By Joanne Landry and Ken Ibold
While most airports sit on the sideline waiting for the final FAA Safety Management System (SMS) rulemaking, some airport managers have begun formal SMS planning and implementation programs.
With more than 500 certificated airports operating across the nation, it appears that the total number of airports developing or operating SMS programs represents a mere fraction of all airports that would be affected by the agency’s SMS regulatory requirements.
This wait-and-see attitude implies that airports may face significant bottlenecks in finding qualified managers and technical talent and also may come head to head with an FAA oversight process that is unprepared for the deluge. Consider the following:
• Nine of the nation’s largest airports were implementing SMS voluntarily as of April 2014, according to the June 2014 GAO report, Additional Oversight Planning by FAA Could Enhance Safety Risk Management.
• Nineteen of the 26 SMS pilot study airports interviewed for Airport Cooperative Research Program (ACRP) Synthesis Study 37, Lessons Learned from Airport Safety Management Systems Pilot Studies, indicated SMS was being implemented.
• Four percent of 161 airports surveyed in early 2014 by Southern Illinois University (SIU) indicated their safety programs included a fully implemented SMS.
• Seven percent of the SIU survey respondents reported having some functional SMS components (see Figure 1).
Based on recent surveys of airport executives about SMS, one conclusion is clear: many — if not most — airports are willing to move forward with SMS but are unwilling or unable to take concrete steps due to their inability to dedicate personnel to the task or find funding to accommodate the effort.
For example, the SIU SMS survey asked airport respondents to indicate their organization’s “willingness to pursue SMS.” Survey results of 165 airport representatives are as follows: Extremely Willing – 5 percent, Very Willing – 7 percent, Willing or Supportive – 36 percent, Some Hesitation – 38 percent, and No Willingness or Support – 14 percent. Likewise, the GAO June 2014 report states that, “Uncertainty about FAA plans for SMS oversight was among the key challenges for aviation industry SMS implementation.”
With nearly 50 percent of the group SIU surveyed stating that their organizations are willing (within various degrees) to pursue SMS, the issue is why so few airports are actually investing in SMS. The SIU survey asked airport representatives that very question. The top two responses were lack of sufficient manpower and lack of funding.
The ideal solution would appear to be to begin planning and preparing for SMS without investing a significant amount of time and funds. In fact, there are a number of steps airports can take in advance of FAA’s final rule to smooth out the implementation process with little impact on existing resources. These include considering long-lead time items such as vision, budgeting, staffing, management buy-in, software development, and safety culture shift.
Staff Skills, Training and Hiring
When SMS arrives, one of the top challenges airports will face will be to employ or re-deploy staff to manage the program and FAA compliance. Determining whether existing staff will require training, or if additional staff should be hired, has a large bearing on both the financial and operational impacts. Training programs exist in various durations, formats, costs and focus, but, of course, training is not doing, and some practical experience may be important. Hiring staff typically involves a fairly long lead time for budget and coordination with human resources offices.
That human collateral isn’t limited to the airport side, either. GAO reports that, “Uncertainty about FAA plans for SMS oversight was among the key challenges for aviation industry SMS implementation. Although some inspector training has been provided, representatives from nine of the 20 stakeholders GAO interviewed cited concerns that FAA inspectors may not be adequately trained to oversee industry SMS activities, and six expressed concerns that inspectors throughout FAA may not consistently interpret SMS regulations.”
With that dynamic in mind, it appears that a well-trained and informed airport SMS team will ensure that, as SMS is rolled out, the airport and FAA can work collaboratively. Important steps to take to initiate staff skills development are:
• Research existing training programs
At the core of SMS is the ability to collect data, manage that information to allow for data trending, and proactively manage hazards and associated risks.
• Target staff who likely will oversee the SMS program
• Budget and schedule training
• Expand training to other team members
If hiring is the preferred option, collecting relevant skills and qualifications from airports that have engaged SMS managers can facilitate the process. Keep in mind, however, that other airports will be competing for qualified SMS personnel, particularly when the final rule is issued.
Software and Data Management
At the core of SMS is the ability to collect data, manage that information to allow for data trending, and proactively manage hazards and associated risks. Numerous commercial off-the-shelf software systems offer SMS modules, but integrating the SMS software with existing data systems and repositories typically proves challenging. Many airports collect information manually on paper, in spreadsheets, and in separate databases or software systems. That means a one-size-fits-all solution is elusive, depending on the specific airport’s existing processes.
Prior to purchasing an SMS software program, consider conducting an assessment of all data sources and systems to decide whether it makes sense to expand an existing system or procure a new one.
For example, management at General Mitchell International in Milwaukee recently launched an SMS implementation program. As part of the planning phase, the airport’s existing Cityworks system was identified as the “data center” for SMS. This decision was based on the large amount of existing operational, maintenance and safety data contained in the database. A new module will be developed that will integrate existing processes with SMS specific functions, such as hazard identification, risk ranking, corrective actions, audits and metrics management. One of the key data design concepts was to ensure that future FAA reportable SMS data would be separated from the broader SMS program that will include terminal and landside operations.
