BizAv Focus on Mandatory SMS

A major focal point at BASS 2023 was Safety Management Systems (SMSs) – and with very good reason. In January, the FAA issued a Notice of Proposed Rulemaking (NPRM) that would require all Part 135 certificate holders, Part 91.147 air tour operators and certain Part 21 Type Certificate and Production Certificate holders to implement a SMS – these industry segments would no longer be left to develop SMS program voluntarily.

In essence, these commercial aviation operators would be following the well-traveled path of Part 121 operators in terms of SMS implementation. Highlights of the BASS SMS session addressed the business aviation community’s efforts and strategy to more widely implement SMSs.

Collaborate and Maintain Current Efforts

The FAA has set down a marker in its policy commitment to expand SMS implementation through additional commercial aviation organizations. Panelist Doug Carr, Senior Vice President, Safety, Security, Sustainability and International Operations, National Business Aviation Association (NBAA), estimated this expanded FAA policy effort will add more than 2,500 operators to the organization’s oversight responsibilities. “This will be a significant workload increase for FAA,” he added.

Yet, Carr, his fellow panelists Sonnie Bates, Chief Executive Officer, Wyvern,

Paul ‘BJ’ Ransbury, Chief Executive Officer, Aviation Performance Solutions (APS), and session moderator Keith DeBerry, Chief Operating Officer, National Air Transportation Association (NATA), unanimously noted Part 135 certificate holders and other operators falling under this expanded policy outreach will successfully expand current SMSs and implement new systems as required.

“SMS is all about relationships,” Ransbury said, and added implementation is also about professionalism, working together, having conversations with your colleagues, and other strategies.

Bates added SMSs are complex, but presented a cogent case for these additional operators to fall under the FAA’s expanded SMS oversight. Noting that under current rules, safety culture assessment, voluntary reporting and other tenets of SMS “are working.” He then pointed to “what’s not working: total system safety; human factors analysis; safety culture survey and others.”

To the point that SMS implementation has been voluntary for non-121 operators, Carr pointed out there “has been real, voluntary progress over the last several decades. There has been FAA recognition that business aviation voluntary efforts have been good. This performance has put us on par with the rest of the world.”

Carr was among the session panelists who reminded this community “that one size does not fit all. Small operators do not equal large operators.” To encourage those operators requiring new or enhanced SMSs, it was suggested they reach out to subject matter experts at industry organizations, including Flight Safety Foundation, NBAA, HAI, FAA and others, for assistance. “Start small,” Ransbury added, and continued, “think about scalability. Make it work for you – a part 135 SMS does not equal American Airlines’ SMSs.”

Moderator DeBerry added several vital dynamics to the discussion on establishing or upgrading SMSs. While pointing out these operators first need to build and maintain a safety culture, he offered the imperative to consider returns on investment. SMSs are “something beyond safety. We have to invest in people.”