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Safety Management System for Non-Part 121 Operator

Introduction

Aviation plays a crucial role in the socio-economic development of the American economy. The aviation sector has consistently grown and expanded in recent years and is expected to extend even more in the future. Such developments shape significant opportunities for innovations, including applying new technologies and operations which will stimulate economic growth in the country. However, such a plethora of new options come with a plethora of significant concerns for the industry. That means that there must be efforts to guarantee aviation safety and improvement. As such, preparation and implementation of SMS models tailored for the Federal Aviation Regulation 141, 135, and the 141 aviation companies is timely and has the potential to ensure safety enhancement based on a structured management system to manage risks in operations. The purpose of this paper is to create safety management and implementation model for the three careers.

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Safety Management System (SMS) for Non-part 121 (airliner) Operator

The aviation industry positively impacts the world economy as it transports people and cargo worldwide. Surveys indicate that the aviation industry has nearly 61 million passengers, contributing almost $1 trillion to the world’s Gross Domestic Product (“Adding value to the economy,” n. d.). It, therefore, means that the industry should have a continuous improvement of its security services to ensure that safety is not compromised. However, with the present limited accident rates, it is progressively becoming difficult to introduce further innovations based on the previous aircraft accidents’ reactive scrutiny alongside the corrective actions formed through safety recommendations (Nugraha, 2019). Thus, there is a need to craft a modern safety management approach which makes it easy to assess risks proactively instead of over-relying on inspection and remedial actions which emerge from accidents. Such innovation encompasses safety management systems which show that safety efforts become useful when integrated into the operation plan (Nugraha, 2019). The paper aims to evaluate the preparation and implementation of a safety management system (SMS) among the general aviation companies with 135, 141, and 145 certificates.

Literature Review

Importance of Safety Management System in Aviation industry

A safety management system enables an operator to isolate hazards, examine them, and structure measures to combat the accrued risks that come with such dangers. A systematic approach allows for all the organization’s members in the implementation process. According to Yeşim & Gerede (2018), SMS enables aviation operators to project and eradicate the safety hazards before they lead to accidents. It also allows the management to handle near mishaps effectively and to use such critical lessons to ensure safety and efficiency in the future (Grimaccia et al., 2017). The SMS approach can also minimize accident risks, limit the insurance costs, enhance productivity and morale, and is generally reliable.

SMS Components

The management of any aviation institution should outline the policies and explain how safety procedures will be executed. Moreover, the administration is responsible for defining every employee’s duties and the respective accountability procedures (Grimaccia et al., 2017). It must also have accountability policies which should expose the organization’s leadership and their respective duties to ensure adherence and safety to SMS policies. The risk management system is also a component of the SMS model, and it analyzes, controls, identifies, and manages safety risks to develop the implementation procedures.

The system must scrutinize the threats to safety by isolating and acting upon the issues on time. The third SMS component comprises the safety assurance system, which provides proactive scrutiny alongside systematic improvements to realize the objectives (Yeşim & Gerede, 2018; Batuwangala et al., 2018). The SMS model should measure, assess, and track the model’s performance to ensure its effectiveness. The fourth component constitutes safety promotion, which includes communication, training, and all other actions which aim to create a safety culture in all stages of the workforce. It ensures that all the organization employees understand their responsibilities and the subsequent steps in executing such responsibilities. They must also underscore the safety policies and implement their respective reporting procedures, communication mechanisms, risk management tools, and reporting procedures (Yeşim & Gerede, 2018; Batuwangala et al., 2018). The personnel has to be trained to conduct their duties in tandem with the safety procedures and policies.

Safety policy

In addition to practical aspects, SMS is regulated by formal documents, which is essential in the development and implementation of the system. The FAA advisory circular (AC) 120-92B defines the safety management system and its implementation as per the dictates of 14 CFR, Part 5 (“AC 120-92B – safety management systems,” n. d.). As such, Part 135 holders should design SMS models that comply with the policy requirements and align with its internal operations system. An SMS has four features: safety risk management, safety policy, safety promotion, and safety assurance (Grimaccia et al., 2017). The four components are steered by a company’s safety culture, which constitutes every employee’s relative safety behavior in an organization. All the four pillars have their unique procedures and processes which have to be developed and implemented in a company.

Although such methods look simple, organizations must embrace them once they have been adopted. The safety policies are designed by the top management of an organization regarding safety awareness in a company. That means that safety policies should have organizational resources for the SMS, safety objectives, and outline to the staff to report safety concerns, emergency response plans, and unacceptable behavior (Grimaccia et al., 2017). Based on the model, an organization should have an individual executive officer who manages its financial resources, operations, and human resources.

