SMS for the Small Operator

“I know that there are those who complain that they’re too small for a Safety Management System (SMS). Or that it’s too costly. Or that they don’t have time. One by one: No one and no company is too small for a SMS. The cost of a SMS is far less than the cost of an accident.”

These words, excerpted from a presentation by the Federal Aviation Administration, Flight Standard Service, SMS Program Office, ring as true today as they did when presented at the Shared Vision for Safety Conference in San Diego in 2010.

Yet, many small operators have not formally adopted an SMS. They may incorporate elements of an SMS, but it often lacks the discipline of a formal system.

Much of the membership roster of the NBAA consists of small operators. If there’s ever a way to leverage safety practices in business aviation, doing so with small operators is it.

If you’re a small operator of business aircraft and have been holding out on incorporating an SMS, here are some points that should make you reconsider.

An SMS Is Easier In a Smaller Operation
An SMS can be implemented in any operation, regardless of size. SMS programs are now flexible and there are significant advantages for smaller operators. Because an operation is smaller, the cost is lower. And because a small operator employs fewer people, it’s much easier to create open lines of communication, a key component in an effective SMS. The greatest single barrier to implementing an SMS in a small organization is the belief that it is too difficult.

An SMS Is Required for IS-BAO Registration
To qualify for IS-BAO (International Standard for Business Aircraft Operators) registration, an operator must have a functioning SMS. Whether you’re operating an aircraft for a corporation, a family office or a high-net-worth individual, IS-BAO registration provides your senior executives or owners with the ”sense of assuredness” in safety that they expect.

Many charter customers, especially major corporations, require that a charter operator hold a platinum rating to contract for the air transportation of company employees. In the Part 91 world, IS-BAO is your equivalent. A functioning SMS is a requirement for IS-BAO registration, and many have chosen to adopt an SMS and voluntarily become IS-BAO registered.

IS-BAO is Now More Scalable
Smaller operators will find it easier to meet the requirements of IS-BAO thanks to work being done by the International Business Aviation Council (IBAC) and the NBAA Safety Committee. The objective is to make the standard accessible to more operators. The ”Vision 2020” standard is a major rewrite of IS-BAO, according to Bennet Walsh of IBAC.

In creating Vision 2020, IBAC interpreted directives from regulatory organizations in a way that establishes a ”common core of safety elements,” which were then written to be applicable to flight departments of all sizes. For instance, an emergency response plan for a large flight department might include coordination with multiple aircraft, facilities, company divisions and even different countries, but for a smaller flight department, it could perhaps involve coordination with a single executive and the FBO where the aircraft is based.

Safety Does Not Discriminate by Fleet Size
It’s quite amazing, but a flight department leader once told me that since they operated only one aircraft, they had their ”arms around the department” and did not require the formality of an SMS or IS-BAO registration. In my mind, that attitude of complacency is even more reason to put an SMS in place. Last time I checked, there is no correlation between safety and fleet size.

The CEO as a Pilot
If you work for a small company, family office or a high-net-worth individual, and the principle or senior executive is a pilot, an SMS safeguarded by the discipline of IS-BAO registration is even more of a necessity. This is not because the executive is insufficiently experienced, but because their mind is often in two places—somewhere between the business at hand and safe operation of the aircraft.

In life and in aviation, it’s hard to serve two masters. Plus, the philosophy of business leadership does not always mesh with safe aircraft operation. A business leader frequently pushes the limits to achieve his/her business objectives, while a pilot is constantly evaluating what can go wrong and taking the most conservative approach. At the end of a long business day, the CEO may not have had sufficient time to shift gears into pilot mode. The discipline provided by an SMS and FRAT can help determine when it’s best for the executive to turn right vs. left when entering the aircraft.

Circling Back
Safety is all about risk mitigation. Risk is not binary. It is analog. In aviation, every action taken should move the risk needle lower on the scale. Adoption of an SMS is a small price to pay to bring the level of risk down by a very significant amount.