FAR Part 91 Safety – What You Can Do Right Now

In a previous article (“FAR Part 91 Safety—Is It Time for a Wake-Up Call?”), we provided insights from 19 current directors of aviation about the state of safety in the Part 91 business aviation sector. What prompted that article? The answer is alarming.

According to statistics from AIN, five accidents involving U.S. registered business jets operating under Part 91 in 2023 resulted in 15 fatalities. That was a significant increase from 2022, when there were zero fatalities in business jet accidents.

Clearly, the statistics are going in the wrong direction.

This article focuses on the top seven concerns about business aviation safety raised by those aviation directors. We offer some proven recommendations about how you can mitigate the issues in your flight department.

1. Business Aviation Talent Shortage

The most significant concern on the minds of the aviation directors interviewed was the critical shortage of seasoned talent. Many flight departments have lost talented pilots to the airlines, and others are losing pilots and AMTs to “poaching” by other Part 91 flight departments. The result is a talent vacuum due to the high rate of turnover.

How do you counter that? Get comp data for your area and ensure your compensation and quality-of-life programs are on par with or better than the industry. The cost of retaining a pilot or AMT is far less than replacing them, easily approaching $250K per pilot.

Take steps to position your organization as a “business aviation employer of choice.” Then, develop a short ‘30-second “elevator speech” about your flight department and use it at FBOs during trips and at recurrent training sessions. Word travels quickly in business aviation circles. Get creative.

2. Level of Effort Required To Maintain a High-Functioning SMS

This was the second most critical safety area expressed by the aviation directors. All flight department team members with safety-related responsibilities hold other primary positions in the department, and few flight departments have the budget capacity to appoint a full-time Safety Manager.

Allocating the bandwidth to manage a high-functioning SMS effectively can be a challenge. What can you do? Appoint not just a safety manager but an assistant safety manager as well. In addition to extra work capacity, you then have a succession plan for the safety position. Also, some flight departments devote one leadership team meeting per month to safety efforts. Safety has to become part of the department’s “Top of Mind Culture”.

3. Complacency

Aviation directors noted that there is an overall lack of focus on the fundamentals of safety in some Part 91 flight departments. They believe this results from the lack of a regulatory requirement to implement an SMS under Part 91. The Part 135 world now has the FAA SMS Part 5 Mandate, but an equivalent requirement has yet to be imposed on the Part 91 sector. What can you do?

As a business aviation leader, you can impose your own mandate. If you are not IS-BAO-registered or BASC-compliant, strive to achieve those goals by a specific date and rally everyone around the cause. It should become a part of everyone’s performance objectives to make it happen.

Don’t yet have a FOQA program? Same approach: Set a date and make it happen.

Do you have an aviation team member who doesn’t buy into these safety-related objectives? Maybe your flight department isn’t where that person should be.

4. SOP Non-Compliance

This is a chronic problem in many flight departments when:

• The destinations are highly repetitive.
• The pilots are long-tenured, having flown together for years.
• The aviation department’s culture does not stress that SOP compliance is a cornerstone of the organization’s values.

It’s long been known that humans do a very poor job with repetitious tasks. We are just wired that way!

So, we need to take overt actions to counter SOP non-compliance. Okay, how? Make the execution of the SOP somewhat different but accomplish what’s needed. For instance, change who is giving the briefing to whom. Another technique is to change the order of the IFR Approach chart briefing. Making things different will capture people’s attention. Keep it fresh.

SOP Non-Compliance is the insidious “First Cousin” to Complacency. Be alert to it always!

5. Lack of Professionalism

Aviation directors say there exists a serious lack of commitment to the pursuit of excellence or continuous improvement in the Part 91 industry today. The attitude of doing only the minimum required or just enough to get by prevails.

It appears frequently in training, where many treat a recurrent session as “checking to minimum criteria” rather than “training to excellence.” This is another area where you, as the leader, can reset the attitude of every member of your flight department team. The objective is excellence, not doing as little as possible. Leadership takes energy and enthusiasm, and it can be lonely at times. But most people will follow a leader they believe in.

6. Training Center Performance

Many aviation professionals consider initial and recurrent training to be a real burden. Yet, their employers are paying the training providers huge sums. In many cases, this training exceeds the price of advanced university degrees. Still, all too often, we hear, “What’s the minimum that I have to do to get out of here?” That doesn’t sound like a quest for excellence!

In the FAA FAR Part 91 world, it’s important to consider what can be achieved during “training” as opposed to “checking.” Yes, the FAR 61.58 checks must be completed, but that’s only the start. What have been some chronic problems since your last training event? Put those in the syllabus and train to “excellence, proficiency and competency.” Consider every moment at the training facility a golden opportunity for YOU to EXCEL.

7. The Impact of Automation

When you find yourself asking, “What is it doing now?” you know you need a more in-depth understanding of the avionics systems’ software. If you only know the “hows” but don’t understand the “whys,” you aren’t truly competent and in command of your aircraft.

Gaining this level of technical avionics competence takes study and practice. And that must be accomplished while not flying the aircraft. It takes many more sim sessions to gain an introductory level of avionics systems understanding than to master flying the airframe. Trying to pick up avionics knowledge “on the fly” is dangerous and irresponsible. That’s the furthest thing from a professional approach and attitude.

Bringing It Home

The problems above that have plagued aviation for years actually do have near-term means of mitigation. As a business aviation leader, you can reset the tone and hit these critical safety concerns head-on.

It will take time and repetition of the message, but it starts with you as the leader, and there’s no time like today to begin.