In early 2000, the International Civil Aviation Organization (IACO) developed its Safety Management Manual (SMM) under Annex 19, which outlined guidance for ICAO States to develop a safety program. ICAO wanted each State to outline how they intended to comply with safety. However, the U.S. was not fast to act, and the Federal Aviation Administration (FAA) developed Advisory Circular 120-92, which outlined voluntary and recommended safety practices for 14 CFR Part 121 air carriers. Recommended, but not mandatory.
The Air Commerce Act of 1926
In 1926, the U.S. created the Air Commerce Act. The act was created to entice those outside the government to invest in aviation. This led to the birth of commercial aviation in the U.S. However, from 1926 through the early 2000s, the U.S. placed the responsibility of safety with a given organization, and the pilot in command. There were no regulatory guidelines that indicated that safety programs were a requirement for any operator.
In 2006, Comair 5191 crashed after the flight crew departed on the wrong runway. The FAA attributed a lack of communication and a loss of situational awareness as the root cause. However, in 2009, tragedy struck again when Colgan Flight 3407 crashed on final approach, killing all on board. The FAA realized now was the time for change, and AC 120-92 became mandatory for all scheduled 14 CFR Part 121 air carriers. In other words, they needed a plan for safety.
What about 14 CFR Part 91 and 135 operations? Advisory Circular 120-92 provides guidance for all operations, but only mandates safety programs for scheduled air carriers. However, ICAO mandates that operators meeting specific criteria, regardless of the type of operation, are required to have a safety program before international travel.
What is a Safety Management System (SMS)?
Nonetheless, a Safety Management System (SMS), was now mandatory as part of The Airline Safety and Federal Aviation Administration Extension Act of 2010. As of 2018, U.S. Part 121 air carriers are required to develop and implement a safety program. But what is SMS? At a minimum, SMS is a system that identifies risks and hazards within an organization along with mitigation strategies. SMS is comprised of four main components (or pillars):
- Safety Policy
- Safety Risk Management
- Safety Assurance
- Safety Promotion
Together, these pillars create a continual process for writing company policy, identifying risks and hazards, measuring the effectiveness of organizational procedures, and lays the groundwork for how an organization promotes safety via communication and training.
Change is Coming for Part 135 Operators
While this practice is only mandatory for 14 CFR Part 121 operations, change is coming, and soon Part 135 operators will be required to develop an SMS. If you are a part 91 operator who flies internationally, you may be required to develop an SMS under Annex 19.
Ask yourself, what does safety mean to you? Do you have a plan? What will you do when change comes? Are you ready?
