Small- and mid-sized aircraft operators can implement safety management systems (SMS) that are appropriately sized and not overly costly, speakers said during an NTSB webinar May 11.
“Our homegrown system is something that is working for us,” said Ben Berman, director of safety and chief pilot with Parts 91 and 135 operator Open Air, based in Gaithersburg, Maryland. “Ours would be considered a ‘small-letter’ SMS but we do have these safety functions going on,” he added. “The bottom line for us is to get more people involved and then better document what we’re doing ... to make sure that the safety change is permanent.”
Berman was among several speakers representing small- and medium-sized operators who spoke during the webinar on the FAA’s proposed SMS rule, moderated by NTSB Member Michael Graham. Other invited operators were SevenBar Aviation, Aero-Tech Services, Boston Med Flight, Blue Hawaiian Helicopters and Jet Access.
The comment period for the FAA’s new Part 5 regulation for Part 135 charter operators, Part 91.147 air tour operators and certain aircraft manufacturers closed on April 11. Business aviation associations have concerns over the application of SMS requirements originally mandated for airlines—the NBAA has called out “the lack of scalability and flexibility offered by the proposal, especially for the smallest operators.”
Also speaking during the webinar was Dale Whitmore, the FAA’s SMS program office manager, who suggested that smaller operators can draw from existing safety practices to establish SMSs that will comply with the FAA’s future regulation.
“In the current Part 5 rule [for airlines] there is a requirement to conduct audits,” Whitmore said, using one example. “That’s all it says: the rule is not prescriptive in any other application of the audit concept. The purpose would be to monitor your system, to look for possible gaps in the system that may cause failure or non-conformances that have already occurred. The question you should ask yourself is what do I do right now to monitor my system? ... If you collect information and review information [for] some extended period of time, you’re conducting data collection, analysis and possible correction.”
The new Part 5 regulation will contain an updated Advisory Circular AC 120-92, “Safety Management Systems for Aviation Service Providers,” with additional implementation guidance, Whitmore said.
The NTSB first recommended that SMS programs be implemented by Part 121 airlines in 2007; it called for the same requirement for public aeromedical helicopters in 2009, Part 135 charter operators in 2016 and air tour operators in 2019. In March 2021, the board adopted an investigative report that recommends SMS programs be required for all Part 91 revenue passenger-carrying operations, including parachute jumps, historic aircraft experience flights and sightseeing balloon trips.
“Many NTSB investigations have identified organizational deficiencies affecting safety management that could be improved by SMS,” said William Bramble, an NTSB Office of Aviation Safety human factors specialist. “These include pathological safety cultures, blurred lines of authority and responsibility, and missing, incomplete or otherwise dysfunctional safety systems.
“Dysfunctional safety systems can lead to a lack of awareness about the existence, prevalence or severity of hazards, a lack of effort to systematically address known hazards and a lack of insight about the ineffectiveness of some existing risk controls,” Bramble added.
Open Air operates five Cirrus SR22 single-engine piston airplanes and seven Cirrus SF50 Vision Jets, with a flying staff of 14 pilots. Most of its operations are conducted under Part 91, with missions such as donor organ transport flown under Part 135. The company has an informal SMS program that recognizes the four SMS pillars of Safety Policy, Safety Risk Management, Safety Assurance and Safety Promotion, Berman said.
“We have not got any fancy computer systems,” Berman said. “We haven’t hired consultants at this time; we will consider it in the future. I think probably the most important thing that we can do is have more than one person evaluate the safety information we receive from our pilots and other personnel, and so we’ll be enlarging our team. We have support from the company to do that, but we can’t blow our entire budget out of proportion to build a giant safety team.”
