In Face of Barriers, SMS Is Picking Up Steam

A year after the FAA released its final rule mandating charters, air tours, and manufacturers to adopt safety management systems (SMS), industry leaders are starting to see interest pick up from affected operations in part as they seek to lay the groundwork to come into compliance. But, in addition to a drive for compliance, they also began seeing an uptick for an unexpected reason—the people in the back of the aircraft.

The agency on April 26, 2024, mandated SMS for Part 135, air tour operators, and manufacturers (those with a type and production certificate), establishing a deadline of May 28, 2027, for compliance. That is the date when operators must submit their declaration of compliance, meaning they have SMS fully implemented.

Some companies have been spurred into action because of the mandate. Justin Raymond, director of operations in the Americas for Web Manuals, said his company has seen “a significant rise” in business aviation operators and manufacturers looking for SMS support. He cited the FAA’s final ruling as largely driving this trend.

But also, one of the ripple effects from the high-profile accidents that have brought a spotlight on aviation safety this year is that passengers have started to question the safety standards of their operations, noted Bryan Burns, president and CEO of the Air Charter Safety Foundation. As such, ACSF, which administers an SMS program for its members, has seen inquiries increase in that area.

“What we’ve discovered in the last couple of months with the activity surrounding recent accidents,” said Burns, “is that passengers that are in the back of these corporate aircraft are asking pilots: ‘Hey, what’s this about SMS? Hey, what am I hearing about ASAP [aviation safety action programs], data monitoring, and the term ‘just culture?'”

He likened the scenario to two decades ago when industry audits began to take root. Passengers saw that companies were advertising that they had met the high standards and began to ask whether their operator was also participating in that: “‘Are we doing this? Are we mitigating and managing our risks?’”

This comes as media coverage has particularly intensified since the January 29 midair collision between a PSA Airlines CRJ700 and U.S. Army Black Hawk near Ronald Reagan Washington National Airport. That was followed within weeks by fatal accidents in Philadelphia and Scottsdale, Arizona. “Whether it’s an incident or an accident, fatal or nonfatal, it’s on the news every day, somewhere, someplace,” Burns added. “And that has triggered just a lot of questions.”

For manufacturers, the mandate has been an imperative. SMS has received substantial attention on Capitol Hill, particularly in the aftermath of the Boeing Max crashes. The mandate was something manufacturers pushed for as they faced other proposals that could have substantially altered the certification process.

However, most manufacturers have long been on board, regardless, noted Walter Desrosier, GAMA’s v-p of engineering and maintenance, noting that the International Civil Aviation Organization has had standards in place for years.

While many have pieces of an SMS, Desrosier said that does not mean the manufacturers are in compliance with the final rule as written. They are assessing the requirements to see where it might differ from where they are, conducting a “gap analysis,” he said.

The FAA also said it is seeing the number of operators proactively implementing SMS continue to climb.

However, the mandate and the deadline are raising numerous questions. Chiefly, will an already strained staff at the FAA be able to keep up with the requirements that were extended to 2,500 more operators? And, how will a small operator—particularly those with a single aircraft, few staff, and few resources—comply?

The benefits of SMS have been well documented and endorsed by many industry associations, which have long advocated for the programs and key elements of SMS, such as just culture and data analysis.

Web Manuals’ Raymond noted that in addition to the simple mandate, companies are coming on board because there is “an industry-wide recognition that proactive safety management is essential in reducing operational risks. Many operators are realizing that traditional, manual processes are no longer suitable in the industry’s evolving landscape.”

He also sees a broader industry shift toward data-driven safety reporting and just culture, key elements of SMS.

Desrosier pointed out that many of the elements of SMS are not new to manufacturers, and the reasons behind the FAA and ICAO mandates are the “very same reason that we as manufacturers have been looking at this all along.” In fact, the manufacturers played a role in helping to design the global standards.

About one-third of ACSF’s members have either incorporated or at least started the process of adopting an SMS, Burns noted. But these operations are the ones that are taking the time and investing in a safety organization, likely more predisposed to SMS programs.

Even so, Burns was encouraged by the inquiries the association has been receiving, including the helicopter operators that have reached out through its partnership with Vertical Aviation International.

This is critical given the vast number of operations that need to adopt the program in just two years, including getting it in working order and ready for submission of the declaration of compliance, Burns said.

“What you don’t want to do is wait and then submit some kind of document or manual without having potentially demonstrated between now and May of 2027 that you’ve got a program in place and it’s measurable, it’s quantifiable, and it’s working. Don’t wait until a few months before the deadline and think you’re going to put something together that’s going to be effective,” he said.

