SMS and ERP: Moving Toward Full Integration

Regulatory approaches to aviation safety are after-the-fact reactions to major incidents and accidents or historical data studies. Where working safety professionals value proactivity and prevention, governmental agencies often take an armchair quarterback’s view.

In fairness, it does not help that most major business aviation accident investigations illuminate significant lapses (or absences) of even the most basic SMS safeguards. Considering the previous points, the business aviation industry may reasonably expect broad-brush and reflexive approaches as the FAA opens the comment period on the Notice of Proposed Rulemaking (NPRM) for 14 CFR Part 5 and proposes broadening that applicability to include most non-Part 121 operators.

According to FAA sources, larger Part 91 operators (in terms of aircraft size or fleet size) will see a similar NPRM in 36 months or more. Intentions seem to push regulatory evolution toward a more proactive, holistic and less template-driven safety model. Rather than examining the degree and sufficiency of its proposed effect on SMS, this discussion finds hope and opportunity in suggesting that SMS and the Emergency Response Plan (ERP) deserve full integration.

Proposed Changes to Emergency Response Measures
Outlined in the Part 5 NPRM are those changes related to emergency response measures and their relationship with SMS programs. The NPRM’s specific proposals related to emergency response include the following key points:

• Operators would be required to establish and emplace an Emergency Response Plan (ERP).
• Each operator’s ERP would need to accomplish the following objectives, at a minimum:
  – Delegates emergency authority throughout the operator’s organization
  – Assigns specific employee responsibilities in the event of an emergency
  – Designates “proxies” (alternates) for each emergency responsibility area
  – Outlines coordination of emergency response measures with those of other organizations the operator must work with to provide their services
• As a component of their SMS, an operator’s enterprise resource planning (ERP) system would be subject to Part 5 Continuous Process Improvement (CPI) requirements, which would especially apply to emergency response drills and exercises.

The NPRM makes it clear that ERPs must be viewed and implemented as an integral component of operators’ SMS programs and not as stand-alone documents. We applaud the FAA for reaching this conclusion and have long felt the most effective ERPs and SMS programs exist symbiotically.

When properly designed and adhered to, an SMS program, and by extension, the ERP, should articulate the development rationale for the procedures found within the ERP. Further, the SMS should drive ongoing efforts to fine-tune and advance the ERP, especially as safety reports enter the SMS and move through to risk identification and control measures. Opportunities also exist for operators who utilize the data derived from real-world and simulated ERP activations to help illuminate needed improvements in the SMS program.

The Safety/Emergency Response Relationship
Safety and emergency response are distinct in many ways but also interdependent. No effective safety program stops at identifying risks and controls. It must also establish what to do when those safety controls fail. In return, an emergency response’s learning outcomes must contribute to the organization’s understanding of risks, safety gaps, operational constraints, and oversights.

Providers must endeavor to ensure emergency response programs, plans and services are complementary to clients’ safety programs. They should also proactively attend, observe and participate in industry safety audits to stay ahead of predictable regulatory changes like the recent Part 5 NPRM.

In addition, they should adopt further procedures related to records-keeping following simulated and actual ERP activations. The After-Action Report (AAR) process should help operators comply with the proposed SMS Continual Process Improvement (CPI) obligations. These examples indicate how external stakeholders in your ERP can contribute to evolutions in thinking and changes in regulatory guidance.

Operators that hold the safety of their passengers and employees as their primary value will appreciate a fully aligned and integrated SMS-ERP architecture. This appreciation will undoubtedly hold fast, regardless of the specific changes adopted after the NPRM comment period expires.

The NPRM industry review period was recently extended, thanks to the efforts of NATA, the NBAA and others. This expanded period presents an opportunity for operators to undertake compliance measures now.