The goal of this blog is to simplify the complicated processes associated with aviation safety management systems (SMS). This will be accomplished by means of short, targeted articles on important SMS topics. Announcements, when SMS relevant, will be provided from time to time.

Please feel free to ask questions, comment on the articles, or contact me directly to discuss a topic of interest.  Additionally, you are invited to visit the Air Safety Group web site to learn more about our professional service offerings.

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In a recent post on the NBAA AirMail forum an operator questioned the discovery, during an IS-BAO audit, of the requirement for a flight data recorder (FDR) to be installed on their aircraft. The individual did not provide information, regarding aircraft type or age, so it is not possible to address the FDR requirements specifically for this operator.

To discover how an operator could be surprised by this requirement let’s take a look at each of the IS-BAO FDR/CVR requirements and how they relate to the ICAO and FAA requirements.  What becomes evident is the IS-BAO Standard stays true to the ICAO SARPS and bases the FDR/CVR requirements on aircraft weight, whereas the FARs deviate from the ICAO SARPS and base the FDR/CVR requirements on the number of passenger seats. Note that the FARs applicability dates also deviate from the ICAO SARPS.

IS-BAO 8.14.1
All aeroplanes for which the individual certificate of airworthiness was first issued on or after January 1, 1989 and that have a maximum certificated take-off mass over 27,000 kg (59,525 lbs), shall be equipped with a Type I flight data recorder.

ICAO Annex 6, Part 2, Section 3.6.3.3
Flight data recorders — aeroplanes for which the individual certificate of airworthiness is first issued on or after 1 January 1989

3.6.3.3.1
All aeroplanes of a maximum certificated take-off mass of over 27,000 kg shall be equipped with a Type I flight data recorder.

FAR 91.609(c)

(1)
No person may operate a U.S. civil registered, multiengine, turbine-powered airplane or rotorcraft having a passenger seating configuration, excluding any pilot seats of 10 or more that has been manufactured after October 11, 1991, unless it is equipped with one or more approved flight recorders that….

(2)
All airplanes subject to paragraph (c)(1) of this section that are manufactured before April 7, 2010, by April 7, 2012 [compliance date], must meet the requirements of §23.1459(a)(7) or §25.1459(a)(8) of this chapter, as applicable.

(3)
All airplanes and rotorcraft subject to paragraph (c)(1) of this section that are manufactured on or after April 7, 2010, must meet the flight data recorder requirements of §23.1459, §25.1459, §27.1459, or §29.1459 of this chapter, as applicable, and retain……

IS-BAO 8.14.2
All aeroplanes for which the individual certificate of airworthiness was first issued on or after January 1, 2005 that have a maximum certificated take-off mass of over 5,700 kg (12,567 lbs) shall be equipped with a Type IA flight data recorder.

ICAO Annex 6, Part 2, Section 3.6.3.4
Flight data recorders — aeroplanes for which the individual certificate of airworthiness is first issued after 1 January 2005

All aeroplanes of a maximum certificated take-off mass of over 5,700 kg shall be equipped with a Type IA flight data recorder. [Type IA flight data recorders are explained in Annex 6 Part II Section 3.6.3.1.8]

FAR 91.609 (c)

See (1)-(3) above.

IS-BAO 8.14.3
It is recommended that all aircraft for which the individual certificate of airworthiness was first issued on or after January 1, 1989 and that have a maximum certificated take-off mass over 5,700 kg should be equipped with a Type II flight data recorder.

ICAO Annex 6, Part 2, Section 3.6.3.3
Flight data recorders — aeroplanes for which the individual certificate of airworthiness is first issued on or after 1 January 1989

3.6.3.3.2
Recommendation — All aeroplanes of a maximum certificated take-off mass of over 5,700 kg up to and including 27,000 kg should be equipped with a Type II flight data recorder.

FAR 91.609 (c)

See (1)-(3) above.

IS-BAO 8.14.4
All aeroplanes for which the individual certificate of airworthiness was first issued on or after January 1, 1989 and that have a maximum take-off mass over 27,000 kg shall be equipped with a cockpit voice recorder.

