Plane Conversations

As the CEO of a Part 135 / 91 aircraft charter and management company, I can not proclaim to be an expert on SMS. There are people in our industry a lot smarter on the subject than I am because they have taken the time and energy to study, learn, listen, share knowledge, and attempt to develop systems that incorporate the best practices of the collective knowledge of our industry.

What I can proclaim is that Safety is critical to our company. The fact is that Safety is the most critical issue we face. We cannot afford to do anything that does not allow us to operate at the highest level of safety. The group of people I have worked with over the years will tell you that I support them in operating at that level. I have often said, and I truly mean it when I say it, that if we cannot make a profit and operate at the highest level of safety, then I will get out of this business and do something else to make a living.

So, I have taken the time to listen and learn SMS and, as a company, we have invested money developing the processes and taking the time to put a true SMS in place – and, more importantly, to actually use the system. 

Our industry and the consumers that use us have not always rewarded those who adhere to the highest level of safety. Some users of our services have either assumed that the FAA keeps our industry “safe enough” or they just don’t care, concerning themselves only with price.

Safety Requires Thought and Time Investment! Safety Costs Money!

The debate has gotten heated over the requirement to have a Safety Management System in place, even in operations that do not hold themselves out for hire. The NBAA Avmgr Forum has hundreds of emails over the past few weeks from flight department managers and consultants to the industry on the subject of SMS.  

There are two sides to the debate and some merit exists even on the side that I do not sit on.

Here are comments from the side that says we don’t need SMS in our world of flying aircraft:

• Common sense, good, real training and operational policies that make sense (not policies on what to do when the pencil holder fails) are what we need to improve safety.
• I have only been flying for 38 years and never needed a SMS manual to be safe. It might be a useful tool for larger operations but for a 2-5 pilot ops is simply a waste of time, money and trees.
• Having me write a SMS manual for my three pilot one aircraft operation is a waste of my time, but reviewing a good document on aviation safety and best practices could be a good read on occasion.  Such an approach could generate discussion among pilots, promoting teamwork and better understanding of safe decision making…  The bureaucratic approach to safety will yield lots of paper documents but I suspect it will do little to actually advance safe operations.

 And from the pro-SMS side: 

• Many in our industry are making IS-BAO a lot more complex than it needs to be. The discipline of having an outside perspective (auditor) is a generally accepted business practice.  It is designed to give you credibility as a leader, not talk behind your back.  ”Because I said so….” Is not an effective tool.  We do this in the cockpit and call it CRM, line checks, etc.  Why not with our overall operations?
• Yes, common sense is king. Commons sense is missing from allot [sic]of issues, in and out of aviation. Sure, he who flies with the most paper is not the winner. But neither is he who flies with the least paper the most competent and safe. It all requires balancing common sense, necessity, need and what really works.
• The concept of risk identification and mitigation is embraced in many industries…. We often like to think we are ahead of the pact[sic], but the reality is most of the world has left us (Aviation) in the dust when it comes to codification of best practices and risk mitigation.

From Dwayne McMurry, our Director of Operations, with whom I have worked side by side for over 20 years, the following observation:

 “If I were the owner of an operation that had a flight department with 2 or 3 pilots, I would suggest that the Chief Pilot is not guaranteed to be at my company forever and the airplane, pilots and flight department as a whole would most likely survive him/her.  I would certainly want an Operations Manual or SOP of some type and a Safety Management System in place to pass down established policy, procedure and history of my flight department to the next pilot(s) for the future of my flight department.

Sometimes pilots and flight department managers forget they work for somebody and feel they only have to answer to themselves.  If you wrote the check for the plane and fly it yourself, that’s one thing.  When someone hires you to do a job … most likely, some day, for some reason, someone will replace you and a legacy should be passed on.  What better way to do it?”

This is a complex debate that cannot be fully covered in one blog post or article. What I will say is this: that I would not want our company to operate on pure common sense alone and would also not want to operate strictly from the manual without common sense. What about a combination of good common sense and experience combined with a system that establishes processes, procedures and ways to measure safety? Could it be that we need both?!

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 Part 2 in a Series on Safety Management Systems for Business Aviation Operators

In a previous post on this subject, I suggested that Safety Management Systems (SMS) are good for business aircraft operators. I believe that business aviation as an industry does have a prevailing culture promoting safety but that having systems in place to document and measure safety takes it to the next level. I also suggested that one of the problems with the implementation of an SMS is the lack of consistent interpretation and enforcement by the worldwide governmental aviation regulatory agencies. If the International Standard for Business Aviation Operations (IS-BAO) is the standard that adopts the best practices to promote safety, as suggested by Aviation Research Group US (ARGUS) and the National Business Aviation Association (NBAA), then let’s embrace it.  

