[Peetwo]

In another hemisphere: Aviation Safety and SMS?? -   

From the grown up world of Safety Risk Management, we get this excellent contribution from David Huntzinger, via Linkedin reflecting on the AIN article ..."NTSB's Graham: Scalable SMS a Must for Smaller Aircraft Ops"... 

Dave Huntzinger 
Associate VP at Laminaar Aviation Infotech Americas, Inc

I read with interest NTSB Member Graham's comments about proposed rulemaking for Part 135 SMS programs. He, along with many others, ascribe to the notion that any SMS program required of 135 operators, must be "scalable", especially for the small operators. The FAA has said there will be no relief from the requirements.

The trouble is, there is precious little guidance on what constitutes "scalable".

Please allow one practitioner to offer some context that may help others understand how to implement an SMS using scalable practices. I am going to skip to Pillar #2, Safety Risk Management, and talk first about Hazard Identification and Risk Assessment.

How do we identify Hazards? There are about 10 or12 tools available to the safety practitioner, roughly spaced between reactive, proactive and predictive methods. These include
Reactive (after the case), Event Reporting Systems (including ASAP), Investigations, Flight Data Analysis
Proactive (looking for trouble), Audits, Safety Surveys, JHA/JSA, Flight Data Analysis
Predictive (proactive with risk value based on severity and probability, gives the predictive status), FRAT, Risk Assessment, Safety Risk Profile, Change Management

Now, for the context. A large operator, such as an airline, probably uses all of these. A small operator would be buried with that load. I propose we pick three of these for the small operator
Tool #1, Reactive. Event Report System. If you are an owner/operator, this is easy. A paper journal or log book will suffice. An electronic version is nice. It makes the Safety Assessment activities easy. What do you record? Anything non-standard that happened during the day. Scare yourself silly? Record it, risk assess and develop corrective or mitigative actions.

Tool #2, Proactive. Audit. This compares what you are doing with an accepted industry standard. There are many audits out there. Some you have to pay for. Or use the internationally recognized SMICG. Audit a friend in exchange for them auditing you. This can be done during scheduled maintenance. The insurance companies are using Safety SMEs to help their clients. Try them. Findings can be entered into your Event Reporting System and managed exactly the same way.

Tool #3, Predictive. FRAT. I know, I know. Are you fire fighting with a B-3 and a Bambi Bucket? I don't expect you to do one for every lift. Ridiculous. How about one for morning and one for the afternoon?

These three tools provide an all-around record of your operation. It pretty much satisfies all the elements of Pillar #2.

For Pillar #3, Safety Assurance, reviews your entries regularly, say each month. At least annually. This shows your risk exposure over time. Continuous Improvement.

Pillars 1 & 4 could fall into the "1 and Done" bucket. There are plenty of service providers that can give you a Safety Policy, SMS training powerpoints and other support documents.

Hope this helps with "scalable". I am space limited. Have to go.

And the AIN article:

NTSB's Graham: Scalable SMS a Must for Smaller Aircraft Ops
by Kerry Lynch - March 23, 2023, 11:03 AM


NTSB member Michael Graham expressed concerns about the recent spate of close calls in aviation and said this highlights why SMS should be fully used. (Photo: Kerry Lynch)

National Transportation Safety Board (NTSB) member Michael Graham stressed his belief that there should be no exceptions for size from the FAA’s safety management system (SMS) rulemaking but did say the final regulation must be scalable for small operators. During the Air Charter Safety Foundation’s Safety Symposium on Wednesday in Daytona Beach, Florida, Graham noted that the NTSB has been pushing for the FAA to mandate SMS for Part 135 since 2016, following the Hawker 700A crash in Akron, Ohio.

“The voluntary days are over with. We didn't hit enough people,” he said, adding that about 10 to 12 percent of Part 135 operators have adopted SMS. “We’re talking out of 2,000 operators. You can do the math and that's not many. The time is over. The safety benefits are there. We all need to get there.”

He said the NTSB was pleased that the FAA had released the notice of proposed rulemaking to extend SMS requirements to Part 135 and air-tour operators. While some have asked about alternatives for the smallest operators, Graham said the answer should be: “Nope. You don’t have an SMS if you don’t have all four components [safety policy, risk management, assurance, and promotion].”

However, he has been pushing for guidance and scalability. “It has to be scalable. If it’s not, it’s never going to work.” Graham pointed to an NTSB recommendation that the FAA provide guidance on specific examples, methods, and techniques for small operators.

Thus far, the FAA’s draft guidance has not done that, he noted. “I read it. There’s nothing in there.” He said it only repeats language that it should be scalable. “It’s just like everything else: ‘scalable.’ Good luck. Good to go.”

Graham also expressed concern over the associated oversight. NTSB has asked the agency to require SMS and then verify the effectiveness. “We already see issues with oversight in a lot of our accidents with [Part] 135s. Now add SMS to it.”

Graham opened his discussion at ACSF talking about the “elephant in the room. Let’s face it. We’re all wondering what is going on with aviation right now.”

He pointed to the meltdown of the notam system, turbulence incidents, and the half-dozen near collisions that they’ve counted so far this year—but there are a couple of others the Safety Board is looking at right now, but still categorizing them.

The average for Category “A” and “B” close calls is about 17 to 18 per year. “Now we’ve got six of those in two months. That’s not good.”

Frustrating to the NTSB is the number of cockpit voice recording readouts it has been able to get out of these six events: “zero,” Graham said, noting that most get overwritten every two hours. NTSB has called for a 25-hour time on them, he stated. “We've got the technology out there. This is ridiculous. We’ve got to have this.”

Adding to this, he said, NTSB has received pushback on its efforts to interview crews afterward. As for reasons behind these incidents, he said “I don’t think it’s going to be one smoking gun. We’re investigating.”

He noted air traffic control procedures are among the areas being reviewed, but emphasized the importance of data and SMS. He pointed to the strong safety record of the airlines. “They earned it. They worked really hard, but I’m concerned,” Graham said. “Are we putting on the autopilot here? Are we just letting things run? Are we putting that SMS up on the shelf now? Because we all know you have to work continuously and manage risk and safety assurance. If you're not, you don't know when the next big one's going to happen.”

MTF...P2