With the forthcoming publication of a final Safety Management System (SMS) rule for Part 121 carriers, operators should understand that there are interactions between the safety management efforts of the Federal Aviation Administration (FAA) and themselves. The interactions are intended to provide a more effective, efficient, and proactive approach to safety while providing flexibility to allow operators to modify SMS efforts to fit their business models. There are distinct SMS roles, responsibilities, and relationships for the FAA and the operators as outlined in the paragraphs below.

(1) Responsibilities of Certificated Operators and Aviation Service Providers. Part 121 Operators have a responsibility to provide their customers with safe, reliable transportation. Title 49 of the United States Code, states, "When issuing a certificate under this chapter, the Administrator shall consider the duty of an air carrier to provide service with the highest possible degree of safety in the public interest and differences between air transportation and other air commerce ." This makes management of safety a specific legal responsibility for air carriers and is a fundamental principle of the FAA oversight doctrine. While this section applies specifically to air carriers, the FAA expects all certificated organizations to make safety a top priority and holds their managements accountable for doing so.

(2) Oversight Responsibilities of the FAA. The FAA is responsible for developing and implementing regulations and standards and then ensuring operators apply those regulations and standards to their entire operation. The regulations and standards, along with the processes that apply them to operators from the very first day they are certificated, are important safety risk controls not bureaucratic requirements.

(3) Oversight Systems. The other system on the "protection" side of the model in Figure 1 is the Safety Management System-Oversight Organization (SMS-O), the system that is used by the regulator to provide oversight of the aviation service provider's operations. Traditional oversight of aviation service providers consists of activities such as certification, surveillance, investigation, and enforcement of regulations. The FAA is transitioning the traditional oversight process from a quality control approach with principle emphasis on surveillance of compliance with technical standards, to a systems approach that stresses the systemic nature of aviation businesses and the larger system as a whole. While traditional oversight functions will continue to exist in future safety oversight systems, the primary means of safety oversight will shift more toward system safety methods and an emphasis on operator safety management. Moreover, the ability of the government to provide the resources that would be required to manage safety through intensive direct intervention in aviation service provider's activities is questionable at best.

(4) Relationships between Aviation Service Provider's SMS and Oversight. Figure 1 depicts the functional relationships between the productive processes in aviation service provider organizations, their safety management functions, and the functions of FAA oversight activities. On the "protection" side of the model depicted in Figure 1, two management systems exist: the aviation service provider's SMS (noted as SMS-P) and that of the oversight organization or regulator (noted as SMS-O).

Figure 1. SYSTEM RELATIONSHIPS- CERTIFICATED OPERATORS
 

(5) Voluntary Programs and the SMS. The FAA wants to increase the use of voluntary programs, particularly use of the Aviation Safety Action Program (ASAP) and internal evaluation programs (IEP). Both of these programs have strong relationships to SMS safety assurance and safety promotion. Operators are being encouraged to integrate these programs into a comprehensive approach to safety management and we have seen evidence already that new entrant Part 121 operators are being asked to include these components now even though the SMS rule is not final.

SMS for Corporate Aviation Operators

The US aviation industry is undergoing revolutionary regulatory changes. Part 121 Commercial operators will soon be required to have a Safety Management System (SMS) with oversight by the FAA. While corporate aviation operators may have been spared from an FAA SMS rule near term, many Part 91 business operators have already learned international operations have necessitated that they have an SMS. If your company does not have an SMS, you are falling behind your colleagues in this very important safety area.

Why is SMS necessary? Notwithstanding the International Civil Aviaton Organization (ICAO) SMS requirements that have been mandated for all member States, having an SMS makes good business sense. Along with improving the overall safety culture of your operations, there is also the opportunity to limit liability exposure that, in turn, may reduce insurance premiums.

How can an operator demonstrate an effective SMS Program? The International Business Aviation Council (IBAC) established the International Standards for Business Aircraft Operators (IS-BAO) as one of the means to verify a company's SMS status. JDA offers IS-BAO Audit Services as part of our overall SMS program.

JDA Aviation Technology Solutions can assist in establishing an SMS customized to your company and its specific needs. We offer a full line of SMS products and solutions:

• SMS Manuals tailored to your company
• SMS Training for your personnel
• Safety Culture Assessments
• SMS Gap Analyses
• IS-BAO Audit Services
• Safety and Compliance Auditor Training

Each solution is custom tailored to your particular organization's needs and provides your employees with the skills and knowledge required for today's changing regulatory environment.

If you would like to learn more about these services and the value that they will deliver to your company, please contact Capt. Jim Hobart, Vice President of Safety at jhobart@jdasolutions.aero or 301-941-1460 x 220.

Toledo Express Airport Safety Management System (SMS)

The Toledo Express Airport has embraced SMS and offers through its website, the ability for staff, the traveling public, airport contractors and tenant organizations to report safety concerns:

 
http://www.toledoexpress.com/FortheAviationIndustry/AirportOverview/ReportaSafetyConcern.aspx.

To immediately report a safety concern the Toledo Express Airport offers 2 options:

1. Call the Toledo-Lucas County Port Authority Police at 419-865-2352 or
2. Fill out the online form.

Providing the safest airport environment for both the traveling public and airport employees is Toledo's top priority. The Toledo Express Airport Safety Management System provides a confidential means of reporting safety concerns. Toledo Express users have a responsibility to report any hazardous conditions or behavior and encourage and welcome the same participation from the traveling public. If there is any question as to whether an event is a safety concern, Toledo wants the event reported.

Their online Safety Management System is an easy and convenient way to provide safety information and feedback through completing the on-line form.

Safety Report forms may also be printed and sent via mail, email or FAX:

• Fax to 419-867-8245
• Email to SMS@toledoportauthority.org
• Mail it to 11013 Airport Hwy Box 11, Swanton, OH 43558

To view the Toledo Express Airport SMS on-line form, go to http://toledoexpresslearn.com/sms/demo-form.php.

EASA expected to set April 2012 as SMS Deadline

It is widely expected that the European Aviation Safety Agency (EASA) will set a date of April 2012 for registered Annex 6 organizations to comply with ICAO-based SMS regulations.

If your organization hasn't initiated your SMS program, time is becoming a factor. It is increasingly apparent that there are a number of carriers who don't know how to best start their SMS to meet regulation requirements.

ICAO has defined that all commercial air carriers must have a valid SMS derived from the Safety Management Manual (SMM) detailing the stages through a safety process depending on your specific operation. To learn more about how to start an SMS, contact JDA at info@jdasolutions.aero.