SMS Increasingly Viewed As Additive, Not Duplicative

By Sean Broderick
Source: Aviation Week & Space Technology
January 27, 2014
Credit: United Technologies

The International Civil Aviation Organization's (ICAO) recently introduced Safety Management System (SMS) annex says much about how the SMS concept is evolving.

Creating a new, dedicated annex—the first in more than 30 years—underscores SMS's aviation industry prominence. More telling, however, is how ICAO constructed the annex.

Annex 19's fundamentals were made up by transferring existing SMS provisions from six other annexes, including Annex 8—Airworthiness of Aircraft. The strategy symbolizes what is happening with SMS programs, and the understanding of them.

Much like Annex 19, individual SMS programs are finally being recognized as compilations of many existing standards and procedures that most commercial aviation operators have, supplemented with some new elements. Establishing them as extensions of existing programs, as opposed to costly initiatives that either introduce duplicative regulations or entirely new systems, is key to gaining acceptance among those—like U.S. repair stations—not yet required to have them.

Researchers at St. Louis University's Center for Aviation Safety Research (CASR), tasked by FAA to study SMS development and implementation, underscore the importance of creating rules that are both scalable and additive. “Such an approach would allow the smaller operators to either be exempt from all or part of the SMS requirements, or demonstrate compliance through more manageable means,” CASR reasoned in a 2013 paper that compares SMS standards to existing regulations. “Larger organizations would then simply leverage their full range of safety and quality assurance systems to demonstrate compliance.”

One of the report's goals was to make direct links between SMS standards and programs that industry either is required to have in place or can implement voluntarily. ICAO's standards and recommended practices (SARP) called for most industry service providers—including commercial airlines, maintenance organizations and aircraft manufacturers—to have these measures in place by 2009. Much of the world is there, but FAA is still working to establish rules for its operators.

FAA has issued draft SMS rules for Part 121 carriers and Part 139 airports, and has tasked a working group with recommending regulations for manufacturers under Part 21. An SMS requirement for repair stations is expected to follow, and many expect the manufacturing SMS rulemaking to serve as a baseline.

In the meantime, U.S. service providers are relying on FAA-issued guidance, including Advisory Circular (AC) 120-92, to build SMS programs. Using the AC as its baseline, CASR cross-checked U.S. service provider regulations—including Part 145—and approved volunteer efforts like the Aviation Safety Reporting System (ASRS) against the AC's list of 29 fundamental SMS components.