Aviation groups are asking the FAA to overhaul a proposed rule requiring safety management systems for charters and tour operators. NBAA and the National Air Transportation Association have filed comments on the proposed rule, saying the one-size-fits-all approach by the agency unfairly burdens smaller, less complex operations. “For any SMS to be truly effective, it must be tailored to the size and complexity of each operation,” said NBAA President Ed Bolen.
NBAA says the FAA has also not given operators enough time to get their SMS plans together, calling the 24-month deadline “unrealistic.” It said a three- to five-year implementation is recommended by safety auditors. The group also doubts the FAA can meet that timeline. “The FAA has limited resources to meet existing SMS oversight requirements, much less to oversee new programs,” NBAA said. It’s recommending the agency go back to the drawing board and involve stakeholders in developing an effective plan for SMS implementation. Bolen also stressed that the industry is on board with the SMS requirement, but it needs to “better serve the wide diversity of operational types within business aviation.”
Flaws in the SMS proposal? Imagine that!
Here’s a suggestion: Transform all the lofty
Get realizations described here into specific guidelines that can be incorporated into daily operations or: go/no go decisions.
Seeing the program tailored to a single pilot 135 operator like myself would be nice also.
Typo correction: delete “Get”
Corrected post. Sorry for the earlier typos
Here’s a suggestion: Transform all the lofty
generalizations described here into specific guidelines that can be incorporated into daily operations or: go/no go decisions.
Seeing the program tailored to a single pilot 135 operator like myself would be nice also.
I am disappointed in NBAA’s lack of knowledge regarding SMS. SMS was first adopted by ICAO on February, 25, 2013. It was effective worldwide on July 15, 2013, and applicable to all appropriate aviation entities on November 14, 2013. NBAA should have been aware of SMS a long time ago given the organizations they represent. I would suggest aviators read Annex 19 and ICAO Document 9859 before they condemn it. Pilots and mechanics should consider this program their best friend. You will find it is not a one size fits all. NBAA should thank the FAA that it did not burden the entire industry with SMS all at once since the FAA could not have approved all these programs at once in a reasonable period of time. Folks need to do their homework before they make inaccurate and misleading comments publicly.
I can report that I worked for a company that had an approved SMS. It created extra paperwork for the pilot/captain. I saw little benefit in all the paperwork involved. Also, to their credit, the DO and Chief pilot followed the program. Unfortunately the company owner did not, only using SMS as a sales tool. If an SMS issue came up the owner would not follow through or would just do what the owner wanted to do. So yes I have experience with SMS and have expressed my opinions on it several times.
NBAA has been knowledgeable of and a proponent of SMS implementation for years. They have a very good SMS guide on their web site that can be tailored and applied to all types of flight operations from an individual operator through corporate flight departments.
This article and issue are about the FAA proposed rule making document, not the ICAO documents you identified. The FAA document IS a one size fits all document that would be onerous, especially for small operators. What has been proposed, if implemented, will more than likely lead to generation of SMS docs that will sit on the shelf and only be pulled out when needed for reporting to demonstrate compliance. Or worse yet, prompt “inaccurate” reports to meet compliance requirements and avoid potential fines and disciplinary actions from the FAA.
A measured approach to tailored SMS implementation could lead to safer operations. This is what NBAA is proposing be accomplished with the recommended overhaul of the FAA proposal. What has been proposed will generate reporting metrics that the FAA would use to give the appearance of a safer ops environment (think ISO 9000 et al in the Quality Management world) but in reality will just increase work load without achieving the intended flight safety improvement.
SMS was pushed on larger 135’s before it was required many years ago. The FAA would stop all controversy if they would just simply lead by example. The day absolutely any of these three letter government agencies adopt an SMS program every transportation company will gleefully follow what the government agency is doing.
SMS is all about organizing and recording your every operation inside the company then exposing everything to the FAA. Could you imagine the FAA showing the American public what they are doing behind their locked doors? 🤣🤣
I work for one of the larger helicopter and fixed wing EMS companies as an A&P and IA. It has been 5 years ago they implemented a company wide SMS system. Will have to say aircraft mechanics as a whole are not the most trusting of the FAA and their programs when it come to looking into your personal business. But hands down this has been the most transformative program and a culture change I have ever seen in aviation when it comes to safety. Been doing this aviation thing for a while, started between my junior and senior years of high school with a pilot license and working on airplanes! The system will work if you use it properly!
Oh and I forgot to add that I will be 60 years old this year. So yeah been there done that got the t shirt! Lol
Every example the FAA used in the NPRM proposal, very lofty and wordy indeed, was covered by rules, regulations that ARE ALREADY IN EXISTENCE. Common sense can not be regulated into existence.
This is SOOOOO needed. I was happily running a part 61 flight school when I had a woman ask to bring her infant child along in the back seat on her introductory flight school. Silly me though it would be a good idea to check with the FSDO about car seat requirements. Instead of providing me with any guidance on car seats, the Baltimore FSDO instead informed me that since the infant child in the back seat was not receiving instruction, by default he was chartering an air tour and as such I needed to be part of this program if anyone ever wanted to ride along in the back seat again. I called AOPA and NAFI who confirmed this. Being a good little flight instructor, I then complied with this edict and heavens you should what a nightmare we have in the way of paperwork, training, drug testing, and audits we are buried under now just to do a couple dozen of these flights every year. This program is set up for a corporation, not a mom and pop flight school that just wants to bring someone along in the back seat a handful of times every year. This reform is long overdue.
I think that having small children on an instructional flight is an unnecessary, possibly dangerous distraction.
If you don’t want to become an air tour operator, with all the paperwork and headache that entails, you should tell your students they need to find a babysitter.
Helen, just to be clear, the SMS program is not going to help the wonderfull interaction you described above. This is additive to the burden you already have. Find the NPRM on the wonderfully interactive website, you will need asprin and LOTS of coffee.