Fast Track FAA Acceptance of Your Part 5 SMS

Edit your Part 5 SMS Manual and prepare your Declaration of Compliance (DoC) in just a few hours.

Follow these steps to assure rapid FAA acceptance of your professionally-developed SMS:

1. Stand up your Part 5 SMS in just a few weeks. This is done by editing the harmonized SMS Manual template, policy statements, and Emergency Response Plan. Then, configure the integrated QSMS web app to the size, scope, and types of operations you conduct.
2. Enroll your personnel, management team, and the accountable executive in the integrated computer-based SMS training courses (see more below). Track progress and file completion certificates.
3. Place your SMS into operation and learn how to perform Part 5 safety risk management (SRM) and safety assurance (SA) processes within the QSMS web app – in real time, and without FAA oversight. It’s on-the-job training for your Director of Safety, department managers, and the accountable executive. Your SMS provider supports you during this time, until you and your team are ready for ‘show and tell’ with FAA.
4. Use your SMS provider’s Declaration of Compliance template to verify where each part 5-specific regulatory requirement (SRR) is addressed in the SMS Manual, Emergency Response Plan, and software/web application.
5. Use your SMS provider’s Schedule of Events template to plan a timeline for the performance of SMS design validation DCTs. Run each DCT internally to assure that safety attributes have been incorporated into your written guidance and software. Remember, these are the same DCTs FAA will perform when they evaluate your SMS design.
6. Submit your SMS Manual, DoC, and a Schedule of Events to your local Certificate Management Team (CMT).
7. Then comes the hardest part of the SMS acceptance process – successful completion of SMS design demonstration DCTs with your CMT. A competent SMS provider can guide you through this challenging time with tactics and tools designed to relieve stress and make the process easier and more successful. Refer back to your Schedule of Events to run the many SMS design demonstration DCTs. Perform each DCT internally to ensure your employees, managers, and senior management are ready for your CMT to come in and repeat the process. Correct any deficiencies, administer additional training if necessary, and work with your CMT to coordinate and schedule their design demonstrations in your various departments.

SMS Training Program

Concurrently with the launch of your new SMS, provide SMS training for front-line personnel and SMS training for department managers, as well as for senior management and the accountable executive. The right training will go beyond SMS theory to include safety promotion and company promotion messages intended to improve your organization’s safety culture. It’s important for this training to be harmonized with your SMS Manual and web app – This means the same concepts are explained and the same terminology is used. Online, web-based, self-paced training (which can be taken and reviewed at any time) is efficient and effective.

Essential SMS Peripherals

As your SMS is implemented and your management team becomes familiar with how to operate a part 5 SMS, submitted safety reports can sometimes create a record of regulatory violations. There are several ways to deal with this, but only two are really effective:

• Aviation Safety Reporting System (ASRS). NASA’s ASRS confidential reporting system was established in 1976 to identify potential safety concerns in our aviation system. The program worked because 14 CFR § 91.25 specifically prohibits the use of these reports for enforcement purposes. However, recent changes in FAA policy now make protection from civil penalties and certificate action less assured.
• Aviation Safety Action Program (ASAP). ASAP permits pilots, mechanics, and flight attendants to report apparent violations and be assured of protection from FAA enforcement action. By integrating ASAP into your SMS web app, redundant reporting into a separate system is eliminated. Operators can enter into their own Memorandum of Understanding (MOU) with their Certificate Management Team, and 3rd-party facilitation fees need not be paid. All Event Review Committee actions and decisions are performed and recorded in the harmonized SMS web app, and guidance is contained in the integrated ASAP Policy and Procedures Manual.
• Voluntary Disclosure Reporting Program (VDRP). FAA Advisory Circular AC 00-58C sets forth procedures for operators to voluntarily report 14 CFR violations. The VDRP program provides operators with a way to avoid civil penalties when an unintentional violation is discovered, and fosters a cooperative relationship between the operator and their principal inspectors. Your VDRP should be incorporated into your SMS Manual, and harmonized with your SMS software.

Conclusion

The FAA Part 5 compliance date of May 28, 2027 requires operators to no longer put off their SMS implementation strategy. Senior managers – Don’t let part 5 SMS development burn out your management team! It is highly stressful to attempt development of a new and complex project, particularly one you’ve never done before, while continuing to run daily operations. Instead:

• Provide professionally-developed tools – don’t ask busy managers to build them!
• Provide training – NOT on how to develop an SMS; instead, teach your people how to configure and operate one.
• Choose the right SMS provider – One that will support and assist you throughout FAA’s SMS acceptance process, including SMS design validation and design demonstration phases.
• An integrated ASAP, together with a positive and non-punitive safety culture, are essential to a successful employee reporting program.
• When the SMS reveals apparent violations, disclose them to FAA with an integrated VDRP. This is an essential tool in your SMS toolbox. VDRP disclosures help to avoid civil penalties and certificate action. They also remove noncompliance ‘skeletons in the closet’ which if left undisclosed, could be discovered by FAA in a future oversight activity. This is especially important in maintenance recordkeeping, since errors and oversights can become a permanent part of aircraft records.

A professionally developed SMS is more than just part 5-compliant; it’s a fast track to FAA acceptance and encourages buy-in from employees and managers. When integrated with ASAP and VDRP, it also protects personnel and the company from enforcement action, promotes safety reporting, supports safety culture improvement, and results in continuous improvement over time within a comprehensive aviation safety management system. It’s the right choice!

For more information, please contact Omni Air Group:

Paul Salerno – Flight Ops

Bruce Salerno – Technical Ops

Steve Winter – Senior Developer

Cheryl Bzdawka – Office Manager

Telephone +1.760.239.7895

eMail: [email protected]

Paul Salerno – SMS Guy

Paul holds a Bachelor of Science degree in Aerospace Science, and is a graduate of FAA’s System Safety and ATOS training courses. He holds an airline transport pilot certificate with type ratings in large non-transport and transport category aircraft, having logged over 5,000 hrs. as pilot in command, flight instructor, and check airman.

Paul served as chief pilot, director of operations, and director of safety for 18 years under parts 119 / 135 / 121 of the US Federal Aviation Regulations. He has authored numerous technical publications, including FAA-approved airplane flight manuals, flight operations, cabin safety, and maintenance procedures manuals, inspection programs, pilot training programs, and SMS-related manuals and programs. Paul is also an A&P mechanic and has developed several one-time and multiple Supplemental Type Certificates (STCs).

Paul is the President of Omni Air Group and developer of the OmniSMS® Aviation Quality and Safety Management System. Designed specifically for US Part 21/135/121/141/145 certificate holders, OmniSMS is a total quality and safety management solution that complies with ICAO, 14 CFR Part 5, SM ICG, and SM-0001 SMS standards. Please visit OmniSMS.aero for more information.