Safety Management System
SMS
This article first appeared in POPA Magazine, Fall 2023.
12/22/2023. Estimated read time: 6 min.
Looking for the Safety Forest through the SMS Trees
A flight control check once saved my life.
I was taking up a Waco ZPF-7 solo for an aerobatic refresher. I completed a run-up and flight control check from the hold short line, finding I could not move the stick left of neutral. Flight controls are good, so I taxied back to the hangar to investigate. The front seatbelt had four out of five harnesses secured, but the crotch strap dangled loose and lodged in the flight control stick assembly, completely preventing any left roll.
What if I had taken off? Would I have had the presence of mind to kick some rudder in, or would I slowly roll right, unable to correct immediately after takeoff, fighting it to the ground?
At the time, I was flying five different aircraft under a Part 91 operation and had no official Safety Management System. Fast-forward a decade, and my experience broadened to IS-BAO Stage 3 Part 91 and 135 operations, from single-pilot to crew ops with hundreds of planes and pilots, from turboprops and pistons to super mid-sized jets. As you can imagine, the paperwork drastically increased.
Waco ZPF-7
First Principles
At the most basic level, aviation safety is about not dying. Before using an SMS manual, I had my own safety system. I evaluated everything through the lens of what would kill me, devised a filter of priorities, and reduced those into the most essential action steps I could take.
20% of accidents happen due to mechanical issues, 80% due to pilot error. On the mechanical side, fluids and flight controls are my highest priority. I won’t start or take off in an airplane without knowing the status of those things. On a lengthy preflight checklist, my eyes see fluid, flight controls, and then everything else, not to neglect other items but as second-tier tasks. For example, removing the emergency exit pin is important but less critical than your oil level.
On the pilot error side, most of my mistakes happen when I am in a hurry or tired. So, I’ll build in time to complete preflight tasks without being rushed, and I won’t let ATC or people in the back dictate my pace. I view rest and recovery as work. When I am tired, I intentionally slow down more.
This philosophy of flight saved bodily injury and perhaps my life that day in the Waco. It could have prevented a Gulfstream operator from crashing off the end of the runway in Bedford, MA. The crew’s “failure to perform the flight control check” and attempted a takeoff with the gust lock engaged. They had all the paperwork and were a prestigious IS-BAO Stage 3 operator. Flight control checks for this operation were hardly ever accomplished (only 4 out of 175 previous takeoffs). The I’s were dotted and the T’s crossed, but there was a lack of priorities.
Safety Management Systems
The first SMS systems arose from commercial airline operations, forming the next generation of safety. First came aircraft mechanical improvements, then CRM concepts in the crew environment, and lastly, the organizational aspects of safety, codified as an SMS.
The basic tenets are to operate more safely today, reduce risks for tomorrow, and promote non-punitive communication, which should lead to fewer incidents and cost savings—added bonuses: regulatory compliance and marketing opportunities.
SMSs are still relatively new. Airlines have only been required to have one since 2006. However, the requirements are trickling down. In April 2023, the FAA proposed a new rule to require 135 operations to have an SMS, although many operators have already implemented one for years. While the FAA is more lax on part 91 operators, ICAO recommends that operators of aircraft over 12,500 lbs have one, leading some countries to require an SMS for those operations, such as Bermuda.
So, of the two groups of operators, PC-24 operators may have to have an SMS in place for some foreign operations, while PC-12 drivers have the luxury of optional SMS usage. Regardless of the operation, is it a good idea to have one? Is an SMS appropriate for smaller departments? Could you have a basic set of principles and skip an SMS altogether?
Maybe.
An SMS is only as good as its usability. The original design was for large organizations, and taking hundreds or thousands of pages of documentation and applying it to a one-plane, one-pilot flight department will lead to complacency in its implementation and use. An airline system would be inappropriate, but every SMS doesn’t have to look the same. Can the system’s strengths be parsed to a level where smaller departments derive value and safety benefits?
Strengths and Weaknesses
If you enjoy writing technical papers, looking at a proposed table of contents for a Safety Management System will get your blood flowing. It is appropriately formatted and thorough in its content. And its completeness is a weakness. In the real world, the longer the manual, the more difficult it is to see the forest for the trees.
But there are strengths. It is a consolidated document of information regarding a flight department. A single source of reference where thoughtful, personal limitations are codified. A mode and means of communication for flight department personnel. A plan of action when things go wrong. It is a constant feedback loop of risks and improvements. It is a springboard for incoming personnel. It answers, “How will we operate to remain safe now and in the future?” It articulates the Safety System you already have in place and is an excellent thought exercise to describe and refine how you operate.
On one hand, an SMS can be cumbersome and distracting to create and maintain. Conversely, it can be a great clarifying tool for your operation. Despite my critiques of SMS, they have made me a better pilot by strengthening my thoughtfulness, preparedness, communication, and professionalism.
Aviate
Now that I am in the world of fully developed SMS manuals, I still view my previous system as my foundation for safety. It is how I prioritize and filter a vast amount of information into action steps for which I am responsible. So what do you do? Forgo the hassle or dive in? Consider the following levels of implementation:
I don’t need it, I don’t want it. I like your priorities, but I will not actively use an SMS. Fine, understanding yourself is a good thing. At least look through a table of contents for an SMS and see if you have addressed the different categories they include. NBAA PUBLISHES A PROPOSED IS-BAO TABLE OF CONTENTS for free.
I want one, but I like it as easy as possible. Use a table of contents and create your own. It can be much simpler than it is usually presented. For example, pilot requirements: “per insurance.” Flight operations: “Part 91 regulations + no-ops with RCAM values less than 2.” It’s just a description of whatever you are comfortable with. NBAA members can access the latest NBAA MANAGEMENT GUIDE. It is a complete resource intended to touch on all topics of running a flight department.
Full on. Utilize a service to create and customize a fully developed SMS program. Unfortunately, if regulatory compliance is required, this is probably the minimum level you can go to. And then don’t forget, it’s a living document that is not intended to get dusty on the shelf. AVIATION MANUALS is a good resource, or IBAC can walk you through their IS-BAO CERTIFICATION PROGRAM.
Regardless of your implementation level, everyone should collaborate with others. Network, keep reading, asking, and learning. Don’t be a Flight Department on an Island. Cheat, copy what others do if you think it has merit. This isn’t English class; this is real-world life and death. Above all, check your fluids and flight controls every time.
