Small-Operator Exemptions Some SMS requirements do not apply to certain single-pilot operators. A review of Part 5.9(e) reveals 13 potential Part 5 exemp- tions that may apply to a select group of single-pilot operators, specifically “entities with a single pilot who is the sole individual performing all necessary functions in the conduct and execution related to, or in direct support of, the safe operation of the aircraft.” Tis exemption would require the individual
to be the aviation equivalent to the “chief cook and bottle washer.” All necessary functions of the sole individual are clarified in the new rule to “generally include: operational control, refueling, ground handling of the aircraft, flight planning, weight and balance calcula- tions, performance of preventive maintenance, coordination of maintenance activities, preflight and post-flight activities, and financial deci- sions related to operating the aircraft safely, in addition to operating the aircraft.” If a sole proprietor performs all those tasks
Buckle up—the journey might get a little bumpy for unprepared operators.
to you, in whole or in part. Here’s a brief overview of the revised applicability. For more
details, please refer to Part 5.1. ■ Operations conducted under Part 121 (air carriers)
■ Operations conducted under Part 135 (commuter and on-demand operations) —new
■ Operations conducted under Part 91.147 Letter of Authorization (LOA) holders or applicants (passenger-carrying flights for compensation or hire)—new
■ Part 21 type certificate and production certificate holders—new.
without assistance, they will indeed get much- needed relief from illogical requirements like submitting a written hazard report to themselves.
What Is a Safety Management System?
If you’re not yet familiar with the foundational components of an SMS and how to apply them, it’s time to get up to speed, and fast. Te definitions section of the SMS rule is short, with only 10 definitions provided. An SMS, as defined in Part 5.3, is “the formal, top-down, organization-wide approach to managing safety risk and assuring the effec- tiveness of safety risk controls. It includes systematic procedures, practices, and policies for the management of safety risk.” Definitions of an SMS from most resources
follow a similar theme to that shown above. For those still disoriented by the whole thing, I prefer to think of SMS from an operational risk management perspective and ask three simple questions. 1. What keeps you up at night? To consider what can go wrong in daily operations, one must attempt to identify employee and
customer exposure to hazardous conditions and activities hiding in plain sight or lurking in the shadows. Tis is no small task, but it is the most critical SMS activity. Every employee and stakeholder must participate in this process (via, for example, observation, interviews, surveys, and so on). Once this process is completed, an operator should develop a comprehensive list of hazardous activities and conditions and assess the corresponding risk level based on probability and severity. Te risks deemed too high must be mitigated to the lowest acceptable level.
2. What are you doing about it once you’ve identified some risks that need mitigating to reach a lower, more “acceptable” level? Beyond avoidance, what else can be done to reduce the likelihood or severity of those risks resulting in an accident or incident? What policies, procedures, training, and education can you provide to ensure that employees and customers understand workplace hazards and how to avoid, mit- igate, and report them?
3. How do you know if it’s working? What are your results? Don’t just consider lagging indicators such as accident and incident statistics. Do employees feel safe reporting unsafe conditions? A spike in employee reports (this is a good thing versus accidents) should provide the information you need to answer that question. Are employees more invested in workplace safety and efficiency? Do they better understand hazards, and are they being reported before they lead to undesired outcomes? If the answer to these questions is yes, you are off to a good start. Be patient and repeat the process, addressing any gaps you discover. Of course, getting beyond a general under-
standing of SMS is paramount for compliance with the new rule. Where should you start? Fortunately, several excellent resources are available to make that determination. Here are some to consider in your quest for SMS
knowledge: ■ Safety Management Systems Rule: Federal Register PDF version of the final SMS rule. ■ Advisory Circular 120-92B: Safety Management
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