An element of the SMS has long left me unsure about its implementation. This is the need “. . . to develop a procedure to identify and maintain
compliance with
current safety-related legal, regulatory, and statutory requirements . . .” (FAA AC 120-92A). As expected, this is called “compliance” when the auditors come to visit.
By my reckoning, to implement this SMS compliance element completely, a safety department would have to know whenever rules, regulations and procedures change in regulatory documents from say, for example, ICAO, applicable national regulatory agencies (e.g., FAA, EASA, DGCA, etc.) and federal and local regulatory agencies (e.g., OSHA, state and city laws, others). Even if you didn’t keep up with all regulatory changes, you’d at least have to know about the important, applicable-to-you rules and that, by itself, could be a full-time job.
So how do other companies ensure they “remain compliant” with the latest regulations? Surely, not everyone can hire a full-time aviation lawyer. Is there any electronic, automated way to constantly check applicable regulations for changes? At the very least, what do you have written in your SMSes about “compliance” to keep the auditors happy? Thanks for any advice or inspiration.