For airports with limited or no existing software solutions, the SMS initiative may create an incentive to begin tracking inspection data, maintenance records and other operational data — and, thus, a comprehensive system should be considered as a solution.
Most SMS projects can be phased to allow for early planning and budget allocation, even in advance of the final rule. Figure 2 offers a seven-step approach to preparing for and implementing SMS in segmented efforts. The first three steps can be accomplished prior to rulemaking without significant impact to staff and budgets. Within the green phase, management prepares for SMS through planning, funding preparation, staff identification and business objectives.
While many pilot study airports decided to roll out SMS throughout their organizations, it may be more effective for an airport to begin airside and then deploy to terminal and landside. In other cases, management may decide to integrate SMS into construction safety (to comply with FAA Order 5200.11) first or to operations as a means to prepare for upcoming compliance. Future rollout to other departments, such as maintenance and planning, could allow time to test processes, systems and functions before total implementation.
These business-related decisions and associated planning, scheduling and department identifications can be made prior to rulemaking. A core function of pilot study airports was to conduct a gap analysis. Step 2 in the chart supports a similar effort by conducting a formal assessment of current and future program needs. Step 3 in the chart consists of developing a formal implementation plan. (For additional information, see the FAA PGL 13-06 mentioned earlier.)
The planning effort can be accomplished with internal staff and very little budget and will prepare management for the SMS rulemaking regardless of the specifics outlined in the regulatory requirements. When developing a plan, it is important to consider scalability and flexibility. It may make sense to develop a Plan A and a Plan B, to allow consideration of various options, rollout schedules, departments, and staff roles and responsibilities.
Budgetary Sources and Planning
Budget constraints, as reported in the GAO and SIU surveys, appear to be a considerable barrier to SMS implementation. FAA has outlined AIP eligibility in PGL 13-06. Specifically, funding is allowed for the development of an SMS implementation plan, an SMS manual and software purchase. PGL 13-06 indicates that AIP planning grant, AIP entitlement, or AIP discretionary funds may be used. To request funds and discuss funding amounts, FAA asks that you contact your airport district office.
Approaching SMS with a good plan can help to manage the program more effectively after the rulemaking is issued. Planning doesn’t need to incur significant costs or staff time. Planning can be accomplished as a collateral duty and a shared duty by multiple staff. The SMS rulemaking need not result in reactionary efforts, if planning and thoughtful considerations are accomplished early in the process.
Getting a head start on SMS can be a relatively straightforward process: identify leaders, assemble a team, get informed, begin planning and scheduling, review funding options, research data and software, and most importantly, start now. A
Joanne Landry, principal of Landry Consultants LLC, can be reached at email@example.com.
Ken Ibold is a consultant in RS&H’s Aviation Program and can be reached at firstname.lastname@example.org.
Existing FAA Documents Offer SMS Clues
Airport management can get ahead of the SMS regulatory requirements by seeking clues in existing FAA documentation and by proactively preparing for future SMS program aspects, such as employee skills development, new staff hiring, software and data management strategies, implementation phasing and cost planning.
FAA’s Air Traffic Organization has conducted internal SMS initiatives for years. FAA’s Airports Division has been implementing SMS internally, and in support of that effort has been publishing various documents to manage the SMS functions and oversight. Relevant documents to the airport community include the following:
1 FAA Order 8040.4A Safety Risk Management: Order 8040.4A is adopted by all FAA lines of business agreeing to use the same risk matrix and general terminology. Airports can begin development of their Safety Risk Management (SRM) program by leveraging the FAA matrix, terms and concepts. The advantage is that all future SRM will be aligned with FAA.
2 FAA Order 5200.11 FAA Airports (ARP) Safety Management System: Order 5200.11 outlines how the airports division manages SMS internally, including oversight of airport construction safety programs. The companion to this order is the FAA Office of Airports Safety Management System Desk Reference, which provides additional guidance. These documents offer insights to the FAA ARP management of SMS, including relationships with airport sponsors and process flows for Safety Risk Management oversight and approvals. Note: see Order 5200.11 Changes 1, 2, and 3 for additional information.
3 FAA Program Guidance Letter 13-06 Safety Management Systems: The PGL 13-06 serves two purposes: a) it provides information regarding AIP funding opportunities for implementation of SMS; and b) the guidance letter presents a very clear and concise outline of an SMS Implementation Plan and SMS Manual. Before starting to plan either of these SMS efforts, review 13-06 for guidance and instruction.
4 FAA Safety Management System (SMS) for Airport Guidance, Tools, & Related Information: The FAA SMS website holds a vast amount of resources and references, industry research, and examples from pilot study airports. This is the best place to start for SMS information gathering.