Vapor Trails to Paper Trails
The Air Charter Safety Foundation is a non-profit organization comprising nearly three-hundred member companies. The foundation’s stated mission is to “lead and support the advancement of the highest safety standards available; to enable the business, charter, and fractional ownership industry to offer the safest air transportation products in the world; and to provide objective information about these standards and services to the public.
In accordance with its noble aims, the Air Charter Safety Foundation has organized an aviation safety leadership committee to review the FAA’s proposed rule requiring on-demand air charter, commuter, and commercial air tour operators to implement and use Safety Management Systems (SMS). The Notice of Proposed Rulemaking (NPRM) sets out to improve aviation safety by requiring organizations to implement proactive approaches to managing safety.
Citing the NPRM’s potential impact on Part 135 charter operations, air tour operations, and Part 91 certificate holders, Air Charter Safety Foundation president Bryan Burns stated:
“The ACSF is very pleased to see that the SMS NPRM is being issued. The ACSF has long been an advocate for voluntary adoption of SMS, and, as such, we provide an industry standard and training to effectively implement an SMS.” Mr. Burns continued: “Moreover, the ACSF’s board leadership has a cross-section of industry experts that represent air charters and manufacturers who’ve been actively engaged in promoting recommended safety practices. These industry leaders are already reviewing the proposed rulemaking to ensure that it addresses the variety, complexity and size of many of our member companies as they pursue a pathway to compliance.”
The FAA has set forth that it would afford certificate holders and aircraft operators one or two years to come into compliance with the new rule. Additionally, subject rule would more closely align the United States with Annex 19 to the Convention on International Civil Aviation.
According to the FAA, Safety Management System (SMS) denotes a formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of safety risk controls. Safety Management Systems include procedures, practices, and policies for the mitigation and management of all hazards likely to be encountered by air, ground, and maintenance crew-members, as well as passengers, and any other individuals peripheral to the business of aircraft operations.
Pilots, however, broadly look upon Safety Management Systems as nooses fashioned from red tape, political theater, window-dressing, and blame allocation mechanisms that function on the fatuous premise that the risks inherent packing people into aluminum tubes and blasting them through the upper atmosphere on columns of burning jet fuel can be mitigated with paperwork. Plainly stated, thousands of veteran pilots with immaculate safety records consider the notion of the SMS a ham-handed bureaucratic attempt to supplant pilot expertise and experience with flowcharts, worksheets, and basic mathematics.
In any case, the ACSF will submit the results of its SMS NPRM review to the FAA on or before the deadline of 13 March 2023.