FAA Eyes Collaboration Toward Enhancing SMS

FAA officials are hoping to foster collaboration as the industry moves toward implementation of safety management systems (SMS), telling the Air Charter Safety Foundation Safety Summit attendees on Wednesday that the agency wants to gauge the maturity of these programs so the company benefits from them.

But Safety Summit attendees still shared concerns that there will be an unevenness in implementation approvals from their local Flight Standards District Office inspectors, and that it opens the door to opinion.

Under a 2024 rulemaking, Part 135 operators face a May 28, 2027 SMS compliance deadline. That is the date when operators must submit their declaration of compliance, meaning they have SMS fully implemented.

Suzette Rash, manager of the FAA’s Office of Safety Standards, and FAA aviation inspector Jim McKenna simulated a hypothetical scenario of a conversation between an FAA principal inspector and company safety officer, highlighting how this collaboration could take place. The idea was to sit down and have a conversation in a way that could spotlight how companies manage risks rather than “kicking tires” through inspection.

This scenario pointed out a connection between maintenance issues, something that a robust SMS can help tie together and position a company to address.

“We wanted you to learn from this [simulation] that the minimum is the compliance—you have your safety management system that meets Part 5—but then your real benefit of the safety management system is utilizing and maturing your safety management system,” Rash said. “That’s where we want to get to, both as an inspector workforce and industry: we want to help improve safety management within the organizations to help identify those hazards so that we can come back and make them safer.”

As this happens, she added, the inspector workforce will have greater confidence in an operator’s ability to identify hazards and mitigate risks. “Then we could focus our energy and our resources in the areas that we […] don’t have that confidence in.”

The FAA is just getting started at measuring and looking at safety culture, along with SMS maturity, Rash said. But she also stressed that this isn’t to emphasize what is wrong, but rather, “how can we make it better. So, as we go in and look at that, don’t be fearful that you’re going to get a compliance action or an enforcement action. It’s just a conversation about how we can make this better.”

This approach reflects a different philosophy and perhaps lessons learned from the implementation of Part 5 SMS requirements with Part 121 scheduled airlines. “When we rolled out the 121s, we were really focused on the implementation plan,” Rash recalled. Rather than focus on implementation and a back and forth of what the FAA thinks would not work, the agency is asking operators to design an SMS that they think fits best, use it for a period of time, work out the bugs, and then submit it to the FAA when they believe it works. “We’re saying, ‘How is it performing,’ versus, ‘Let me look at the design.’”

One audience member questioned whether these conversations raise a gray area where some inspectors may want to initiate certificate actions. But Rash said the agency is training its inspector workforce on this approach and that disagreements could always be elevated.

Another noted that “just culture” is not just within a company but must be between the FAA and the operator, saying that the subjectivity involved in inspector review of these programs “is challenging for us.” The commenter added, “Sometimes it feels like this isn’t regulation, [and] this is, you’re telling me how to run the business.”

Rash responded, “We do recognize this is the squishy area. It’s a very uncomfortable area.” FAA inspectors are maintenance technicians, pilots, and dispatchers. “We like black and white. So we’re now in an uncomfortable position.”  As a result, the FAA is conducting a lot of outreach with the inspector workforce and stressing that the agency does not regulate by policy.

“We’re getting there,” she added. “We’re trying to shift that narrative.”