Aviation SMS Are Not Required by All Operators
In November 2006, the International Civil Aviation Organization (ICA0) mandated the implementation of formal aviation safety management systems (SMS) for most commercial aviation service providers. Besides the usual suspects of large airlines and airports, the list of required operators includes
- flight schools,
- aircraft designers,
- aircraft parts manufacturers, and
- aircraft manufacturers.
To provide SMS implementation guidance, ICAO released the Safety Management Manual (SMM), now in its fourth edition. This user-friendly SMS Bible provides an abundance of useful information to help safety professionals and managers understand SMS requirements as they undergo the SMS implementation process.
While most commercial aviation service providers are required to implement SMS, this is not a blanket mandate. There are many exceptions, notably local private operators that do not fly outside their country of origin and very small airports. If you are uncertain whether your operations require an aviation SMS, contact your civil aviation authority (CAA) or review your CAA's SMS regulatory guidance if available.
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Aviation SMS Structure Same for All Operators, But...
An SMS implementation includes the same elements regardless of industry segment type. This means that SMS requirements are the same for:
- aviation maintenance organizations (AMO / MRO);
- flight schools;
- charter operators;
- aircraft manufacturers;
- air traffic organizations (ATO); and
- fixed based operators (FBOs).
While SMS requirements are the same for all industry segment types, the level of sophistication that an aviation SMS is expected to demonstrate is dependent on the size and complexity of the operator. It makes sense that large, commercial airlines are expected to have an SMS database to demonstrate:
- continuous improvement;
- safety trends; and
- documented proof of all safety activities, such as SMS training and audits.
Risk Based Oversight Addresses Both Large and Complex Operations
Regulatory SMS oversight is risk based. After determining whether an operator has all the required SMS elements, SMS auditors will judge an operator's SMS implementation based on their risk profile and determine whether the level of SMS performance documentation is commensurate with both the size of the operator and their risk profile. In some cases, these factors may mirror each other. For example, a large international airline naturally is exposed to more risk than domestic airlines.
Looking at risk from another angle, a small company with multiple operation types is exposed to more risk than operators conducting only one type of business. For example, we have clients that are small companies, but they may have:
- fixed wing charter operations;
- rotary wing scenic tours;
- FBO; and
- at least one AMO.
This is only one combination that comes to mind. Other popular combinations include:
- flight school;
- fixed wing charters; and
Both large and complex operators will need more advanced SMS data management strategies than small, simple operators. These operators have a higher burden to satisfy to demonstrate:
- safety performance monitoring activities;
- tracking of safety tasks; and
- continuous improvement of the SMS.
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Small Complex Operators Require More Oversight
So besides the larger airlines and airports, small companies with multiple types of operations understandably have more risk than operators dedicated to one line of business. We must remember that these companies are still very small and lack the financial resources of larger operators. Many have fewer than 100 employees across all business units.
We can easily see that as an operator has more than one type of operation, risk naturally increases exponentially with each additional type of operation. These small, but complex operation types will face higher levels of regulatory scrutiny when SMS auditors practice risk based oversight. Of course, this is how it should be.
Even though SMS regulatory auditors may use the same auditing protocols for all operators, the SMS documentation required by simple operators will not be as extensive as larger and complex operators. For example, when auditors wish to review SMS performance monitoring, a large operator may be expected to demonstrate SMS performance monitoring by using real-time charting tools and performance monitoring dashboards. Very small operators may be asked for a list of reported safety issues and documentation as to how they were managed.
Managing SMS Documentation Requirements in SMS Database
There may be times when you wonder whether your operation needs an aviation SMS database to manage standard SMS documentation requirements, such as:
- Hazard reporting;
- Risk management activities;
- Initial and recurrent SMS training;
- Management reviews of SMS performance; and
- Safety promotion activities.
Aviation SMS databases have the "potential" to save time and money. They also facilitate regulatory compliance by ensuring all SMS documentation requirements are managed appropriately. A best practice is to have all SMS documentation in one centralized repository that can be accessed by employees based on their role in the SMS.
Furthermore, modern, full-featured SMS database software serves as templates to provide confidence to stakeholders that regulatory requirements are not inadvertently overlooked. Management also receives additional assurance that risk management processes are managed according to the "system design." Commercial, off-the-shelf database solutions come configured with well-defined risk management processes that follow the aviation industry's best practices.
Given the benefits of aviation SMS databases, there are times when you should not waste your money on this technology.
Many companies across the world will be throwing their money away if they purchase aviation SMS software or subscribe to aviation SMS software as a service. Let's explore four reasons your company may not want to invest in an aviation-specific SMS database program.
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We Are Not Yet Required to Comply with SMS Regulations
Not all aviation service providers are required to implement formal aviation SMS.
