FAA To Expand Safety Management Systems Requirements
Safety is a menacingly powerful word.
While many safety aspects can be quantified with historical data, assessment qualitative and emotional aspects tend to vary with the situation or implementation. I operated with SMS requirements throughout my career that ranged from, “How you will mitigate this risk” to “Prove to me that this risk won’t be realized”. Yes, you can be too safe. To say that openly casts shade on you and your organization. But good intentioned imposition of requirements in the name of safety can easily paralyze an operation. Some of the periodic reporting requirements alone in the NPRM will prove onerous for a small operation.
The NBAA has been advocating and providing resources for developing scaled SMS implementations for a number of years. Their program is as reasonable an approach as I’ve seen for fairly universal application in aviation operations.
We’ve gone through SMS in New Zealand. I would say about 90% of the benefits come from 20% of the system, and the rest is all cost in time and money (and all cost is a harm to safety). We were promised from the start that it would be scaled to the size of our operations, but in the end we had to do all the requirements even if the CAA guys acknowledged it made little sense for us.
The hardest part of implementation was a lack of understanding from CAA about SMS since they were quite new to it as well, so we had little effective guidance (despite a lot of effort on their part) and a lot of inconsistent directives. Different CAA officials would have different ideas about how parts were supposed to work, and we would get whipped back and forth or have to push back against some of the zanier ideas.
The Top Five Things To Get Right
Not a lot of new information, but a great summary of the data. Thank you.
A customer of mine once told me that in his business they use the acronym PACE. Primary, Alternate, Contingency and Emergency plans. When in a life-or-death situation, it makes a lot of sense to (at least) have a backup to your backup… and adjust as you progress through your flight.
Poll: Do You Bother With NOTAMS?
- Yes, because it’s required. Miss something important and it’s your fault. The only realistic way to do this is to learn how to scan quickly to determine which ones might matter and simply skip those that don’t appear to. The danger, of course, lies in missing the one critical fact hidden somewhere in the daunting morass of irrelevant minutia that is the NOTAMs associated with your flight plan. (Legal proof that you were warned!).
- About 80% of my flights are IFR—but I use Foreflight—which automatically brings up NOTAMS. I skip over the mundane (“a single runway light OTS”) to look at what DOES count. It’s an indication of the ineffectiveness of the government system that so many pilots use PAID systems (like ForeFlight) rather than use a “free” system like the government.
- Bother with, yes. Bothered by…absolutely! I used to have to sort through yards-long printouts of paper containing mostly inapplicable NOTAMs prior to each flight. Many of these NOTAMs are merely kiester-covering lawyer-proofing by airport and infrastructure entities who are too lazy to fix or remove inop equipment or features. Local bureaucrats think they can wash their hands of an issue once they’ve published the NOTAM. There need to be time limits on NOTAMs just like MELs, fix or remove by a date certain or face a fine.
- I once had a transatlantic flight which had 3 ETOPs alternates and 2 destination alternates due to bad weather in Europe. The paperwork printout stretched from the flight deck to the aft galley of a B-767, (yes, I paced it out!). Two thirds of this train was made up of trivial or just flat out non-pertinent NOTAMs (oh yes; and each one had a disclaimer paragraph about the Federal paperwork REDUCTION act!).
- Yes, but what really bugs me are the NOTAMs posted for things happening days later. Obstacle NOTAMs are almost useless when there are dozens. Just tell me what the minimums are. More than 100 NOTAMs at some of the major airports is also ridiculous.
- I try, and with ForeFlight have some limited success wading thru the nearly indecipherable mess. By far the most import “fix” needed is to eliminate the useless jargon that buries important information. What, Where, and When in straightforward terms is how NOTAMs need to be presented with the “What” being the only bit that might take as much as full sentence or 2 to explain.
- Runway and taxiway notices that show up on ForeFlight.
- Always when flying someone else’s airplane for hire.
- First time you land at an out-of-the-way airport that has no fuel – and you didn’t read the NOTAM… You tend to pay attention after that.
- I always check aerodrome, but there is too much garbage to check enroute NOTAMs.
- Depends on what and where I’m flying.
- Not so much for local flights, but yes for cross-country trips.
- At least to know if the runways are open at start and destination. Then scan for other abnormalities quickly.
- That’s what dispatch is for. We only see the pertinent NOTAMs.
- Always when filing IFR, seldom when flying VFR (except TFRS and WX).
- CFR 91.103. Any more need be said? Bottom line is answer is yes.
- Yes, always, but I have a lot of doubt that I’m finding all of the wheat among the chaff. We need tools that allow us to deselect types of NOTAMs (obstruction lighting, things that are in the current version of charts, etc.) and allow us to specify our routing and only see NOTAMs within a reasonable distance of our route.
- I always look, but I do a good deal of skimming looking for the tasty bits.
- Always when IFR. Rarely when heading out for the $100 VFR hamburger.
- Try to filter and decipher – but often too much gibberish.
- I have to check NOTAMs. Part of being an air carrier captain. The key is knowing what NOTAMs are important. As an IFR pilot, if a NOTAM affects the clearance usually ATC will not clear you on the requested clearance, e.g. closed airport. I believe VFR pilots have to be much more careful about checking NOTAMs because as a VFR flight the pilot is mostly on his/her own.
- Depends on the mission. Other than TFRs and airport or runway closures, they are irrelevant to local GA and Soaring flights.
- Runway NOTAMs yes, others not so much.
- Always, and that’s why I’m so cranky about their inadequacy. NTSB needs to start listing FAA as likely cause of all accidents ever.
- Depends on type of flight.
- I read them until my eyes glaze over and I begin to drool.
- Yes but there are so many and so badly organized they are almost worthless.
- Every time I fly cross-country.
- Depends on what kind. Destination NOTAMS, yes. ARTCC NOTAMS, no.
- When I have to.
- I am still a dinosaur and get a brief from Flight Service. I ask for pertinent NOTAMS, even though they are supposed to give them to me.
- If it doesn’t show up on Foreflight, no.
- Only the ones that humans can actually read.