Safety Management Systems (SMS)

[commander900]

ICAO Annex 6 Part II requirements will require business operators flying internationally to have a SMS system in place by November 18, 2010.

There is allot of suggestion out there saying unless you are IS-BAO registered you may not be allowed to operate in Europe.

Does anyone know whether there is any truth in this? How are EASA planning to deal with this issue?

We will have an SMS in place that conforms to the IS-BAO format and the ICAO requirements however due to our location we weren't planning on IS-BAO registration.

There seems to be so much confusion out there on this issue...any thoughts welcome.

[Stratocaster]

First things first, EASA still has no published regulation to rule flight operations in the European skies. And it's not expected to be out for another 2 years. Yes, all the national authorities handed over their powers to EASA but we're still in a transition period from one system to another. And once the EASA Part OPS regulations will be out -supposedly in April 2012- you can expect another official "transition period" of anything between 6 and 24 months so that everyone can implement the new regulations (realistically 18 months ?).

Second, last August IS-BAO has been officially recognised as an industry standard by the European Committee for Standardisation (CEN). This means that EASA can now print what they've been saying for years but couldn't put it in writing for legal reasons, i.e. "if you're a bizav operator in Europe, and don't have an AOC, one way of meeting EASA requirements will be to show us your IS-BAO certificate of registration". Will there be another way? In theory yes, but if it ends up like in Bermuda where they discourage you to try the "home-made SMS" I don't think many people will give it a try (i.e. instead of having IS-BAO auditors in your office you'll probably have CAA inspectors -good luck trying to work with them if they've made their entire career in a major airline and don't understand bizav). No wonder EASA and IBAC both pushed for about 5 years to get this recognition.

Now in your case, it would probably not be a bad idea to have an external audit to make sure your SMS works. On the other hand I've heard (but not experienced myself yet) that during ramp checks an IS-BAO certificate is very helpful when the inspector wants to know whether you have an SMS or not.

Conclusion (from my point of view): no, there's no urgency to become IS-BAO registered but waiting for the last limit is not recommended either.

Hope this helps !
(PM welcome if you prefer)

[His dudeness]

Conclusion (from my point of view): no, there's no urgency to become IS-BAO registered but waiting for the last limit is not recommended either.

Sounds like good advice...I have tried to get clarification on that from 'my' authority (the german LBA) but had no success. Also I crawled through a lot of EASA.eu drivel but have not found a real solid statement.

It sucks.

[aw ditor]

Strato.'

If an Operator decides to go down the non-ISBAO route with Bermuda (and a number have) you do not get CAA Auditors/Inspectors waiting on your doorstep. There are a couple of "Bermuda acceptable" companies providing AN(OT)O Article 85/OTAR 91/125 Ops.Manuals which include an SMS. Please see the Bermuda DCA website. I concur we are waiting to see what EASA will do from a policy viewpont. Presumably once policy and timescale are decided it will be up to the National Authorities to apply the rules across their Registry, hopefully, equably across Europe.

A.D.

[Stratocaster]

Hmmm, well the 2 "off-the-shelf" manuals I've seen so far are -in my humble opinion- either:
based on outdated (ICAO?) guidance material
thicker than the L.A. phonebook but beat around the bush for ages and miss their target
...If not both.

So it may be fine for a major airline with lots of (hopefully cheap and underworked) staff to tailor these generic manuals, and it may impress a rookie auditor/inspector, but for a bizav company I still think the IS-BAO Generic COM remains the best start point. Partly because at least they don't even try to make you believe that an SMS can be simultaneously "copy-pasted" AND meaningful for your company. Yes, you'll probably have to spend days on your own SMS chapter but if you're serious about safety you won't mind the investment.

And as I understand it, stating that if you buy an ops manual from a "Bermuda acceptable" company then you won't get an inspector on your doorstep is misleading... and actually quite the contrary of what OTAR Part 125.21 says.

