Story ID: 124AINSMScourse
Preparing for the Future of SMS
By: Kerry Lynch
Caption: A week-long course hosted by NATA and the U.S. Transportation Safety Institute is designed to give tools to organizations as SMS rules loom.
Word Count: 2122
A few months after FAA Administrator Steve Dickson outlined plans to release regulations requiring safety management systems (SMS) for Part 135 charter and 145 repair station operations next year, the FAA is said to be “far along” in this rulemaking effort. The question is, though, are the vast and varied numbers of Part 135/145 operators ready for it.

The FAA, which has required SMS for Part 121 scheduled carriers since 2015, has long encouraged other operations to voluntarily adopt such programs and has had a program in place to help facilitate implementation. Along with the FAA’s voluntary program, a number of companies have developed detailed software to help organizations implement their own SMS. And, SMS is a foundation of IS-BAO.

Even so, a large number of operations are expected to need to adopt SMS, or at least more fully adopt it, once the rulemaking is released. The exact number is unknown because so many have incorporated plans through private program providers.

Looking at just Part 135, the FAA’s database recognizes just under 2,000 certificated operators. Of those, 26 programs are accepted into the FAA’s voluntary program with another 157 in the works. Meanwhile, more than 1,000 business aviation operators have achieved IS-BAO recognition, but only about 30 percent of those involve certificated air carriers worldwide.

This lack of adoption came sharply into focus during the National Transportation Safety Board’s investigation into the Jan. 26, 2020, Island Express crash that killed basketball player Kobe Bryant, his daughter, six other passengers, and the pilot. The NTSB called the accident preventable and said, “We have long believed in the benefits of SMS. Although the company used some SMS tools, it did not implement the entire program.”

With an eye on these concerns and on the looming regulations, the National Air Transportation Association (NATA) teamed up with the U.S. Department of Transportation’s (DOT) Transportation Safety Institute (TSI) to develop a week-long course on SMS for the 135/145 community.

In tandem, NATA created a new Air Transport Safety Manager certification through the International Society of Safety Professionals (ISSP) for members who take the course and an associated certification exam. The certification program is designed to help elevate the professionalism and status of safety managers.

“Business aviation is a unique space, providing new challenges every day and opportunities to engage in continuous improvement,” said NATA senior v-p Ryan. Waguespack. “This collaboration with TSI, along with our new SMS pilot program, allows NATA and its members to take our shared mission of advancing aviation business safety to a new level.”

HUGE NEED FOR TRAINING

Based at the expansive Mike Monroney Aeronautical Center in Oklahoma City, TSI is not part of the FAA but is a separate organization within DOT that provides a host of courses across multiple modes of transportation. The TSI menu includes a bevy of aviation safety management, accident investigation, and other courses, making it the right fit for NATA’s vision of an in-depth course on SMS.

NATA and TSI initially lined up four weeks for the course at its Oklahoma City location, but Roger Hood, course manager for TSI’s Aviation Safety Division, expects the course to continue on into the future. “We understand there’s going to be a huge need for this training,” he said. “We have very high demand.”

Because class sizes at Oklahoma City have been limited during the pandemic and some people may not want to travel, TSI is looking at alternative sites to accommodate others, he said. In addition, the course is spurring interest in some of TSI's more specific programs and follow-on courses.

NATA and TSI invited me to audit the course and I took the opportunity, choosing a week in January. I have covered SMS but taking such a course would give me a better understanding of what is involved and what it might take to incorporate. And in fact, it also got me thinking about my own organization’s safety protocols.

Before we (the students) attended the class, we were instructed to read and familiarize ourselves with Part 5, the FAR created to house SMS regulations, along with the accompanying Advisory Circular 120-92B.

Course managers wanted to make sure we had a basic knowledge of the regulation because the week-long training takes a deep dive into it with a “how-to” approach. This is important because the FAA’s SMS rulemaking for Parts 135 and 145 is believed to be largely based on Part 5.

Reading through the regulation and AC, it struck me that every section had language on the scalability of the required elements of SMS. The AC acknowledges the differences in size and complexity of operations and the volume of data available but says Part 5 “allows organizations of different sizes to meet those requirements in different ways. The SMS functions do not need to be extensive or complex to be effective.”

Whether it accomplishes that goal remains to be seen. In January NATA launched a Voluntary SMS Implementation Project to evaluate the application of SMS across the Part 135 charter and Part 145 repair station communities.

Hood opened the class with introductions, highlighting the depth of experience of the instructors—most of whom remained with the class throughout the week, on hand to answer questions or go over individual concerns. This included D Smith, the manager of TSI’s Aviation Safety Division.

Students also introduced themselves. A number represented well-known charter operators and MROs, or maintenance divisions within operators. Some of these students have SMS but were trying to enhance their programs. Others were part of the way there, and others were at the beginning or looking to enrich their education.

The Four Pillars

The FAA says an SMS is intended to provide for a systematic approach to achieving acceptable levels of safety risk; it is essentially a decision-making process that relies on four pillars—a safety policy, safety risk management, safety assurance, and safety promotion.

