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Virtual Safety Office – Safety Analyst Mentor Program
As SMS becomes more prevalent worldwide due to ICAO and State Regulatory Requirements, small operators with limited staff and resources will likely turn to outside contractor organizations to assist with the set up and support of their SMS. The services may include SMS consulting, implementation, training, manuals and implementation of an application tool such as SMS Pro™ to enable the organization to structure and manage all the SMS component requirements more effectively.
Regardless of the size of the organization at least one staff resource will be needed to manage and operate the SMS on a daily basis. Considering all that makes up an SMS, the task of managing the SMS components is a full-time assignment. Small business aviation departments, charter operators, repair stations and scheduled air carriers with limited or multi-tasked staff will be hard pressed to keep their SMS current and effective. Implementing an SMS application like SMS Pro™ will make it much easier to manage the company's SMS program, but it still requires a dedicated staff to operate and manage the program. This may be especially challenging when the SMS manager may also be a line pilot or has other company responsibilities. In the aviation industry, managing safety cannot be a part time job. One option that small operators may want to consider is to outsource some staff safety functions to an outside service provider.
In 2008 JDA and NWDS formed a strategic partnership pertaining to the use and implementation of SMS Pro™. That partnership became SMS Partners. JDA, with its cadre of former career FAA managers and inspectors, has extensive safety, and SMS training and implementation expertise. NWDS developed SMS Pro™, which was viewed as one of the key pieces needed for any organization that was implementing SMS.
It became apparent after preparing SMS proposals for several small operators, that providing a hosted SMS application on a monthly subscription service that included a dedicated safety analyst resource made sense. This approach enables SMS capability for the small operator that may not otherwise be able to have an effective SMS. The hosted subscription-based service is the Virtual Safety Office (VSO), and the resource that supports the VSO for the customer is the Safety Analyst Mentor (SAM).
VSO – an operator, be it corporate/business, charter, repair station or scheduled air carrier, which has/intends to have a Safety Management System (SMS), elects to implement SMS Pro™ for collecting hazard and safety event data, conducting risk analysis and managing the SMS components. Instead of the client/user purchasing an SMS Pro™ license and having a dedicated and customized hosted solution, the client/user elects to access SMS Pro™ via the Internet to a generic SMS portal operated by a SAM. The VSO enables the client/user to take advantage of all the features and capabilities of SMS Pro™ and submit and review their safety event information and related SMS components for a monthly subscription fee. The VSO portal will be shared with other VSO clients/users with the assurance that no client will be able to access or see another client's safety data or SMS components.
SAM – is an outsourced safety specialist that operates SMS Pro™ for clients as part of a VSO subscription or is contracted to support a dedicated/licensed SMS Pro ™ application. In either model (VSO or Dedicated) the SAM operates SMS Pro™ and performs the following functions:
- SMS Pro™ administration
- Hazard /safety event identification, analysis, tracking and assignment
- Trend analysis
- Assist with risk analysis
- Create reports
- Client coaching, training and mentoring
- Track and manage action item assignments
- Update stored manuals, documents, policies and procedures as directed by client
To learn more about the VSO SAM services call 301-941-1460 ext 140 or email info@jdasolutions.aero.
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SMS Regulation – When and What?
Although only a few ICAO States have regulations in place for approving safety management systems (SMS), most nations are working to comply with an International Civil Aviation Organization (ICAO) regulation that will require an SMS for international operators of large aircraft and business jets weighing more than 12,500 pounds.
There are misunderstandings about the SMS requirements and, with few exceptions; every country is still struggling with the regulations. Canada, which has been working on SMS for 10 years, still doesn't have fully implemented SMS regulations. Singapore has regulations, and Rwanda, Tanzania, Kenya and Uganda have completed their regulations. Even though ICAO States were supposed to have SMS regulations in place by January, 2010, most are lagging like the U.S., which filed a "difference" with ICAO stating that the FAA does not have an SMS regulation in place yet. The FAA however published an advance notice of proposed rulemaking (ANPRM) seeking public inputs and comments on a potential SMS regulation. The FAA formed an Aviation Rulemaking Committee (ARC) to assist with reviewing the ANPRM comments and crafting a draft rule.
The FAA has already published Advisory Circular 120-92, "Introduction to Safety Management Systems for Air Operators," to provide information for operators to develop SMS programs voluntarily. But there are no FAA authorization procedures to accept or approve an SMS.
Recently FAA Administrator Randy Babbitt delivered a message to aircraft operators that believe they should be exempt from implementing an SMS. "I'm confident that SMS will really make a difference [in reducing aviation accidents].
I know there are those who complain that they're too small for SMS. Or that it's too costly.
Or that they don't have time," he said. "No one and no company is too small for SMS.
The cost of SMS is far less than the cost of an accident. Saying that you don't have time for SMS is the functional equivalent of saying that you don't have time for safety."
Babbitt characterized SMS thus: "You identify the problem, you analyze it, you come up with a solution, you train to the solution and then you check how you're doing. [It's] a safety feedback loop."
To operators who believe SMS is just a fad, he said that not only is SMS here to stay, "It's going to be here for the long haul because it works. Everybody has a responsibility for safety."
There are some indications that the FAA plans to release an SMS rule by year-end. However, those familiar with the rulemaking process point out that the U.S. rulemaking process takes several years and the likelihood that an SMS final rule will be published by the end of 2010 seems remote. As the original November 18, 2010, deadline for general aviation operators draws near, it is clear this country will not be alone in missing that goal. However, other countries will require aircraft operators to have SMS implemented by year-end.
In the meantime, the benefits of implementing SMS now using ICAO Annex 6 guidelines or the IS-BAO guidelines (business aviation) far outweighs waiting for an FAA rule to be published.
Safety Quotes Worth Repeating
"There are two critical points in every aerial flight—its beginning and its end."— Alexander Graham Bell, 1906
"You are professionals trained to deal with three things that can kill you: gravity, combustion, and inertia. Keep them under control, and you'll die in bed."— Sailor Davis, long-time TWA ground school instructor
"Most accidents originate in actions committed by reasonable, rational individuals who were acting to achieve an assigned task in what they perceived to be a responsible and professional manner."— Peter Harle, Director of Accident Prevention, Transportation Safety Board of Canada
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