[aw ditor]

Strato

Re Post 5, you will not, repeat not, get a UK CAA FOI/Auditor on your doorstep as you implied in a previous post. You may well get a Bermuda DCA Auditor visit you (I'm not one!) but my experience of them so far is they have a practical approach to the Corporate/Private sector. They simply expect you, not unreasonably, to operate in accordance with/to your AN(OT)O Article 85(6) "Approved" Ops.Manual, if you have gone down that particular route.

AD.

[Stratocaster]

Aaaah, perception is a tricky animal... I probably understand why you think that I stated that CAA auditors will get involved in case a VP-B company/flight department doesn't get IS-BAO registered. Yes, it can be understood this way. But actually that's not what I thought I was saying (i.e. was considering a company in Europe and used CAA as a generic term for all the authorities; ok NAA would have been better).

Fact remains that in their letter to operators the Bermuda DCA...
"(...) strongly recommends that you proceed in the manner described in Part 125.21(b), namely to become IS-BAO registered and comply with the standards demanded by the IBAC. If you decide to proceed in accordance with Part 125.21(c), the approval process could be protracted and your submitted Operations Manual, Safety Management System and Fatigue Management Scheme will be outsourced for review at your expense. (...)"

Is it reasonable to bypass an audit just because the manual is approved? Depends on the management team of the operator, depends on the manual, depends on the staff, depends on the authority, etc.

However I'm not sure countries and authorities can afford to keep a blind eye on bizav. Ok some do, some don't. The wreckage of the then-brand-new BD700 crashed in Fox Harbour showed that CAA/NAA/etc. cannot stay completely out of the loop.
Transportation Safety Board of Canada - AVIATION REPORTS - 2007 - A07A0134 (http://www.tsb.gc.ca/eng/rapports-reports/aviation/2007/a07a0134/a07a0134.asp)

[His dudeness]

So you honestly think an SMS would have prevented this Accident?

I´m managing a two-pilots one-aeroplane cooperate flight department, was flying commercially before. Honestly, I don´t see a benefit, all it does is putting more workload on me. If one is a reckless person no system in the world is preventing you from crashing. JAROPS and EU-OPS is the best example IMO of overregulation that does NOTHING for safety. Now we get something similar for the non-commercial sector.

I´d like to know if 'we' are actually worse than the rest of the industry, given the environment we do work in. I'm homebased at an airfield which is dangerous, I know that, my bosses know that and yet this airfield is why I have a job. So what difference will the SMS make?

[Stratocaster]

Ironically, the Canadian Business Aviation Association, through its auditors, said they had an SMS... Obviously their SMS didn't work too well for them.

First, let's try not to fall into the trap of saying that an SMS is a guarantee that you won't have an incident or accident (ever again). Example: look at NASA, probably the most experimental and complex human enterprise run very cautiously by -supposedly- some of the brightest guys in the aerospace industry. They've been doing risk management for decades but couldn't prevent the loss of human lives in two space shuttle crashes. With all the bells and whistles they have, how red-faced were they when they unintentionally 'burned' the Mars Climate Orbiter because their multinational teams didn't use the same units of measurements when programming the orbiter's entry into the Martian atmosphere (i.e. they found out their mistake only after they lost the expensive equipment)? There's a lot of fascinating litterature about the failures of NASA's risk management activities but it would be too long to explain here. One of the take-home-messages we can learn from their 'SMS failures' is that at that time they were trying to run the entire agency under the motto "Faster, better, cheaper". Unsurprizingly, you can have two of them, but not all three simultaneously.

Perhaps some of us will prefer to read a summary of the Fox Harbour accident in the article published by the Flight Safety Foundation:
http://flightsafety.org/asw/dec09-jan10/asw_dec09-jan10_p18-21.pdf

As well as the follow-up on the skewed relationship between TC and CBAA, which touches more on the SMS subject...
http://flightsafety.org/asw/dec09-jan10/asw_dec09-jan10_p22-25.pdf

How useful is SMS? To be brutally honnest, IMHO in the end it depends how humble and smart a company/flight department really is. Ok, money is a factor, but not a major one because NAA give you time to adapt. Actually they face the same kind of challenges as the rest of the industry but we're not here to discuss this issue here.