A safety policy is essentially a contract establishing the commitment to SMS. This commitment must come with buy-in from the top of the organization, the course stresses. The safety policy must be signed by the “accountable manager,” someone who has financial and decision-making responsibilities for the entire organization. This is typically a senior leader and lays the commitment for the safety program at the hands of the top layer of the company.

On the first day, Hood provided an overview of the safety policy. Not just a statement that an organization wants to be safe, the policy needs to include safety objectives, the commitment to that objective, a clear statement of the resources that will be dedicated to carry it out, a commitment to a safety reporting element, a definition of unacceptable behavior, and provisions for an emergency response plan. An organization must communicate this policy to employees and continually review it to ensure it meets the needs of the organization.

The class provided examples of different approaches to a safety policy, including TSI’s own safety policy along with those of Jet Linx and Million Air.

While opening with safety policy, the class delved into the other three pillars of SMS.

Kodey Bogart, owner of KB Solutions Safety Management, and Smith provided a presentation explaining risk management, including the difference between risks and gambling (one involves informed assessment, the other guesswork), and stressing that this is an ongoing process.

Risk management involves identifying the hazard and assessing the risk associated with the hazard, including the likelihood and severity. It also looks at controls and potential outcomes.

There are color-coded matrices available that enable safety managers to visualize the severity and likelihoods associated with the risk to help guide informed decisions. Having the ability to make informed decisions is critical because most organizations do not have unlimited resources to devote to every risk.

Jerry Kosbab, president of AeroDirections who is renowned in the safety community for his expertise with the “BowTie” approach to risk management, gave an overview of this method. We were to look at a hazard, defined as something that is a normal part of business but has the potential of harm if control is lost, and then determine a “top event” that occurs from that hazard. The top event is described as “a deviation from the desired state or activity” but one that recovery is still possible. That is the center of the BowTie.

At the left of the BowTie are threats involved with the hazards and possible preventative mitigation controls. To the right of the BowTie are “recovery controls” (what you do in response to the top event) and consequences.

We had class exercises on forming a risk matrix as well as BowTies, and you realize how different organizations can take markedly different approaches to risk management. These approaches can be granular (my class group worked on a BowTie surrounding the introduction to bag loaders) to something much broader, such as new ownership.

Another takeaway for me throughout the risk management sessions is that an organization must dig deep and think critically about all of its operations to ensure that safety is part of the fabric.

Terry Taylor—a 40-year aviation veteran with safety management experience at the FAA, Embry-Riddle Aeronautical University, TSI, and his own Chameleon company—explained the difference between the SMS pillars of safety risk management and safety assurance: risk management answers whether the system is capable of operating safely, effectively, and within the requirements of the regulations; safety assurance answers whether the organization is following the system as designed, is it operating safely and effectively, and does it have the data to back that up.

Safety assurance is constantly monitoring and ensuring that a company’s risk management is working. To get there, there must be continuous and periodic monitoring, as well as auditing and comprehensive evaluations.

As for safety promotion, Jet Linx director of safety Sheryl Clarke explained a safety culture must be deeply ingrained and automatic, she said, noting that without a strong safety culture, the other three pillars will not matter.

She stressed that simply buying an SMS software program and then placing the program on a shelf will not work. Instead, the program must not only have the buy-in of leadership but front-line employees. Safety managers should have ties to all departments. Employees must be trained and participate.

Key to this is the concept of just culture. Employees must feel safe in their jobs to participate, particularly in reporting, without reprisal. Just culture goes beyond reporting. It is a key part of how employees feel in their jobs and parlays into human factors. Do they feel secure enough to make decisions that are in the best interest of safety?

“It is impossible to punish your way into a good safety culture,” Smith said. “It’s impossible to punish your way out of human errors.”

He stressed that organizations need to build a culture where safety is part of the entire fabric of an organization. Safety isn’t a priority, Smith said, noting priorities change and can be negotiable. A safety culture must be a principle, a guiding philosophy.

Expanding on that was Dan McCune, associate v-p of safety at Embry-Riddle. He noted that “everything revolves around safety culture” at Embry-Riddle. He characterized this culture as “doing the right thing when no one is looking.”

In human factors, he continued, errors have a reason, whether skill-, rule-, or knowledge-based. Nothing happens in a vacuum and rather than punishment, organizations need to root out those underlying reasons to correct them.

Participants who registered through NATA were given the opportunity to obtain Air Transport Safety Manager (ATSM) certification. We were handed a study guide that reinforced the lessons through the week. Near the end of the week, we took the exam to further reinforce the concepts.

The nascent ATSM certification likely will evolve over time, Smith said, with possible continuing education components and other requirements. But for now, I count myself among the early certification holders.

Importantly, I learned the class wasn’t simply a high-level overview of SMS, but a how-to course where instructors want to give participants resources and tools so they can effect a positive safety culture and fully implement SMS and be ready for the FAA.

Other sessions are planned for April 12-16 and July 12-16.
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