How to Make SMS Work Better for Everyone

ICAO, the International Civil Aviation Organization, a group that provides aviation safety standards, requested its participating nations to require safety management system (SMS) of its "service providers" by the first of this year (for more on ICAO’s SMS standards, see http://www.icao.int/anb/safetymanagement/). The FAA and most other nations’ regulatory agencies requested waivers to extend the compliance period to better implement SMS within their countries.

The FAA postponed the release of a proposed SMS rule for operators in order to properly align the objectives of SMS with their current air carrier oversight program of system safety (ATOS, or air transportation oversight system). Anyone familiar with ATOS knows that the ATOS scheme for identifying risks within each of an air carrier’s processes is extremely rigorous and often duplicative. FAA Flight Standards has expressed its commitment to improve the ATOS risk identification process.

Additionally, FAA Flight Standards has expressed its commitment to implement SMS within its own organization. For SMS to be truly successful, it must be viewed as a collective collaborative effort on the part of both industry and the FAA. An integral part of SMS is the collective sharing of safety data, analysis and corrective action among all facets of the airline industry including the FAA. SMS is not just something for the airlines to adopt; rather SMS is a program the FAA needs to embrace and adopt SMS principles for the agency to make it work for everyone.

FAA Flight Standards has taken numerous steps to implement SMS within its own organization. The department is certified as an ISO 9000 standards organization and is committed to retaining feedback processes such as the CSI process (formerly called customer service initiative; now likely to be renamed the consistency and standards initiative) for resolving regulatory issues in the field. Flight Standards has established a repository for collecting industry-wide safety data (ASIAS, or aviation safety information analysis and sharing) and they have hired system analysts, who along with aviation subject matter experts have already produced several excellent safety studies leading to meaningful corrective actions within the nation’s airspace.

They also sponsor a focus group to encourage voluntary adoption of SMS among the air carriers. The lessons learned from this focus group will not only assist the air carriers in integrating the SMS process into their programs but it will greatly assist the FAA in training their own inspection workforce in SMS policy. So what other changes should we expect from the FAA’s commitment to implement SMS internally?

I believe FAA Flight Standards should also implement a risk management review within the regulatory process to ensure that each proposed rule has true safety value. SMS is built around the concept of managing risk whereas the regulatory process focuses on compliance and enforcement. A SMS process review of regulations is not the same as preparing a cost benefit analysis: that is a requirement that satisfies the Administrative Procedures Act and would remain. The advantage of a SMS process review of a proposed regulation is similar to when someone petitions the FAA for a rule change which requires that they show "an equivalent level of safety." I would envision that for the FAA to propose a new rule consistent with risk management, the agency would want to provide in the preamble a statement as to how each provision provides for "an increase in the level of safety."

The most immediate benefit from this approach in rulemaking is that it would focus on true safety advances as opposed to proposals that are "administrative in nature" from entering the rulebook and diluting the true safety rules. For example, the FAA recently proposed a rule that would require U.S. air carriers operating outside the United States to carry aircraft noise certification information on board their aircraft (Docket FAA-2008-1097). Air carriers have such information in their operating manuals but not necessarily on each aircraft. It would be difficult to describe how an extra sheet of paper in each cockpit would "increase the level of safety."

Another benefit in implementing SMS within the regulatory process is that it should reduce the redundancy and clarify the intent of regulations. For example, the FAA recently proposed revising the training programs for pilots, flight attendants and dispatchers that, if adopted, will add several hundred pages to the regulations (Docket FAA-2008-0677). At first glance the proposal for pilot training looks to be redundant to the existing advance qualification program (AQP) rules for pilots. Currently AQP is optional but if the FAA desires to mandate AQP for every airline, why would they not propose a simple provision mandating AQP instead of proposing to add several hundred more pages to the regulations?

While adopting a SMS approach to current rules would be a significant task, the goal of SMS is a sound one. Every two years the FAA asks for public comments on how their regulations can be improved, but little changes. However, if the FAA were to integrate an SMS process into rulemaking, I would think that many more industry people would submit requests to change the current rules and in so doing, truly enhance overall airline safety. I know I would.