If someone falls into the trap of the "faster, better, cheaper" paradigm he'll most probably end up with botched-up training and manuals, rudimentary non-evolving systems, crappy company procedures and useless self-inflicted requirements based on irrational arguments and guesses. Yes, an SMS can easily turn into that kind of nightmare. Yes, an SMS can exacerbate the internal problems of a company/flight department to the point of eating its already-thin margins (i.e. in terms of safety and economic viability). There is absolutely no doubt about that!

There's no substitute for knowledge and intelligent thinking. On the other hand, managing safety is one of the most difficult things to do, especially now that we've improved so much. So let's face it: if we burn our hard-earned money on a 3-day SMS seminar attended by only 1 guy from the company, buy a generic manual we barely tailor, install an SMS software that can't import/export data from other applications and don't encourage staff to participate, then won't be able to make noticeably sounder decisions to manage risks wisely. Perhaps we'll have the illusion of safety but not much more than what we already had.

Is there light at the end of the tunnel? IMHO not if we take the "faster, better, cheaper" tunnel! Does it mean the only option is the "slower, better, expensive" tunnel? Fortunately not, and we should stay away from it too. By definition, there's no magic bullet to solve anybody's problems, but knowledge and intelligent thinking are good fertilisers for creative and meaningful ideas that really work.

Is bizav worse than the rest? There are numbers out there and apparently it's getting difficult to compare one sector against another. Even if you take the stats with the necessary pinch of salt, you can't deny that the accident rates are better on the airline side, and much worse on the G.A. side.
International Business Aviation Council (IBAC) (http://www.ibac.org/safety_brief.php)

[His dudeness]

if we burn our hard-earned money on a 3-day SMS seminar attended by only 1 guy from the company, buy a generic manual we barely tailor, install an SMS software that can't import/export data from other applications and don't encourage staff to participate, then won't be able to make noticeably sounder decisions to manage risks wisely. Perhaps we'll have the illusion of safety but not much more than what we already had.

Well, that sounds reasonable...however, if I look at my own example (2 Pilots/1 Airplane), I don´t see how SMS will improve things. (I´m not perfect, but I think I do my flight preparation reasonably well)

We will have to implement it, maybe it really gives us tools we never had before, but I honestly doubt it. It looks like another paper tiger. I briefly looked over the 2009 BA safety report, and it says that the total accident rate for jets operated acc. FAR135/JAROPS1 is 1.95 vs 0.24 coorperate and fatal accidents are 0.55 vs. 0.04 coorperate per 100.000 flight hours.
I found similar rated numbers for the airlines, but suspect that a comparison would be hard to make anyways, since they usually have less T/O and Landings and usually go to facilities well suited for them.

I´d love to see the authorities a move forward to increased simulator training as a strict rule for operators. Like initial on a sim, and then at least one event a year. And NOT paid for by the employee. That, IMO, would help to bring standards up.

[Stratocaster]

In your case, your own particular situation... Well, I have absolutely no idea. Not a single clue, your dudeness! But I totally sympathise with your efforts! :ok:

And I totally agree, more sim training would be helpful. As well as more training on non-technical skills.

[Karl Bamforth]

His Dudeness,

Most well managed companies will already be complying with most of the requirements of an SMS. The SMS is really about documenting what you do and making sure everyone in your company understand your standards and requirements, without the SMS its often a case of the boss just believes everyone understands but has never checked.

For a small company with only 2 pilots and 1 aircraft it doesn't take long to sort out. The main thing is don't buy a ready made one and leave it on the shelf or copy your mates, it is worse than not having one at all. For a small company it would be a very small document.

Have a look at the Canadian CAA website they have a great coverage on SMS introduction.

Most ppl that hate the idea of SMS it is simply a case of they don't understand it. I hated the idea and hated having more paperwork but after doing a one day seminar and realising what it is about I can see the value.

If I can be of any help PM me.

[His dudeness]

Karl, thanks for the hint towards canada.

