As an industry, we’ve known that Safety Management Systems (SMS) requirements are coming for airports for some time now. Despite the long fuse leading up to rulemaking, many airports aren’t well prepared for regulatory requirements for SMS. Over a decade ago, the FAA started work on both internal and external initiatives for implementation of SMS, and it released the first Advisory Circular introducing SMS for Airport Operators in February of 2007. The first Notice of Proposed Rulemaking (NPRM) for Part 139 was released in 2010 as an effort to harmonize FAA regulations with ICAO Annex 14 standards and recommended practices at airports. Incorporating comments from industry on the original document, the NPRM was subsequently revised, and a supplemental version was published in 2016.
After the changes to the original NPRM, the FAA now estimates that system-wide benefits of the forthcoming total approximately $370.9 million, while the total costs associated with implementation are estimated at $238.9 million. These estimates do not include the cost of mitigations that may be required as part of the implementation process. Airports covered by the proposed legislation would have up to two years to implement an SMS after the effective date of the final rule, reflecting the need for additional time that many commenters to the NPRM identified as necessary to meet the requirements of the rule.
Notably, the SNPRM does not require tenants of an airport to have a separate SMS. However, from a practical perspective, airport managers must ensure that the airport SMS applies to any safety issues including employee safety, ground safety, vehicle safety, and passenger safety to the extent that they are related to aircraft operations. At a functional level, this requires that airports work in concert with tenants to ensure either that the tenant is working within its own SMS or is included in the airport SMS as a stakeholder and participant. The SNPRM provides some flexibility to airports in how general aviation operations are treated as well, allowing the certificate holder to scale their implementation to meet the unique operational needs of each airport.
While the timing of the final rule may be uncertain, we can be assured that regulated SMS for airports is a near-term reality. New regulations always produce some growing pains as the industry adjusts, but this step by the FAA will be a good one for the airport industry as it provides a systematic method for improving communication, reducing operational costs, improvement of operational processes, prioritization of safety needs, and better utilization of resources. Still there are obstacles to address in order to conform to proposed legislation.
Developing, implementing, and maturing an SMS within the airport industry is undoubtedly a substantial project. So where should an airport team start?
- Commitment: Before beginning SMS development, the airport must educate senior leadership, governance bodies, and stakeholder leadership about the benefits of systematic, business-based approaches to safety management. Without management support - financial and otherwise - implementation of SMS is unlikely to succeed. Commitment must also focus on grassroots education about the purpose of SMS, and the key role all members of the airport team play in providing feedback within the system.
- Training: Training helps establish safety as a core value within the organizational culture,
- Gap Analysis: An honest and thorough gap analysis helps establish a baseline for safety performance, so we can chart a course to our desired safety goals. The gap analysis also helps identify key safety performance indicators, so that we can monitor progress throughout implementation. Airports can conduct a gap analysis internally, or may choose to turn to an outside contractor to offer a fresh look at processes for safety.
- Program development: There are a number of ways to develop the necessary components of the SMS, but for most airports, the most logical is to approach the task as an evolutionary, phased process. Here again, a consulting firm may be useful to reduce development time and assist with initial training and start-up. NATA has a number of excellent training and support solutions to ease the development process as well.
Using the many resources provided by AAAE can help jump start SMS development, and airports must remain cognizant of the many unique challenges from one airport to the next. No one solution will apply to all airports, but careful planning, and working to stay in front of legislation, will help airports to prepare for the transition to a safety management system that will enable systematic safety management, even as the industry continues its rapid growth in volume and complexity.
Goodheart, B. J. (2017, First Quarter). Safety Management at Airports. Aviation Business Journal. 39-43.
Learn more from Dr. Goodheart at the ACE SMS Review Course