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Safety risk management constitutes the identification of hazards and the management of the connected risks. The TEAM concept, which comprises transfer, eliminate, accept, or mitigate, is the drive controlling the risks (Grimaccia et al., 2017). Within safety risks management, an organization should define a system which encompasses hazard identification, safety assessment, safety risk analysis, description and analysis, and safety control. Part 5 indicates that organizations should apply the model while revising existing systems, adopting new techniques, recognizing new hazards, and implementing new designs. Grimaccia et al. (2017) suggest that safety risk analysis should consider a merger with the systems’ purpose, personnel, process outline, operating environment, and facilities required. The analysis procedures should have systems which recognize emerging hazards introduced from the analysis processes, and when such risks become unacceptable, they should be controlled.

Part 135

Part 5 constitutes the processes which ensure the effective SMS model. However, it does not offer the particular ways to implement the system (Batuwangala et al., 2018). It is a requirement that all the organizations operating Part 135 design and adopt an SMS model which suits their organization. Additionally, the operators should approve and enforce the emerging safety policies which are appropriate for contemporary demands and systems (Federal Aviation Administration, 2015b). Batuwangala et al. (2018) show that SMS implementation in Part 135 companies is challenging due to its fragmented and ever-changing nature. There are also several hurdles among the Part 135 companies because the industry comprises small one-aero planes, large multi-jet fleets, and one-pilot companies while others are flying internationally. Currently, some of the operators have implemented voluntary SMS models.

SMS is critical to Part 135 companies as it minimizes losses of resources and reduces life-threatening risks. Additionally, safety risk management can influence the business in realizing its goals (Kaspers et al., 2017). Although several commercially developed SMS models, one of the growing challenges in altering the organization’s safety culture to suit the model. The effectiveness of the safety culture is only visible when it positively merges with the organization’s culture. Surveys suggest that organizational culture influences prioritization and balancing processes and policies, including enforcement versus corrective action and safety versus efficiency (Kim et al., 2020). Non-punitive measures positively influence the prevention of accidents even though, in some instances, the management can be held accountable when reasonable efforts were not considered. One such reasonable step is the adoption of the SMS models.

Although there are several recognized safety benefits, there are concerns regarding SMS preparation and implementation within the Part 135 companies, which include documentation and redundancy. The majority of the part 135 operators believe that SMS outlines will only duplicate the current regulatory procedures and increase several clerical works in such organizations (Kim et al., 2020). Several Part 135 operators posit that SMS adoption is burdensome on such companies and their respective staff. Findings document that major flight companies are less concerned about adopting SMS than smaller companies because they already have structures to implement the system (Kim et al., 2020). The FAA Advisory Circular (AC) 120-92B is the primary document used by Part 135 operators to implement the SMS model.

Part 141

Previous studies have piloted a survey to establish the link between safety culture perceptions and predicted safety reporting behavior among five selected collegiate aviation flight courses in the USA. The researchers demonstrated that there is a negative association between age and safety reporting behavior (Adjekum, 2017). Further, the researchers determined that sometimes there are operational pressures to finish such flight lessons at safety expense (Grimaccia et al., 2017). They also underline that there were cases when pilots registered a poor safety culture due to a lack of trust in the safety reporting system’s anonymity (Xue & Fu, 2018). In other cases, sections of the pilots were sure that data obtained in such exercises could be used for other unintended functions and not for safety reasons, including administrative reasons. According to Xue & Fu (2018), a robust safety foundation and its subsequent frameworks can help the entrenchment of safety culture among the Part 141 flight schools. Ideally, there is a need to adapt and embrace the SMS concepts in Part 141 flight schools to improve the safety culture and aviation safety in such collegiate schools.

The FAA authorizes the flight schools under the 14 Code Federal Regulation Part 141. However, certification under this category is voluntary even though the respective institutions must adhere to strict standards that uphold safety (Mendonca & Carney, 2017; (Grimaccia et al., 2017). Furthermore, the conditions for aircraft, operating rules, facilities, personnel, and established curriculum enable such organizations to efficiently conclude ratings and certifications (Xue & Fu, 2018). Previous findings have pointed fingers at numerous safety concerns that could lead to aircraft accidents among the Part 141 approved flight schools. One of the issues is that students are limited from nurturing and applying their aeronautical decision-making skills during the practical (Mendonca & Carney, 2017; Grimaccia et al., 2017). Although the FAA requires that applicants for the licenses exhibit outstanding ADM skills, some flight instructors rarely incorporate instructional methods to examine such ADM attributes.

In one of the previous studies, researchers conducted scrutiny to underscore the existing safety culture among the Part 141 approved schools for the flights after implementing a phased component of an SMS. The project recognized variances in the participant’s perceptions regarding the safety culture (Mendonca & Carney, 2017). The scholars acknowledged that differences in-flight experiences, national cultures, and years accrued in the flight program could be useful in the pilots’ safety culture in such aviation schools. They recommended that there is a need to address the safety culture of Part 141 institutions to uphold the best practices for establishing a Safety Management System.