Further thoughts on this subject related to the adoption of safety management systems by operators, both aircraft charter (commercial) and business aviation  (company flight departments):

Buying an SMS manual from a consultant and putting it on the shelf to collect dust does nothing to further safety in any operation. All flight departments, no matter how small or large, can learn from documenting problems and analyzing them to identify their root causes. It doesn’t have to be an accident or major event to reveal hidden risks. Those who understand workers compensation insurance risks know that frequency of small events can be an indicator of an increased risk for a big event. How many times does a guy have to slip and fall on a slippery floor before he sustains a major debilitating injury? Can it be prevented by analyzing the minor incidents for cause and fixing the slippery floor before the major event happens? You bet  it can!

In a small operation without a lot of daily flight activity, the issues requiring documentation and analysis may be few and far between. In a large operation with a lot of varying activity both on the ground and in the air, the small issues happen more frequently.  Trends and risk concerns will become more apparent as these events are put into the system.

A good SMS also involves the senior management of the company whether that person is the head of an aircraft charter company or the CEO of a non-aviation company that owns a corporate aircraft. In our company’s case, I meet with our Director of Safety monthly for a briefing on all activities and concerns that have arisen since our last meeting. We also discuss causes and make decisions on changes in our operations to prevent future incidents. Our Director of Safety has direct access to me anytime without any fear of reprisal from other management. Senior Management must be bought into the idea and fully support it. 

Establishing a well thought-out SMS is music to the ears of the insurance underwriters. I believe that, over time, they will offer better rates to the insured risks (the operator) who have a good SMS in place. Some already do take this into consideration at annual renewal.  

Overall, our industry has an excellent safety record. It was better in 2009 than it was in 2008.  It improves with better aircraft, better training, and better systems for managing flight operations. The old saying that “if it ain’t broke, don’t fix it” does not work for us. By the time you find out it is broken it may be too late to fix and the cost of being too late is simply too high.

Bottom line: Maintaining the highest levels of safety by putting into place the best business practices on safety management is good for our clients, our jobs, our businesss and our economy.  

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Part 1 in a Series on Safety Management Systems for Business Aviation Operators

There has been a lot of discussion among business aviation operators and support organizations about Safety Management Systems. Much of the discussion laments the additional regulatory requirements that are coming down the pike for already highly regulated business aircraft operators. The question being asked is: do more regulations and formal safety management system requirements make an operation safer?

Many posit that there is already a strong safety culture among operators of business aircraft and requiring a manual system to formalize the culture of safety adds no value and only creates expense and more work.

A recent article in AIN Online by Chad Trautvetter says the following:

ARG/US Endorses IS-BAO as Charter Audit Standard
Aviation Research Group/US (ARG/US) is endorsing the International Standard for Business Aircraft Operations (IS-BAO) as the one standard that all operators of business jets around the world would be measured by and audited against. According to ARG/US CEO Joe Moeggenberg, The charter community has endured multiple standards and audits for many years, translating into significant time and expense. With one universally accepted standard, the burden of time and money would be reduced and charter customers would be provided with one standard of safety assurance covering all operators. He said that if the industry does not take this opportunity to make IS-BAO along with its safety management system (SMS) component the world standard, then each governmental aviation body could offer myriad alternatives or options for demonstrating SMS compliance. Under ICAO requirements, an SMS will be required for all operators of jet aircraft with an mtow of more than 12,500 pounds by November 10 next year. ICAO, IBAC, NBAA and its sister organizations are all behind IS-BAO, and some countries have already recognized IS-BAO as a means of compliance for various registration or operational related requirements such as SMS. ARG/US said it has modified the standards contained in its Platinum audit to be consistent with IS-BAO.

Over the years our business has seen an increasing burden of compliance with FAA regulatory requirements. It would be easy to become frustrated with this burden and to conclude that more regulation only leads to increased paperwork and the increased human resource costs that go along with it - all without any real benefit. I can understand how operators can think in this direction.

However I will say this: It has come increasingly clear to me that the problem may not be the regulations and requirements for implementation of SMS, but the lack of consistent interpretation and enforcement. Ask more than two FAA officials or industry audit groups to tell you how to comply with a regulation or required program and you will get as many differing answers as the number of experts you ask.  If Joe Moeggenberg’s statements are correct and IS-BAO could be the one standard by which all safety systems are measured, then I am for it.

It would be great if the FAA and its counterparts around the world could agree to standard safety practices and a uniform system of measuring and documenting that safety standard.  Let’s not look at the rest of the world, it would be great if United States governmental organizations could agree amongst themselves! Most days we can’t even get the FAA to agree with itself over the standard. What should be standardized and produce a standard level of safety among all charter operators is not working. The Department of Defense (DoD) recognized this over 20 years ago and created their own audit teams to inspect airlines and charter operators interested in flying DoD personnel. Being FAA certified was not good enough for the DoD because they recognized that two operators certified under the same rules could have vastly different standards when it comes to safe operations!

The lack of agreement between the powers that regulate business and commercial aviation both in the US and around the world does not serve as an excuse for everyone who operates business jet aircraft to operate at less than the highest level of safety. As frustrating as it is, the need is there to have a Safety Management System for operators of business aircraft in our industry. Everyone has an opinion about what constitutes safe operational practices and not all opinions are created equal. Operating at the highest level of safety by employing “best practices” can bring only good to all the stakeholders in our industry.

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