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.

The ICAO deadline has been the focus. The fact that some States have already implemented the requirement for an SMS is being overlooked.

Relevance of the ICAO Deadline

I would like to start here because this is the area of greatest confusion and misinterpretation. The ICAO deadline is primarily for States (Countries) to create their rules. The requirement for an SMS is dependent upon, and listed in the following order of relevance:

  1. The requirement of your State of registration;
  2. The requirement of the State in which you operate;
  3. If the State in which you are registered or operate does not have a civil aviation regulatory body then, and only then, will the ICAO requirement apply.

Key Points about State Differences

If a State does not comply with the ICAO requirement the State will file a difference with ICAO, which nullifies the ICAO requirement in that State for operators registered in said State.

When an operator operates into, within, or out of a territory where the Treaty (ICAO) applies, that operator is subject to the oversight of their State of registry, as well as the State or Community where the operations occur. What this means is:

  1. Operators of a State that has filed a difference with ICAO are not required to comply with the ICAO requirement, for which the difference was filed, while operating in that State’s airspace;
  2. Operators of a State that has filed a difference are not exempt from ICAO, or third-country State requirements, while operating in that third-country State, unless the third-country State agrees to accept that difference; and
  3. Operators are not exempt from ICAO requirements, or the requirements of their State of registry, while operating in the airspace of a third-country State that has filed a difference.

There is an important distinction here.

The ICAO deadline has been the focus and the fact that some States have already implemented the requirement for an SMS is being overlooked. For example; Canada currently requires an SMS for private aircraft operators of turbine-powered pressurized airplanes. (CAR 604)

An SMS is a Toolbox

The SMS provides a strategy for organizing all of your tools. Typical tools may include company policies, standard operating procedures, training programs, emergency response plan, environmental protection, corporate quality initiatives, etc.

An “Off-The-Shelf” SMS

The tools in your toolbox are dependent upon the complexity of your operational environment. A properly designed SMS is tailored specifically for the individual operation. For years, aviation regulation has been about check-box compliance and some operators adopt this approach to SMS development. This approach may get you through an initial audit but it won’t establish the safety objective. It will likely do the opposite.

The “off-the-shelf” SMS is a frustration for operational personnel. It rarely addresses the real safety issues and often muddles up the operator’s SOPs to the point of invalidating their relevance amongst line personnel. In all but rare circumstances, an “off-the-shelf” SMS will not address the operators true safety risk profile.

Shifting the Focus

The traditional focus on safety has been reactive. The SMS provides an alternative understanding by examining the total context of the operational system. It shifts the focus from human error to human factors.

The shifting focus will be a topic of a future article.