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Not only organizations but also aviation schools need continuous improvement of the SMS system. Cassens et al. (2015) posited that a third of the mid-air collisions among general aviation between 2000 and 2012 happened during the instructional flights. This research aimed to assess if the behavior-based safety could inspire Part 141 pilots to adhere to the FAA’s categorical procedures and recommendations to limit the midair collisions (Cassens, 2015; Grimaccia et al., 2017). Based on the study, the institution’s latent conditions, such as the pressure to conclude flight lessons supersede the clearing turns, resulting in crashes (Mendonca & Carney, 2017). As such, flight schools should continuously review their policies to alleviate such latent conditions.

Safety Management Systems

An SMS ensures the safety operations of the aircraft based on effective management of risks. It gives a FAR 141 operator the ability to project and correct safety risks before they cause accidents (Amalia, 2019). Training institutions implement various scopes of management systems, including Documentation Management Systems (DMS), Quality Management System (QMS), and Fatigue Risk Management (FRMS). Comprehensively, such programs provide direction within the specified governance system (Grimaccia et al., 2017). Accordingly, an SMS integrates the various management functions as components to enhance organizational safety while improving product and service delivery (Kaspers et al., 2017). Such integrations have unlimited benefits, including reducing all-embracing corporate risks, reducing likely conflicting functions, reducing organizational risks, and reducing costs by limiting redundancy.

SMS components are linked to one another and are not required to be complex or extensive to be operative. The federal regulation 14 CFR Part 5 asserts the need for primary processes which initiate reliable SMS (“14 CFR Part 5,” n. d.). However, it does not articulate specific methods to implement such strategies. In tandem with Annex 19, the requirements under this section were structured to be scalable, enabling operators of various sizes and complexities to embrace such safety management practices into their specific models (Amalia, 2019). That means that different organizations can comply with such expectations in various ways.

Implementation of the SMS Model for Part 145

The SMS model for FAR 145, as proposed by AC120-92B, the flight schools should craft and implement SMS documentation which defines the institution’s safety policy, procedures, and processes. The disciplined approach concerns information management and documentation, providing the relationships between safety management and its respective functions. It also relates to the best ways in which the system can complement other parts and exhibit the relationship between the model and the safety policies in an organization (Amalia, 2019; Kaspers et al., 2017). It comprises the organization’s SMS manual alongside the particular processes that need to be embraced in an organization to ensure safety is guaranteed at all times.

Criticism may be that the document sometimes acts as a standalone due to its precise nature. Reports show that several SMS processes and procedures are already discussed in other existing safety documents, which means that there should be adequate cross-referencing whenever such concerns suffice (Kourousis & Comer, 2018). Additionally, the processes, records, and information considered to meet the SMS objectives can be influential in the case of a formal safety investigation. All the data have to be well-documented to allow for traceability of all interlinked decisions in an organization.

The US is an International Civil Aviation Organization member and as a component of its SSP. It demands all the service providers within its jurisdiction to adopt an SMS or inform the ICA of the dissimilarities existing SARPS under Annex 19 and the national regulations and practices. AC120-92B expects the Part 145 certificate holders to embrace an SMS. As in other aviation service providers, certificate holders are also expected to voluntarily develop an SMS model that complies with Part 5 requirements (Cusick et al., 2017; Kourousis & Comer, 2018). The CFR Part 145 rations uphold a high safety level during the repair institutes’ repairs and operations.

However, studies have continued to explore avenues which could lead to aircraft accidents. Accordingly, several such studies have recommended adopting at least one of the four SMS pillars’ four primary components. According to Kourousis & Comer (2018), Part 145 operators should have processes periodically regulating the ADM instruction status and point, suggesting areas which necessitate improvements. Such include safety education and training alongside every model’s safety assurance processes which may be adopted in an organization. Research by Li & Guldenmund (2018) addressed SMS tenets and safety culture. According to the study, several factors can have adverse impacts on the personnel’s safety culture in the repair institutions. Therefore, there is a need to have a robust safety culture to prevent accidents. In tandem with Li & Guldenmund (2018), an SMS model fosters maintenance and development of robust safety culture among the Part 145 operators. The study evaluated two repair institutions’ reliability to increase the pilot’s knowledge and abilities when experiencing IMC conditions.

As captured previously, such circumstances have led to increased rates of fatal aircraft accidents. Other studies have underlined the overreliance on technology to keep their systems (Ioannou et al., 2017). At the same time, reports also indicate that the desire to complete the work plays a significant role in some participants’ decision-making processes. Such safety hazards often increase the risks of inducing aircraft accidents. Several studies have emphasized that there is a need for increased safety training to alleviate such risks (Cusick et al., 2017; Li & Guldenmund, 2018). The safety education and training elements of the SMS model accords the pilot’s knowledge and skills to conduct the repairs and fly safely. Additionally, SMS models seek to increase the safety culture of the repair schools.

