Aviation SMS – It’s not a “thing” you purchase
This post is part of a series on Safety Management Systems (SMS) for business aviation. If you are new to SMS, we recommend you first read our earlier articles, Understanding SMS Programs for Business Aviation, and SMS Implementation and Practical Considerations for Business Aviation Operators.
There are misconceptions in the business aviation industry regarding SMS requirements, how they can be met, and 3rd-party industry audit standards. SMS requirements have been set forth for aircraft operators in ICAO Annex VI, and guidance to meet these performance requirements have been provided in ICAO Document 9859, 2nd Ed. However, many of the details pertaining to these requirements may give the impression that one of these 3rd-party industry standards needs to be purchased and a registry audit completed in order to implement SMS in flight department operations. That is not always the case.
1. Understand ICAO standards and recommended practices re: SMS
The International Civil Aviation Organization develops and disseminates standards and recommended practices (SARPs) that are contained in 18 Annexes. Annex 6 specifically addresses the operation of aircraft. Annex 6, Part 1 deals with international commercial air transport, while Part 2 addresses international General Aviation (GA). For the scope of this article, we will focus on Annex 6, Part 2 Operations. In regard to SMS within this scope, the performance requirement resides in Chapter 3, Large and Turbojet Aeroplanes. This category of airplane is defined as “aeroplanes with a maximum certificated take-off mass exceeding 5700 kg [12,566 lbs.]” or “aeroplanes equipped with one or more turbojet engines.” In Chapter 3.3, paragraph 3.3.2, ICAO sets forth the requirement as simply “An operator shall establish and maintain a safety management system that is appropriate to the size and complexity of the operation.” And that is it.
Limited guidance is found if one reads a little further under sub-paragraph 184.108.40.206, which provides the following recommendations: “The safety management system should as a minimum include: a) a process to identify actual and potential safety hazards and assess the associated risks; b) a process to develop and implement remedial action necessary to maintain an acceptable level of safety; and c) provision for continuous monitoring and regular assessment of the appropriateness and effectiveness of safety management activities.” If the operator meets the performance recommendations of a-c, then ultimately, the requirement of paragraph 3.3.2 would be met.
2. ICAO requirements vs. 3rd-party audit standard requirements
As stated, the SMS requirements for GA large and turbojet aircraft operators are iterated in paragraph 3.3.2 of Annex 6, Part 2. This terse requirement does not clarify what the SMS is supposed to do, or even look like. Further information on performance requirements is found under the recommendation in the form of suggested processes and the expected outcomes of those processes. This still may not be enough guidance for an operator to establish and maintain an SMS. Therefore, ICAO has published the Safety Management Manual (ICAO Doc. 9859, 2nd Ed.), which contains very detailed and sometimes academic guidance on what the processes in an SMS look like and how they can be applied in an aviation service provider’s everyday work environment. The notion of the Four Components and 12 elements (FAA refers to them as the “Four Pillars”) is also found in this document, which helps an operator distinguish the functional objective of and collaboration between each sub-system (element) of the SMS. Regardless, many have found the guidance provided to be ethereal and more applicable to large scheduled operators with an abundance of resources.
Enter IS-BAO and other business aviation 3rd-party standards providers. These standards incorporate regulatory and industry best-practice guidance to implement in a service provider, in hopes of raising the proverbial “bar” on safety performance. Additionally, these 3rd-party standards may and usually do incorporate SMS requirements. However, the SMS guidance and performance requirements of these 3rdparties are all based on the guidance set forth by ICAO. These 3rd-party standards providers may have adjusted the guidance or scaled it down for business aviation operations, but it is still steeped in the ICAO guidance. For example, in Chapter 1 of the IS-BAO, it states, “The Safety Management Systems standards set out in Chapter 3 are, in particular, consistent with the ICAO SMS Framework.” Therefore, the information contained in the SMS standards of these 3rdparties is not particularly revealing, revolutionary, or even proprietary.
3. Meeting Performance Requirements
The question still remains “Do I need a 3rd-party standard to implement SMS?” The answer is a resounding “No.” SMS implementation could be done following the performance requirements of Annex 6 and the guidance offered by Document 9859. Furthermore, it could be said that no piece of software, or no “off-the-shelf” program, is needed for SMS implementation either. All that is needed is time, patience, and a clear understanding of SMS, the processes involved, and how the various processes coordinate to meet the aim of the SMS. Very little, especially for smaller operators, is needed in terms of extra supporting infrastructure and personnel. If the guidance found in Document 9859 for SMS implementation is not digestible, another source of information recommended would be Transport Canada’s TP 14135 “Safety Management Systems for Small Aviation Operations – A Practical Guide to Implementation.” Either of these sources is excellent for understanding SMS and implementing the required processes that are appropriate to the size and nature of your operation.
However, the challenge often comes up where there is a lack of time or personnel to dedicate to the task of learning and implementing SMS. This is where certain 3rd-party standards, programs, and consultants can help. If you seek outside help for your SMS implementation, make sure to stay engaged and active in the process so the deliverable is applicable to your operation. “One size fits all,” or better yet, “One business aviation size fits all” solutions can actually convolute and confuse what is supposed to be a seamless system in your operation.
Regardless of what solution you decide upon in your operation, there is no requirement to buy anything “SMS” to implement SMS. Certain solutions can save time and educate on SMS, but the bottom line is that SMS is not a “thing” to purchase, but rather a collection of practices, procedures, and beliefs to develop in your operation.
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