Mind the Gap
Implementing a formal Safety Management System (SMS) that is recognized as meeting the standards of your CAA or an accrediting body is considered the Holy Grail of accomplishments for many safety programs. This lofty goal was once strictly voluntary for all but the largest and most complex operators but that is about to change in the USA according to ongoing reports. Most recently, in an interview by Jim Viola, President of HAI, the FAA’s plans to expand the SMS requirements to include Part 135 operators (among others) in 2022 was again highlighted by Steve Dickson, FAA Administrator.
Key Point: Do not wait. An SMS will only help your organization and it will be easier if you start now.
In my travels, I come across quite a few operators that want to implement SMS but feel overwhelmed and unsure where to start. This is understandable because there are so many tools, guides and best practices that it is confusing…until you understand the framework they are built on.
For now, most of the smaller US-based operators that are starting to think SMS start by looking at the FAA’s SMS Voluntary Program (SMSVP) and when they get their hands on the Gap Analysis Tool the doubt starts to set in.
I am not going to sugarcoat it. The Excel-based Gap Analysis Tool has crushed the motivation of many people that were excited and motivated to get started on their SMS.
Next thing you know, everyone is pointing their fingers at each other saying that they should have to fill it out because they do not have time to mess with it and it is not their job. Recently I got excited when I saw a draft of the 8900 guidance and a draft revision of the Gap Tool that is evolving into the Compliance Statement Tracker Tool. I thought, “Finally!” Well, it is an improvement, but it can still be a bit much at first glance.
Mind the Gap - My UK readers will recognize this view, although I am sure after years of riding the Underground you do not even see these gaps or hear the warnings any longer.
Good News: It is a logical tool if you understand the foundation so keep reading.
The US regulations that outline the requirements for an SMS are found in Part 5 of the Federal Aviation Regulations. The good news is that this is a noticeably short and easy read (as far as regulations go) and the key to understanding the tracking tools is to realize that the numbering system aligns directly with the regulation. That is it. The old (and new) tracking tool was built by breaking down the Part 5 regulation into each subsection and all you do is detail how your organization complies with each part, reference your policies and work with the FAA until you can both agree that your approach to complying with that section is sufficient. If you divide and conquer with the help of your department heads you will be finished before you know it.
The FAA’s Gap Analysis / Compliance Statement Tracking Tool is built on the framework of the SMS regulations in FAR Part 5.
Pro Tip: I advise all my SMS clients to structure their SMS policy manuals to follow the same outline as the regulation and the tracking tool. This can apply regardless of what country you are in or who your CAA is. This makes life easier for your regulator and that makes your life easier too!
One last point, you do not have to have everything finished and in place with ZERO gaps to get started down the road of having your own formal SMS. In fact, from my experience most operators are already well on the path towards filling all the gaps and do not even realize it. The tracking tool is just a systematic way for you organize the parts into a system and get a clear picture of how much work and time is involved in reaching your goal of a formal SMS.
In summary: Filling the Gaps = Meeting the Regulations
More Reading:
AIN Article About HAI President’s Interview of the FAA Administrator
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