Safety Management Systems are coming to Part 135. Are you ready?

The United Nations International Civil Aviation Organization (ICAO) organization required member states to make implementation of a Safety Management System (SMS) mandatory for certificate holders by the end of the year 2008. Several countries, notably the United States, have filed a “difference” from the ICAO requirement indicating they will not comply with the directive by the required time. The FAA has initiated rulemaking to address the directive through the advanced notice of rulemaking (ANPRM).

 The approach is intended to solicit feedback from operators as to the impact of the time and expense of implementing a SMS. The next step to make the “SMS rule” a reality is for the FAA to establish an Aviation Rulemaking Committee (ARC), composed aviation industry representatives and the FAA to provide guidance on how the new rule would be written and the implementation process.

In parallel with the rulemaking effort, the FAA has created a SMS Focus Group to study and evaluate the implementation efforts required to enable a SMS within a certified operator. The Focus group consists of industry representatives from Part 121, Part 135, Part 145, airports and interested parties. Both NATA and the Air Charter Safety Foundation (ACSF) are actively participating in the SMS working group. The group is taking lessons learned from voluntary implementation of SMS to hopefully result in a more practical regulation and implementation process.

All in all we are making great strides towards a SMS rule sometime in the 2012/2013 timeframe. While there will be an implementation guideline providing certificate holders an window to implement, our studies have shown that an evolutionary adoption of an SMS can take 3-5 years. Your should be making steps forward today to create the building blocks for the upcoming mandate to not get behind the curve when the it comes into force.

While many organizations perceive the SMS mandate to be an additional cost of regulation, experience indicates that there is real economic value in getting started today. Our customers have seen increased dispatch availability, better recognition of component failure resulting in cost savings, and greater revenue opportunity using system safety principles that have been the norm in Part 121 aviation for 15 years. They have also seen better relations with regulators and have been able to ensure that their documentation and processes meet or exceed the regulatory requirements

Tools are available right now to help you implement SMS in your organization. NATA Safety 1st has a structured program to assist in the development of an SMS, which includes a guidance manual, hands-on workshops, and monthly webcasts. ACSF event reporting and management software program and the newly developed ACSF Operator Standard and Audit Program that will help ensure your SMS conforms to FAA standards

We at ATP are working with carriers to create the building blocks to SMS through application of system safety principles in dispatch, CAMP and CASS programs, training and documentation. While we can anticipate the SMS rule, our approach is to use the ICAO mandate plus our experience in Part 121 response to FAA ATOS oversight and IATA Operational Safety Audit (IOSA) efforts.

There is money to be saved and improved business opportunity through improved performance by starting the SMS process today. Please contact us at www.atp.com or call me at +1 415 330 9502 to discuss how we can get you started at the right price and with the right tools.