Those that are required are typical:
- Airports (aerodromes);
- Aviation maintenance organizations;
- Flight schools;
- Fixed based operators;
- Aircraft or aircraft parts manufacturers;
- Air traffic control; and
- On-demand charter operators.
Depending on the region and the type of operation, some smaller operators don't have to implement an aviation SMS.
If you are not required to implement an aviation SMS, why would you purchase aviation SMS software? Reasons could include:
- Client contract requirements;
- Enhancing safety reputation; or
- Proactive risk management attitude by management.
Besides the three reasons listed above, I am not sure why an operator not required to implement SMS would purchase aviation SMS database software.
An Abundance of Cheap Labor to Manage SMS Documentation
Even if your company is required to have a formal SMS implementation does not immediately dictate that you should spend money on an aviation SMS database. If your company has lots of inexpensive, skilled labor, all of the tasks can be completed using:
- MS Word;
- MS Excel;
- MS PowerPoint; and
Having lots of affordable, skilled labor does not always equate to not needing aviation SMS database software. This skilled labor force must also be dependable to ensure that all SMS documentation requirements are dutifully managed.
Having great software doesn't guarantee SMS compliance either. SMS software is just a tool, just like an aircraft. You can have many aircraft in your livery, but if you don't use them, your corporate mission will not be achieved.
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We Have Very Few Reported Safety Issues to Manage
If you have only a few safety issues to manage each year, you may be able to manage them manually using spreadsheets and email. Unless you operate in Europe (required to submit to ECCAIRS), I have seen no formal regulatory requirement requiring a database to store data related to reported safety issues.
Having a few reported safety issues is not necessarily an indication of a safe company. Few reported safety issues generally mean that your company has a poor safety reporting culture.
A good rule of thumb for healthy reporting cultures is either:
- One reported issue for every ten employees per month; or
- One reported issue per employee per year.
We Are Good at “Influencing” the Auditors
Some companies buy their SMS compliance by influencing SMS auditors. This is not an ethical practice. We know it is happening but I'm not here to pass judgment.
Influencing auditors' objective reporting will work in the short term, but don't expect it to last. There are no surprises when we see these reports as they are happening in countries with high corruption indexes.
If your managers are great at influencing auditors, there is obviously no need to acquire aviation safety database software. Your company's safety culture is not yet ready to earnestly tackle and implement a legitimate and performing aviation SMS.
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Our Safety Culture Will Never Improve
Some companies are focused solely on mission performance and view safety as a "nice to have" or "secondary consideration."
Then there are those companies that don't like being told what to do and resist government insistence that they operate according to "certain best practices."
Other companies have a loose management style that doesn't force employees to abide by certain standards. These "loose" flying organizations naturally assume that employees will act in a safe manner.
You will see other companies possessing retaliatory mindsets toward employees when it comes to reported safety issues. When an accident happens, somebody is blamed and may be fired. The result is that nobody reports safety issues or all safety reports are submitted anonymously.
These are all examples of poor safety cultures. There are some deep organizational concerns to deal with before you tackle formal SMS implementations.
In all likelihood, you will not have sincere top management support. Without top management support, it is highly unlikely they will spend money on an aviation SMS database.
My best advice if you find yourself in this boat and tasked to implement an aviation SMS is:
- Fake it until you make it.
- Take small steps to change attitudes.
Hopefully, things will change over time. This is one reason that SMS implementations take so long. Deeply ingrained attitudes don't change quickly. SMS implementations require a progression of small steps to reach the goal.
Unstable Work Force on Safety Team
If your safety team is riding the revolving door, don't waste your money on an SMS database. I've seen this fail repeatedly.
High safety manager turnover rates guarantee that SMS implementations fail and you will be wasting your money on SMS software tools. When the next safety manager comes to fill the shoes of a predecessor, they may not even be aware of the database or how it works.
This may also be an argument for the necessity of an aviation SMS database. Aviation SMS software tools afford structure and continuity, especially if they are easy to learn. As a rule of thumb, if your operation has more than 40 employees, then an SMS database makes sense.
For smaller organizations, I also recommend that companies with high employee turnover adopt an SMS database. High employee turnover requires considerably more SMS training documentation management. The lack of appropriate SMS documentation is one of the biggest risks for smaller operators when they are audited.
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- 5 Times Documentation Saves Safety Managers in Aviation SMS
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Final Thoughts on Whether You Need an Aviation SMS Database
Each company is unique. Just because you are in the aviation industry does not mean you should run out and buy aviation SMS software.
You may not really need it. Or
Your company may not be ready for it.
If you are needing a modern aviation SMS database solution, we can help. Since 2007, SMS Pro has been working with aviation SMS implementations. These short demo videos will show you how to benefit from an SMS database.
Published November 2015. Last updated June 2019.