For dummies as myself, there is an overview here:

TP14135 - Safety Management Systems for Small Aviation Operations - A Practical Guide to Implementation - Flight Training - General Aviation - Aviation Safety - Air Transportation - Transport Canada (http://www.tc.gc.ca/civilaviation/general/flttrain/sms/tp14135-1/menu.htm)

We already have a manual, checked and approved by our local authority that states safety as first priority, in which I have laid down a few things like minima (all according to EUOPS 1) and I have to say, management back us up all the way. When I say: we won´t fly they demand an explanation, but I never felt pressure by that, since they have accepted every explanation I have given them (not often the case, but...). We also have decided to make intermediate stops where we though it could get tight or the alternate situation is bad, and whilst not liking the extra hassle, we never were pushed by management. I guess this is the first step on the ladder. (I can fill manuals with as much procedures as I want, but reality can be different...)

I remember doing some freelance work on a CJ that I haven't flown before (had CJ experience but not on the particular airplane) and on this very first flight the destination was badly fogged in (like 100m and 55ff VV) and the passengers tried to force me to fly. I did not bend, but was never asked to fly for them again. Lucky me...

[Karl Bamforth]

His Dudeness,

Sounds like you most of the way there already, just spend a bit of your spare time revising it so it helps you.

As the SMS is "fully supported by Management", maybe a short procedure on how to deal with passengers trying to push you in bad weather would help others not as strong as you. All pilots know its their call, but if it is in the SMS and therefore has "Management support" pilots would feel under less pressure when making the decision. I know the pressure doesn't totally go away but having it written down instead of just words spoken by the management should relieve some of the pressure.

[Stratocaster]

My 2 cents... A new procedure would be a waste of time for everyone. 'Strong' pilots don't need a procedure, 'malleable' pilots will completely disregard it.

But you could (should) definitely dedicate a line or two on this subject in the safety policy. A statement, signed by the CEO, saying in essence "the PIC is the final authority on safety-related issues and no pax, regardless of his/her rank in the company, will mess with the crew or try to influence their decisions while under their authority". This sends a powerful message to everyone and ideally the pax should also get a copy of the safety policy before their first trip on a company aircraft.

There's a story about a NetJets pax arguing with the Captain about their decision no to land/leave a particular airport where the weather was crap, threatening the crew and saying he personnally knows Santulli, etc. The guy indeed calls senior management before the flight (not sure the itinerary was the one he wanted but it doesn't matter here). When the aircraft lands there's someone from NetJets waiting for him at the FBO or on the ramp. The two meet and the angry pax receives a check worth the time remaining he had on his NetJets account, with a letter and the best regards of Santulli. Something like "thanks for your business but we're not interested in customers like you".

The story is too good to be true but it seems Santulli is the kind of character capable of supporting his crews in such a strong way. So perhaps it's not just a rumour! :ok:

[601]

"the PIC is the final authority on safety-related issues and no pax, regardless of his/her rank in the company, will mess with the crew or try to influence their decisions while under their authority"

One boss I had added;

"If the passengers don't like it, leave them there and come home empty. They can then deal with me"

I still cannot figure how a SMS will work in a one pilot/one aeroplane organisation.

[Stratocaster]

Transport Canada offers guidance for (very) small operations, perhaps you should check it out.

[His dudeness]

I still cannot figure how a SMS will work in a one pilot/one aeroplane organisation.

Like when CRM was introduced...friend of mine was a singlehand jockey on a Cheyenne for 25 years and then had to have the CRM course...to continue flying his Cheyenne single hand...

Don´t think about it, its just catch 22...

[Stratocaster]

Surprise! Non-technical skills learned in CRM/HF courses can be applied inside the cockpit, but also outside. For instance with the ramp agent, the mechanic, the controller, the refueller, the pax, etc.

Every pilot has to know the limitations of his/her aircraft, I think it's well worth the effort to also learn human limitations. Check out what's going on in the healthcare industry where too many docs still think they're indefatigable gods and where denial is the norm. OK things are moving slowly there, but still...