Today, Federal Aviation Administration (FAA) principal inspectors use different tools to conduct oversight, surveillance and certification of each Code of Federal Regulations (CFR) Part. For example, FAA Part 121 certificate management teams use the Air Transportation Oversight System (ATOS) while other Parts use tools like Surveillance and Evaluation Program (SEP) or National Program Guidelines (NPG).

In 2013, the FAA will perform surveillance and certification functions for Parts 121, 135, and 145 (and eventually all other Parts) using the same system: Safety Assurance System or SAS. The FAA SAS is being designed to keep the best of what works today (for example, Design Assessments and Performance Assessments) and enhance areas that need improvement.

The FAA's SAS is based on five concepts and key points:

Five SAS Concepts

1. The System Model - Describe all of the different functions a certificate holder could perform and include the Master List of Functions and associated Specific Regulatory Requirements (SRRs).
2. National Safety Analysis - Identify hazards and evaluate associated risks and risk controls at a national level.
3. Planning & Resource Allocation - Support FAA managers and supervisors in assigning resources to data collection activities based on oversight priority.
4. Data Collection Activities - Support FAA inspectors in conducting inspection and surveillance of certificate holder's design and performance.
5. Analysis, Assessment & Action - Support principal inspectors (PIs) in determining the adequacy of the certificate holder's design and the effectiveness of their performance and help PIs select the appropriate actions to be taken.

Five Key Points

1. The FAA SAS will standardize oversight of 14 CFR Parts 121, 135, and 145 certificate holders in accordance with FAA AVS (Aviation Safety) Office Safety Management System (SMS) requirements.
2. The SAS will tailor oversight to the size and complexity of each certificate holder.
3. The SAS will prioritize inspection tasks based on oversight priorities at the certificate holder and national level.
4. The SAS will allow the FAA to consolidate and analyze data at a national level in order to identify areas of greatest oversight priority.
5. The SAS will be deployed in 2013 for 14 CFR Parts 121, 135, and 145; Flight Standards employees will be provided training appropriate to their position.

The FAA SAS will accommodate and manage the differences in the Operators (Parts 121, 135 and 145) and even within the individual Parts scaling oversight with the understanding that one size will not fit all. It will allow the FAA to target resources to the areas with the most risk.

FAA inspectors will continue to conduct certification and surveillance activities to assure certificate holders comply with regulations and manage risk effectively. However, SAS offers the ability to share data, collaborate, and integrate voluntary programs such as internal evaluation and aviation safety action programs.

Under SAS the FAA will use two types of Data Collection Tools (DCT), or questions, similar to the ATOS Safety Attribute Inspection (SAI) and Element Performance inspection (EPI):

Design Assessments - Look at how a certificate holder is set up to address risk and comply with regulations.

Performance Assessments - Look at how well a certificate holder is actually performing, and doing what they say they will do (in their policies, for example).

With the pending SMS rule for Part 121 operators and eventually other Parts, the FAA will use the Design Assessment and Performance Assessment to evaluate a certificate holder¥s ability to manage its own SMS in accordance with regulatory requirements and safety standards. The relationship between SAS and SMS is depicted below:

SMS Rule and Recommended Approach

Air Carriers can expect that the Federal Aviation Administration (FAA) will most likely publish a Safety Management System (SMS) Final rule (FR) for Part 121 operators by October 2012. You can also expect that the FR will not vary very much, if at all, from what was published in the Proposed Rule and FAA Advisory Circular (AC) 120-92A.

Smart money says operators should start the SMS process now and not wait for the FR to be published.

In a related note, new entrant Air Carriers seeking a Part 121 operating certificate should be prepared to include SMS as part of their certificate package even before the SMS FR is published.

One of the most effective ways to implement an SMS from a results or safety payback and cost perspective is to launch your SMS with three simultaneous activities.

1. SMS implementation support
2. Compiling SMS manual content
3. Launching and integrating an SMS reporting and management application

The benefit of this approach to is:

1. It saves money by delivering a total SMS solution, sooner.
2. It enables the organization to be fully compliant with the proposed Air Carrier or Airport SMS rule and FAA SMS Airport AC ahead of schedule.
3. It will improve safety. By enabling SMS reporting for your employees and staff sooner, it will allow you to collect data, conduct risk management and implement mitigation strategies within several months of starting the SMS project, which will prevent recurring safety events and save resources and money.
4. Your staff becomes familiar with the SMS reporting and management application from the onset of the SMS implementation and in turn becomes more confident and capable in the overall program.
5. The SMS manual becomes a living document that is developed and updated throughout the process.

Some SMS Essentials

Safety Management System (SMS) Manual, whether it is a standalone document or part of a General Operations Manual (GOM) or an Airport Certification Manual (ACM), is the cornerstone for your entire SMS program. Like your operational manual, such as the GOM, the SMS manual should contain the specific design attributes of: responsibility, authority, procedures, controls, process measures and interfaces.

Safety Policy serves as the foundation upon which operational and safety standards and principles are based and used for other documents to reference in relating operational components to the organization's strategic and safety plans and goals.

Policy also establishes required processes, expected level of performance, and the authority under which they are conducted. Many organizations possess policies and procedures addressing their aviation operations yet quite often other organizations see it differently and would lead one to assume that they are essentially a "paper program" or nothing more than a policy manual. Most often this comes out in aviation mishap investigations. Citing or simply stating a requirement in an FAA document doesn't ensure that it is actually taking place.

Auditing is an essential process to ensure your organization is actually doing what it said it was going to do. Perhaps a more acceptable word might be "evaluation." Audits/evaluations uncover what really happened as a result of activities and also alleviate fears about revealing failures. Failures represent vital learning opportunities and good managers should use these "events" as training tools to help prevent future repeat events. Audits and assessment activities can be tailored to meet organizational needs ñ in other words, it doesn't need to be painful as they can be performed internally or by an external third party. Regardless of how you perform your SMS Safety Assurance audits, they are an essential component of a robust SMS that ensures the SMS is living up to standards. Evaluations are used to determine effectiveness and are not a "magic 8 ball" that can tell you what to do. The outcome of any audit is essential information that must be effectively communicated and implemented in order for improvements to become reality.

Safety Promotion encompasses the channels used to communicate your safety program. People are most successful if they're provided information that is accurate, clear, concise, and actionable. Besides keeping employees engaged in your SMS program, it is one of the best ways to show management commitment to SMS and help bolster a positive and strong safety culture.