GAMA’s Desrosier agreed. Noting there are two years left for compliance, “It’s going to take all of that to effectively and successfully implement [SMS]. We encourage a process where the companies bring in the culture, they bring in the processes, and they bring in the non-punitive reporting, which all takes time. You don’t just turn that on overnight.”

The Barriers

Numerous barriers stand between getting operators on board, but primarily time and resources, Burns said. “Having internal staffing to dedicate to getting through this process is the number-one issue.”

Doug Carr, NBAA senior v-p of safety, security, sustainability, and international affairs, agreed, saying this is particularly true as the industry grapples with how to get the smallest operators on board. Carr noted that awareness is not an issue—most operators have heard of SMS and are aware of the mandate.

But learning how to implement SMS and how they can apply to a one-aircraft operation or a small staff where there aren’t resources is a bigger barrier. 

Burns agreed. “We find ourselves in this constant education process.” He noted that that’s why ACSF developed a scaled-down version of its Industry Audit Standard—IAS Lite—because the original wasn’t accessible for small operators. It also rolled out an SMS platform to facilitate this for small operators.

“Our whole focus was around making it simple, customizable, and a key to a lot of this—low cost,” adding that this was created with the entry level in mind “because they lack time and resources.”

Web Manuals has been working toward that goal as well, said Raymond. “Unlike larger operators that have dedicated compliance departments, smaller operators often have limited resources and personnel managing multiple regulatory requirements. This can increase the complexity of SMS implementation,” he said, noting that his company is working with all sizes of operators.

“Web Manuals’ goal is to make SMS management as straightforward as possible. An effective SMS should scale over time as the operation grows, building on existing processes.”

With an eye on concerns around implementation, the National Air Transportation Association (NATA) is planning a series of forums to help prepare Part 135 and air tour operators, as well as provide better insight to the FAA on their struggles in meeting the requirements. The association is looking at potential locations and timing that would best fit operator schedules, as well as other events where it could reach the larger community.

These forums come on the heels of the 135 SMS Roundup event the association held earlier this year, focusing on topics such as building safety culture and employee engagement, as well as using technology and learning about case studies.

Importantly, the sessions fostered a dialogue between the FAA and operators on areas that were unclear or concerning, said Jenny Ann Urban, v-p of regulatory affairs for NATA. The overarching theme was to help operators understand the need to be prepared for the May 2027 deadline for the submission of their declaration of compliance.

“You need to design and implement your SMS before submitting your declaration of compliance because once that’s submitted, even if you’ve submitted ahead of the deadline, you’ve entered into a regulatory environment where they can come and inspect you,” Urban said.

Also important was to include representatives from larger operators that have already adopted past voluntary SMS programs or submitted their declarations of compliance. They were on hand not only to share best practices with smaller operators but also to learn from each other, Urban noted. A key theme emerging among them was that safety is not a competition, but rather it’s better for the industry as a whole when everyone is incorporating best practices and sharing information.

As far as the FAA officials there, they had an opportunity to hear questions on how the SMS programs will be reviewed and inspected, as well as concerns that different inspectors may have different expectations. A key message impressed by operators was the importance of inspectors being trained and understanding the rules. Particularly important was that inspectors evaluate for compliance but do not dictate how to get there.

FAA Resources

Among the questions was whether the FAA could keep up with the mandate alongside industry. Regulators are hoping—and starting to see—that many will seek approval for their declaration in advance. But there is a prevailing concern about a rush right at the deadline.

FAA officials indicated that they were paying attention to these and other concerns and were using that information as they train and educate their workforce.

“People get a little overwhelmed with SMS, but if you already have management systems in place, you don’t have to reinvent the wheel. You can utilize that,” Urban said, stressing that SMS will be different for every operator.

Every operator has different risks and different safety analyses. This is why it is important to have the regulators understand the industry and make sure SMS is scalable, she said. Operators need to understand what fits and works for them.

But all of this points back to how the FAA will manage this. Carr noted that the FAA has indicated it may fold SMS into its regulatory inspections of the carriers.

The FAA told AIN it is in the “final process” of publishing guidance on SMS maturity and how to conduct performance-based oversight.

The agency further noted it has added briefings for its workforce to prepare them for oversight of SMS and developed enhanced oversight tools to help inspectors evaluate and document the effectiveness of an SMS program. In addition, the agency pointed to an array of other efforts such as videos, a frequently asked questions document, and FAA Safety Team (FAASTeam) briefings.

“We have recognized that there is still some confusion regarding development and implementation of SMS, so the FAA has leveraged our partnership with industry to champion SMS,” the agency said, including participating in industry events “to dispel the mystery around SMS for those service providers who are new to the conversation.”