Does SMS Limit Your Operation?
Bob Conyers, Senior Manager, Safety
Occasionally people who are contemplating SMS implementation express the concern that “SMS will place many restrictions on how we operate our aircraft.” I sense that this apprehension stems from a misunderstanding of what an SMS really is.
The International Standard for Business Aircraft Operations (IS-BAO) contains what is presently the most prominent SMS model that is in use around the world. Both it and the FAA model are based on the model developed by the International Civil Aviation Organization (ICAO). Nowhere in any of these SMS models is there any kind of operational restriction on how aircraft are to be operated or maintained. It is true that IS-BAO, in addition to SMS, includes operational and maintenance standards that must be followed if the operator is to become IS-BAO registered. But those are generally open-ended guidelines that allow the operator to set specific limitations, e.g. “The operator shall establish … flight and duty time limitations.” (More on limitations in a little bit.)
As its name implies, the SMS is simply a Systematic way to Manage your Safety program (Hence, SMS). It is primarily organizational in nature, requiring designation of individuals to be responsible for certain aspects of safety management. Four leading components of the SMS set the foundation for managing safety:
Safety Policy – established and enforced by top management
Safety Promotion – distributed and publicized throughout the organization, with emphasis on participation by every member of the organization
Safety Risk Management – establish a means to identify the hazards that are faced in daily operations, or on a recurring basis; assess the risk associated with hazards and mitigate the risk where practicable
Safety Assurance – Verify for yourself that these measures are, in fact, effective in managing risk to a degree that is tolerable for your operation.
Notice that none of these SMS components restrain operations in any way, except that mitigating risk might lead to limitations to control what is already identified as unacceptably high risk.
That is, in effect, what the standards in the other sections of IS-BAO are intended to achieve. Take, for example, the standard to establish flight and duty time limitations. Virtually all corporate flight departments set such a policy, despite the fact that there is no requirement to do so (under FAR Part 91), because the threat of fatigue has been shown many times to lead to an aircraft accident or serious mistake on the job. There is wide variety in the policies of different companies, as each is written to meet the needs of the operator, and there is flexibility in their application, but each is intended to manage in advance the risks associated with fatigue in the cockpit or in the shop.
All the other standards in IS-BAO are written for the same purpose, and usually allow for flexibility in adaptation and variance in application. In most cases, they are standards that have been followed by operators for many years, including your company.
Each operator can decide on its own whether it wants to adhere to the IS-BAO standards. But operators owe it to themselves to consider how they will continue to maintain a high standard of safety management.