Don't Wait for FAA to Mandate Implementation of Safety Management System

When I was learning to fly, we were taught to scan the horizon to see and avoid other aircraft. As an industry, we need to improve our scanning techniques to see and avoid safety hazards on the airfield. Safety Management System (SMS) implementation will help us improve hazard awareness, the ability to set appropriate priorities and our decision-making processes and practices.

SMS has already been adopted as the minimum standard of safety care by the International Civil Aviation Organization, other countries' civil aviation authorities, international and domestic air carriers, and all branches of the U.S military.

Most airports have sound safety policies and procedures in place; they merely need to be expanded or adjusted to a more proactive safety approach. For example, we need to incorporate Safety Reporting/Data Collection and Hazard Identification into our operational practices. Smaller airports can utilize simple manual databases such as Excel; whereas larger airports may need a more complex system because of the volume of reports and identified hazards.

Although the FAA is accustomed to being prescriptive regarding policy enforcement, that should not be the case with SMS and safety risk management (SRM). Every airport's risk profile and thresholds are different and must be individually evaluated and considered. In the past, the FAA has maintained an underlying belief that non-standard equates to unsafe, until evaluated by the FAA and deemed "safe" or compliant. In an SMS environment, such a position undermines the very nature of SMS
and its predication on determining "safe" operations via local collaborative assessment and mitigation of risks. We need a more flexible approach that allows every airport to adapt its SMS program and associated risk matrix to its own needs, resource availability and risk profile. The FAA should develop a framework of best practices, establishing baseline expectations and processes, rather than prescribe specific SMS practices or its compliance. 

SRM panel attendance and/or facilitation is another issue. As large hub airports are finding, it can be difficult to ensure all the appropriate players attend risk assessment panels, and coordination between the FAA's lines of business is relegated to the airport. It remains unclear what remedies an airport has, and its impact on the construction process and schedule, if the FAA is unable to attend.

Additionally, it's unclear as to who within the FAA has final authority regarding the approval and acceptance of panel outcomes. ATO is designated as having authority for anything affecting the NAS, but has interpreted this affect as anything occurring on the airport, which conflicts with ARP's jurisdictional authority interpretation related to projects regardless of their location.

Industry trade associations should lead and oversee certain aspects of SMS - especially the management of hazard data. Without a centralized repository for airport hazard data, we are unable to fully benefit from such information. Lessons learned, root causes, contributing factors and trends will be more easily recognized and evident through a more holistic national database approach. The National Wildlife Strike Database is a prime example of how effective this strategy can be. A national airfield hazard database, sponsored by an industry trade organization, could provide greater protection from disclosure of such data via Freedom of Information Act requests, thus removing a layer of resistance to reporting of hazards. The information can be de-identified by the managing organization and provided to airports and the industry in a generic, but meaningful, way.

So why do we remain skeptical about SMS costs and want to wait until it's required? We have become conditioned to wait and see how, and to what extent, the FAA will mandate its policy. SMS, however, merits a more assertive, industry-led approach. The FAA's recent delay in SMS rulemaking is an opportunity to remain engaged in the regulatory process, share our ideas and take a more active leadership role. The implementation of SMS makes good business sense, is a more defendable safety response, improves hazard and safety communications, and ensures better, more collaborative safety decision-making and planning. Even though the mandated implementation of SMS currently looks hazy, the benefits of acting now are clear.