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Determinants of SMS Development in Part 145

The preparation, maintenance costs, and implementation among the Part 145 operators depend on several factors, including the existence of mature SMS processes, size and complexity of the institution, and the need to train SMS professionals. Findings illustrate that safety benefits often outsize the costs and development and implementation of an SMS (Cusick et al., 2017; Li & Guldenmund, 2018). Consequently, an SMS implementation among the Part 145 operators often ensures the safety efforts capture aspects where safety benefits will be utmost and more effective. Moreover, it promotes a sound safety culture in the respective organizations.

The basic concept is that compliance with regulations enhances aviation institutions’ safety even though there is a need for more contemporary thinking to limit accidents. It is due to organizations which excessively rely on the minimum standards and are often deprived of proactive measures to recognize possible hazards to embrace the safety culture. Studies also indicate that regulatory compliance plays an instrumental role in routine safety education, recurrent safety training, and safety-linked event investigations (Ioannou et al., 2017; Li & Guldenmund, 2018). As suggested by the FAA (2016), one of the many benefits of SMS ensures compliance and sometimes supersedes legislative standards and regulations. The model is critical by enabling the institutions to abide by national and international regulations.

SMS Maintenance

The maintenance’s primary reason is to enhance safety, which forms the ultimate objective for the Aviation Maintenance Technician (ATM). According to Wild et al. (2017), maintenance reduces flight-related risks by 55 percent (p. 165). Therefore, the AIR 21 is channeled to the Occupational Safety and Health Administration (OSHA), implying that the former was instituted to safeguard employees who defied the FAR regulations while executing the performance maintenance (Cusick et al., 2017; Ioannou et al., 2017). While it is a requirement that companies embrace maintenance systems, there are numerous barriers to the preparation and implementation of the SMS model. Often, repairs are grouped based on size (Kaspers et al., 2017). The smaller stations have under 30 employees, medium to large have more than thirty employees. However, the authors believe that small repair stations have reservations about the proposed SMS models because they think it is overly burdensome, may not improve safety, and expensive (Wild et al., 2017). Applying the present systems is useful in minimizing the excessive use of resources while also limiting SMS costs.

Problems for Small Repair Stations

Several repair stations have several legitimate issues to adopting the industry-wide SMS regulation, especially a one-size-fits-all approach which impacts the small operations. SMS implementation, as adopted by ICAO, is a requirement among all the member states. However, the FAA cannot force organizations to adopt the obligations due to inadequate legislative support (Wild et al., 2017). The small repair stations have a major share of the US’s repair stations, and hence they control tremendous power. Small repair stations are adamant about the proposed regulations because they believe they will be burdensome in their operations. Wild et al. (2017) also indicate that lack of evidence is another obstacle in SMS implementation. A similar concern is shared among several members of the aviation industry. Aircraft Owners and Pilots Association (AOPA) has often questioned the SMS regulation’s value and SMS advantages (Wild et al., 2017). As such, recognizing the zero-accident objective and fatalities’ impossibilities, the SMS model’s challengers are comfortable with the current aviation safety.

Problems for Large Repair Stations

Several organizations running repair stations in the transport sector believe that the model should be implemented. Despite little concerns in adopting SMS, the implementation process’s challenge is due to culture change issues. That is because developing a safe culture is a difficult task that demands a culture change. According to Wild et al. (2017), the development of a safety culture requires creating sub-cultures, just culture, learning, informed, and reporting. On the other hand, workers in big organizations are embedded in the organizational cultures engraved over a long period. That means that changes will be faced with massive resistance, particularly from seasoned employees (Wild et al., 2017). Additionally, the involvement of labor unions further complicates the already messed situations.

The Public Service Electrical and Gas and large repair stations experience similar challenges. The study noted that even senior management share the same concerns because they believe that it is an uphill task to implement the entire process. International Civil Aviation Organization (2017) notes that safety change will invariably introduce safety risks elsewhere. As such, it provides the value of change management, which has to be methodological. Once it has been implemented, a company has to steer the management efforts as boldness in a risk system that may have an adverse effect (Wild et al., 2017). A strong risk system makes the employees depend on the system, makes the system accountable and not oneself, and is harmful to safety management.

Conclusion

Overall, the safety management system is a critical tool in the aviation industry. Irrespective of the company size, it is crucial that organizations adopt the SMS system for their client’s and employees’ safety. As studies suggest, SMS models should be tailored to suit the organization’s specific interests and infrastructure. Additionally, repairs and maintenance should also structure SMS models for the safety of their employees and trainees.

References

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Kim, J. T., Lee, G. Y., & Choi, J. K. (2020). A study on the improvement of safety management system for ATO. Journal of the Korean Society for Aviation and Aeronautics, 28(4), 182-186. Web.

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