. Canned SMS programs may have deficiencies, and there can be significant problems with them, as they aren’t tailored to your operations.
5. Knowing the implications of SMS compliance going forward
While few countries currently enforce SMS (France and Bermuda being notable exceptions), the message is that SMS compliance will eventually apply to all operators of business aircraft. While SMS helps operators improve processes and operate more safely, there are also many practical operational reasons to become compliant, like controlling safety risks. Like Reduced Vertical Separation Minima (RVSM), SMS will eventually become a worldwide requirement, and you’ll need it to preserve international operating flexibility.
SMS will eventually become actively enforced worldwide. As with RVSM certification, if you don’t have it, you’ll be operationally restricted. Be proactive and prepare yourself for the SMS process before regulations begin to negatively impact your international mobility. Look at SMS from the perspective of the positive benefits it brings. As you plan your path forward on the SMS process, work with an experienced 3rd-party provider who can keep you up-to-date on current SMS enforcement issues, including potential operating challenges you may face worldwide.
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