lomapaseo;
The process must be acceptable to them, else you could lose yout TC.
Yes, but "acceptable" must be a sufficently high standard and that is both a political decision as well as an operational safety one. For example, it is my belief that if an airline passes the IOSA process the issues raised by PEI_3721 as well as other issues still obtain and in my view safety is not fully served as per our expectations of what SMS is and what is accomplishes.
While the actual IOSA process is comprehensive in its structure the answers to the questions are, again in my view, not always the whole picture and where a thorough audit process is intended, a less-than-thorough one can result, where shortcomings are "noted" and changes and/or improvements made after the passing of the audit.
In short, while the structure of oversight is essentially an audit of documents and processes, examining that what actually happens within the airline is in accordance with the documentation is not part of the IOSA or TC process or is at best a surface examination. The details are left "in-house", and that is where the risk in SMS arises.
Under SMS, "everyone" is responsible for safety, which is complete nonsense and entirely impractical not to say a conflict of priorities. A flight operations manager simply does not become a safety "expert" or specialist overnight and is far more likely to default to old habits and priorities which are entirely cost and schedule-driven. Take for example, the complexities of implementing an FDA Program. Are line managers going to take such a project on? Not at all. If "everyone" is responsible for safety, where does the leadership come from to implement such fundamental programs? Where do the justifications for resourcing such programs come from and how do they survive when such audits accept box-tick FDA programs?
Perhaps the notion will mature but, like the MCPL notion, I think the accident rate will have to rise before the realities of these cost-control initiatives settle in to the statistics.