The Part 5 SMS Gap Analysis Fallacy
Part 5 SMS development and the outdated SMS gap analysis.
Safety Management Systems (SMS) have come a long way since 2006, when they were first mandated by ICAO. At that time, SMS requirements were new and not well understood. So to help aviation service providers (aka operators) comply with the new requirements, ICAO introduced the concept of an SMS gap analysis. The purpose of a gap analysis is to help the operator identify what is already in place that meets regulatory requirements, and then determine the ‘gaps’ that will need to be filled to comply. The practice is now so widespread and accepted that few people question its validity. Does the SMS gap analysis process produce desired process outputs? And are process outputs aligned with our goal of achieving Part 5 acceptance of our SMS by FAA?
In 2015, FAA finally mandated SMS for US Part 121 air carriers with a new SMS standard. And just like the Wright Bros. who had to build their own aircraft, US airlines had to develop something that had not been built before. So FAA adopted the SMS gap analysis model to assist them. The concept made sense at the time. By comparing SMS requirements against existing resources and systems in place, gaps are identified and a roadmap to compliance can be developed. Note the SMS gap analysis process output – compliance.
FAA’s SMS standard differs from the ICAO standard in several ways (beyond the scope of this article). The part 5 standard goes beyond compliance to include seven essential safety attributes which must be incorporated into an operator’s SMS. Yet FAA’s SMS Implementation GAP Analysis Tool makes no mention of safety attributes; the tool addresses only compliance with 14 CFR Part 5. So where do the seven safety attributes of Responsibility, Authority, Procedures, Controls, Process Measurement, Interfaces, and Safety Ownership reside? In the data collection tools (DCTs) FAA uses to evaluate your SMS during SMS design validation and design demonstration phases of SMS acceptance.
The SMS Gap Analysis Fallacy
During a gap analysis, it’s easy to overlook “hidden” part 5 requirements as ‘gaps’ in regulatory compliance are filled. This is typical of operators who have an established IS-BAO-conforming SMS, and are trying to comply with part 5. The gap analysis may show, for example, that under Subpart B: Safety Policy, managers have authority to make decisions regarding risk acceptance per 14 CFR § 5.23 (b) requirements. The SMS Manual may also show that checklists are being used for internal audits and evaluations in accordance with § 5.71 (a)(3) and § 5.71 (a)(4) requirements. In fact many part 5 requirements will appear to be satisfied, but until SMS design validation DCTs are performed that examine safety attributes, the operator cannot be assured of SMS acceptance by FAA. Specific safety attribute requirements of the part 5 standard are revealed only within the SMS data collection tools.
The Piecemeal SMS
This is why using a gap analysis during SMS development is fraught with potential for oversights and omissions. Beyond failing to address safety attributes, when identified gaps are filled with disparate elements, the result is often an SMS that is ‘pieced together’. The system is not congruent; it’s not harmonized. And of course it can’t be, because the SMS with its many components and elements was simply not designed as a system.
Things get even worse when the operator tries to pair their hard-earned part 5-conforming SMS Manual with software. Returning to the seven safety attributes, you won’t find them in 14 CFR part 5. AC 120-92D discusses them in Appendix F. The real acid test of whether your SMS design will be accepted by FAA lies in their review of your SMS Manual in conjunction with the SMS design validation DCTs. Bottom line: If SMS processes (such as safety hazard reporting, risk analysis, risk assessment, risk acceptance, investigation, corrective action plan development, control implementation, etc.) are performed in the software or web application, procedures for such processes should exist in the SMS Manual (along with the other six safety attributes).
Conclusion
The SMS gap analysis provides only a starting point to determine compliance with part 5. And when identified gaps are filled with disparate elements, the result is often a ‘piecemeal’ SMS. In addition, compliance alone is no assurance that your SMS will be accepted by FAA.
Today, there’s a faster and better way to achieve part 5 active conformance status with your CMT or the SMS Voluntary Program office. Avoid the piecemeal SMS and ensure both part 5 compliance and FAA acceptance with OmniSMS®. This professionally-developed system comes complete with a Part 5 SMS Manual template, Emergency Response Plan, Internal Evaluation Program, SMS web application, SMS Training Program, and integrated SMS training courses. Part 5 Declaration of Compliance and Schedule of Events templates are also provided.
OmniSMS needs no gap analysis, because there are no gaps! And nothing has been ‘pieced together’. The entire system is harmonized, because it was designed as a system and improved over time. Implemented by numerous operators and recognized by FAA, OmniSMS has been accepted by FAA offices across the country. The system is fully customizable and supported by a company that has been developing part 5 SMS systems for over a decade, with a proven track record of success.
From simple to comprehensive, OmniSMS can be configured to be a stand-alone part 5 SMS, or an integrated QSMS with support for AS 9100 / 9110 and ISO 45001 quality certifications. In addition, many essential SMS peripherals (link) are provided (such as VDRP, ASAP, ASIAS data sharing, fatigue risk management, and OHS management). Additional programs such as FOQA / Flight data analysis and LOSA can also be integrated for a truly comprehensive SMS. Learn more about OmniSMS today.