ICAO Annex 6, Part 2, Section 3.6.3.5
Cockpit voice recorders — aeroplanes for which the individual certificate of airworthiness is first issued on or after 1 January 1987 [note applicability date] 

3.6.3.5.1
All aeroplanes of a maximum certificated take-off mass of over 27,000 kg shall be equipped with a cockpit voice recorder, the objective of which is the recording of the aural environment on the flight deck during flight time.

FAR 91.609(e)
Unless otherwise authorized by the Administrator, after October 11, 1991, no person may operate a U.S. civil registered multiengine, turbine-powered airplane or rotorcraft having a passenger seating configuration of six passengers or more and for which two pilots are required by type certification or operating rule unless it is equipped with an approved cockpit voice recorder that:

(1)
Is installed in compliance with §23.1457(a)(1) and (2), (b), (c), (d)(1)(i), (2) and (3), (e), (f), and (g); §25.1457(a)(1) and (2), (b), (c), (d)(1)(i), (2) and (3), (e), (f), and (g); §27.1457(a)(1) and (2), (b), (c), (d)(1)(i), (2) and (3), (e), (f), and (g); or §29.1457(a)(1) and (2), (b), (c), (d)(1)(i), (2) and (3), (e), (f), and (g) of this chapter, as applicable; and

IS-BAO 8.14.5
It is recommended that all aeroplanes that have a maximum certificated take-off mass of more than 5,700 kg, should be equipped with a cockpit voice recorder.

ICAO Annex 6, Part 2, 3.6.3.5
Cockpit voice recorders — aeroplanes for which the individual certificate of airworthiness is first issued on or after 1 January 1987

3.6.3.5.2
Recommendation — All aeroplanes of a maximum certificated take-off mass of over 5,700 kg up to and including 27,000 kg should be equipped with a cockpit voice recorder, the objective of which is the recording of the aural environment on the flight deck during flight time.

FAR 91.609(e)

See (e)(1) above.

On March 16, 2010 Canada’s Transport Minister, John Baird, announced that Transport Canada will take back the certification and oversight functions for business aviation from the Canadian Business Aviation Association (CBAA).

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Progressing To the Next Level of Safety Management

This article is the third in a series of articles that takes a closer look at the aviation safety management system. The entire series can be found here.

In the previous article; “The Shifting Focus of Safety Management,” I made the statement; “In order to progress to the next level of safety management, a performance based approach is required to assess the actual performance of activities against organizational controls.”
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The Shifting Focus of Safety Management

This article is the second in a series of articles that takes a closer look at the aviation safety management system. The entire series can be found here.

Historically, aviation safety management has been based of regulatory compliance.  There is no argument that regulatory compliance is an important part of safety management, although it is impossible to provide rules for every operational situation.

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I read a copy of an email today from Civil Aviation Communications Centre, Transport Canada, which follows.

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The NTSB is amending its regulations concerning notification and reporting requirements regarding aircraft accidents or incidents, which will become effective March 8, 2010.

The final rule herein codifies the addition of five reportable incidents, the reporting of which the NTSB believes will improve aviation safety.

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A Review of What We Have Learned

This article is the first in a series of articles that takes a closer look at the aviation safety management system. The entire series can be found here.

I would like to begin this article series with a synopsis of the seven-part article series; “Understanding the SMS.” Following this synopsis, future articles will discuss the SMS components and implementation in greater detail.

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Do you need an SMS

This seventh and final article is a series to simplify the understanding of the SMS processes. The entire series can be found here.

It is not about the ICAO deadline

Many operators are hung up on ICAO dates for determining when or if they need an SMS. The primary factor in determining the requirements for an SMS is the regulatory requirement of your country of registration and your area of operation. The ICAO deadline is applicable only in absence of a regulatory agency.

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IS-BAO – It’s more than an SMS

This article is the sixth in a series to simplify the understanding of the SMS processes. The entire series can be found here.

History of ICAO Annex 6, Part II

Annex 6, Part II, International General Aviation – Aeroplanes, was first introduced in 1968. Since that time, a number of amendments have been made, but the basic structure of this Part remained geared towards a general aviation environment typically operated for recreational purposes, domestically as well as internationally.

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I previously reported the FAA’s proposal for Safety Management Systems [Docket No. FAA–2009–0671; Notice No. 09–06].

http://proairman.com/faa-proposes-safety-management-systems/

On December 9 there were 169 comments posted on the FAA web site.