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The FAA issued SMS regulations for part 121 in 2015 and part 139 in 2023, with plans to issue a regulation for part 135 operators taking effect on May 26, 2024. The rule will apply to nearly 1,850 Part 135 operators, and more than 700 air-tour providers.
The new regulation will incorporate AC120-92B as the SMS "standard" and generally follow part 121's part 5 to ensure standardization and conformity. The FAA will determine compliance to the regulation during onsite inspections.
Part 135 operators will be given plenty of time to adopt (typically 36 months) their programs and may be required to submit their implementation plans to the FAA for approval.
The SMS can take aviation service providers up to 1380 hours to implement the basic SMS framework when done in-house with existing staff. In other words, the SMS represents a significant project management challenge, one that requires experience and a very specific skill-set to ensure conformity to the standard and more importantly, that you benefit from SMS.
Most small to medium sized flight departments, airports and maintenance providers have staffing constraints, and that means SMS planning and implementation will be highly disruptive to normal operations. And, once implemented, the SMS will likely be managed as a part time endeavor and as an ancillary role to existing responsibilities, which tends to increase workload, lowers morale and raises risks.
After spending the past two decades planning, implementing and managing SMS, our best advice is to get expert help before you even think about implementing the SMS. Make no mistake, the SMS has a steep learning curve as we can attest and is a relatively complex standard that provides lots of opportunities to make costly mistakes should you choose to tackle it in-house.
PART 135. We implement SMS following the current standard found in AC120-92B and Part 5 of the regulation. That regulation is currently aimed at part 121 operators, but will eventually be expanded to include part 135.
The major challenge facing part 135 is the same one facing part's 91 and 139, staffing constraints. Small operators typically manage their SMS on a part time basis and as an ancillary role, which impacts workload and ensures an underperforming program.
From hundreds of audits, we've learned most operators are not fully benefiting from their programs for several reasons:
1. Staffing constraints
2. SMS managed Part time and as ancillary role
3. Low participation from personnel
4. Inadequate training
5. Lack of resources
Since 2006, our approach has been to fully train all personnel before starting the SMS implementation process. Since SMS requires an established safety culture, providing the big picture early on ensures the operator is culturally prepared for SMS.
Implementing the framework is the easy part, integrating SMS into your existing safety culture is more challenging and requires full participation, buy-in and leadership.
Our experience means you avoid the frustration of an in-house attempt and the disruption and distraction it can cause. And, you'll have the peace of mind in knowing your program meets the standard and more importantly, will deliver real benefit.
PART 91. Since 2006, corporate flight departments with international exposure have been required to implement an SMS per the ICAO SMS mandate. Some operators chose to pursue a quality management program such as the ISBAO, while the majority pursued a stand-a-lone SMS solution. Fast forward to today and many operators are now looking for SMS support that ensures standard conformity, but more importantly, ways to fully benefit from their programs.
For new operators looking to adopt SMS, we provide a fully conforming SMS that meets all industry standards and ICAO requirements in about 3-days. As part of that process, we provide training and 12 months of professional management, that once you see how cost effective it is, you'll likely stay in the program.
PART 139. The FAA publication date for the SMS final rule was February 17, 2023 and applies initially to 268 airports within the NPIAS. The other 276 airports will eventually voluntarily adopt the program over time, as the SMS becomes the industry standard.
We have a broad range of options for airports, from initial implementation planning, manuals and training, to turn key implementations, conformity audits and everything in between. Call or email us today for a detailed proposal.
PART 145. For MRO's, adopting and integrating the SMS standard into your operation should be easy if you already have a QMS such as ISO 9001 or the 9100 standard.
If you are starting from scratch, plan on a significant project that will take 1 to 3 years to fully adopt should you decide to "self-implement". In that case, we recommend you contract the initial implementation to phase 2 of the FAA maturity ladder, and then take over at that point.
You will want to avoid the disruption and distraction that is typical in the early stages of the SMS implementation process. We have a program that meets that goal and can be accomplished in roughly 10-14 days. For more information and a detailed proposal, call or email us anytime.
I retired from my flying career in 2004 and spent the next two years as an apprentice working for a company that specialized in SMS, QMS and EMS program implementations.
Since 2006, I've done hundreds of SMS implementations and confirmation of conformity audits and continue to provide SMS management support services to dozens of flight departments.
While, I have experienced SME partners I can call on when needed, for the most part my primary partner is the customer, who knows their operation better than anyone. My goal is to make your transition to SMS a simple process that is affordable.
John Davisson
Owner