As you are most likely aware, the FAA is writing proposed regulations related to the rules that will require a broad-based establishment of safety management systems in most, if not all, aircraft ops and maintenance organizations. To say our overseas contemporaries at EASA have primarily driven this is to understate the obvious. As of Jan. 1 of this year the U.S. was supposed to have initiated regulations related to this effort. It has not happened because the FAA has not yet "defined" SMS.
While aware of this previously, it has come to my attention more recently by the announcement from AEA challenging FAA’s broad-based proposal for SMS in its ANPR. Essentially I agree with AEA, but perhaps not for the same reasons. Primarily, I am leery of this initiative because I believe we have enough regulation and enough regulatory organizations. More regulations will add to the cost of doing business and eventually flow down to the end user. We do not need this, especially at this difficult economic period.
Does the fact that an organization is ISO-9000 certificated "demonstrate" the quality of their product or services? I don't think so; rather it shows compliance with some regulation or guideline. Those that are standard driven will meet minimum requirements, while those that are vision driven will work to be world-class and you can't legislate a vision.
Specifically with the current proposal, it is not whether your organization is single or multi-tiered that matters, but rather what the primary business of your organization is. If you are an airline or an MRO, SMS makes sense as an enhancement. If, however, you are a parts or overhaul shop servicing an airline or business operator, you already have to be compliant with the various regulations of EPA, OSHA, DOT, etc.
Perhaps the real, and justified, point of the AEA response centers on its aversion to assigning a risk manager, forming a risk management team, and doing documented risk analysis as required by the ANPR is that once documentation is given to the FAA it becomes public domain and, in this realm, fodder for any lawyer to use in a negligence lawsuit.
Regardless of the aforementioned, I must admit, I am a staunch, "you can not do enough for safety" advocate. I firmly believe that if there were a strong SMS system at Colgan, Buffalo would not have happened. And, I do not believe in "in-house" training systems. Invariably, these become incestuous. As a corollary, don’t you think an established SMS at Northwest might have kept those pilots “awake”? What about Air Transat, the Canadian operator whose A330 ran out of fuel over the Atlantic because of a maintenance error?
The challenge is to find a balance between what serves safety to the utmost and those things that inhibit business and are redundant to established processes.
What are your thoughts?