Citing the size and complexity of the nation's aviation system, US regulators are still in the exploratory stages of defining a safety management system for participants in the industry to follow. As a result the country could be years away from meeting International Civil Aviation Organisation requirements.

This contrasts sharply with comments made at the US/Europe International Aviation Safety Conference in June when Federal Aviation Administration staff indicated that an advanced notice of proposed rulemaking could be released within 90 days.

Jay Pardee, FAA director of analytical safety services, says the agency has no definite dates for the release of the proposed rulemaking. Instead the plan is to "take our time and go slowly", ensuring regulators understand the implications of a safety management system (SMS).

Pardee believes a number of elements inherent in SMS are already part of the way many organisations operate today, resulting in FAA's "very considered approach" to rulemaking and its intent to develop SMS "in an intelligent way".

"We don't want to duplicate where resources are focused correctly now," he adds.


Another change from the FAA's previous approach in developing SMS is a decision to develop a single set of rules rather than having separate regulations for each branch of the industry such as operators, airframers and maintenance organisations.

But Pardee stresses the SMS framework will allow industry stakeholders to tailor their methodology to meet the four main principles of SMS as mandated by ICAO. Those elements entail identifying safety hazards ensuring remedial action is taken to maintain an acceptable level of safety maintaining continuous monitoring and regular assessment of safety levels and aiming for continuous improvement in the overall level of safety.

Canadian regulators have developed overarching regulations for SMS to which they add rules specific to each facet of the industry. Rules promulgated for air carrier operators and maintenance organisations ended a three-year implementation phase this September. Merlin Preuss, director-general of civil aviation transport for Transport Canada, reports that the three-year promulgation phase for rules governing navigation services provider Nav Canada and airports started in January this year.

To address ICAO's January 2009 deadline passing without having its SMS plan formalised, the FAA is filing a "difference" with ICAO as a matter of procedure. This essentially means the agency will confirm its intent to develop SMS, with a statement that it needs more time to meet the requirements due to what Pardee calls the "sheer complexity" of the US system.

In a parallel effort to creating the advanced notice of proposed rulemaking governing SMS adoption, Pardee says the FAA is committed to adhering to SMS internally: "We need to apply SMS to ourselves in advance and then apply it to customers."

US aviation participants are not standing still while the FAA wrestles with creating the country's SMS scheme. To date 23 airlines, 16 air taxi operators and 10 repair stations are participants in a voluntary SMS pilot programme. One MRO participant is Illinois-based AAR, whose senior management committed to SMS at the end of 2004. Rayner Hutchinson, AAR vice-president for quality and safety, says even if SMS regulations never surface the company "will have done a good thing" in its SMS implementation.

He explains that AAR has had the opportunity to examine what does not work at airlines as it moved forward with SMS. And he reports that the MRO company has been approached by airlines interested in purchasing its internally developed software package that supports SMS implementation.


Operationally SMS has allowed AAR to shift away from its "old way of doing things" Hutchinson says, adding that in the past the approach to problem solving was to fire a handful of employees and then start an investigation. But the "just culture" philosophy associated with SMS has led the company to think twice before adopting that principle.

Misconduct such as alcohol or drug abuse is still dealt with swiftly but AAR's head of safety says that in general the company aims to find out if issues such as fatigue brought on by multiple shifts were factors in a problem before resorting to termination.

Hutchinson stresses: "None of this works unless you have a just culture environment where people feel unthreatened."

Just culture underpins voluntary reporting of problems or concerns in organisations to create that environment AAR has experimented with two different methods of reporting. A telephone reporting hotline had little uptake, says Hutchinson, who reveals that AAR logged roughly three calls in five years. But a button on the company's intranet this year generated an average of just over 70 reports per month.

Employees reporting problems or concerns through the AAR intranet can remain anonymous, says Hutchinson, but he adds that anonymity makes it hard to conduct a debriefing on the issue. AAR has found little resistance from employees in identifying themselves.

Hutchinson also acknowledges "the obligation of management to use that information carefully and not act the way we used to act".

The positive relationship forged between AAR employees and management in terms of voluntary reporting does not appear to be universal. Dr Bert Boquet, who heads human factors at Embry-Riddle Aeronautical University based in Daytona Beach, Florida believes that while some MROs are enlightened when it comes to non-punitive reporting, the blame culture is prevalent in most industries. Rarely is there backtracking to determine why a mistake occurred, he says: "We fire [employees] and go back to business as usual."


Boquet is in the preliminary phase of working with a Florida-based commercial MRO to assess its culture and training as the starting point for developing an SMS programme. He believes an effective just culture allows employees to feel comfortable reporting issues both laterally and vertically within the organisation to achieve useful data.

Transport Canada's Preuss cites an example of a top official at Air Transat feeling inundated during the carrier's SMS pilot phase as the reporting level grew by up to 600%. But Preuss recommended an analysis of the data which showed a 60% drop in serious reports, which he defines as "something broken, something bent or someone hurt".

"Everything we did until SMS was based on compliance," Preuss adds. He believes organisations are making progress towards a just culture environment: "I'm not optimistic it will happen in 18 months to two years, but it is happening." Key to success in this process is building trust between management, employees and the government.

But in some cases organisations appear to be moving backwards. Pilots at American Airlines last month suspended its Aviation Safety Action Program (ASAP) adopted in 1994, claiming that during negotiations to renew the agreement carrier management advocated a proposal that would leave pilots "dangerously exposed". ASAP is an FAA programme that allows labour groups to voluntarily report concerns or problems while generally being free from penalties related to a particular incident.

American management said it was baffled by the pilots' decision to "discard a 14-year programme that has done so much for our pilots, our airline and our industry".

Following the suspension the FAA met leaders of American's pilot union officials reiterated that it has made no changes in guidance governing ASAP.

No details have surfaced regarding these talks. But Boquet of Embry-Riddle stresses employees who feel comfortable with voluntary reporting can supply priceless input: "They are the ones dealing with policy, procedures and governance in actual practice."

Source: Flight International