November 22, 2010

The November 18 deadline set by the International Civil Aviation Organization (ICAO) for the Federal Aviation Administration (FAA) to have in place regulations regarding Safety Management Systems (SMS) has come and gone, yet the FAA is still years away from determining whether a regulatory mandate for SMS even makes sense for business aviation operations. For operators who fly only within the United States, this means business as usual with no immediate reason to be concerned about compliance.

Business aircraft operators who travel outside the U.S., however, are now subject to another country’s safety requirements, which could include SMS. NBAA members who operate internationally should be aware of the requirements for the countries to which they are traveling, said Doug Carr, NBAA vice president for safety, security and regulation.

Carr cautioned that in particular, operators traveling to Bermuda and several Caribbean nations may be required to have an SMS, or to demonstrate that one is being implemented. Since the FAA has no SMS standards for non-commercial operations, Carr said that an operator-developed SMS that addresses the requirements of ICAO Annex 6, Part II should be deemed compliant.

These include:

  • A process to identify actual and potential safety hazards and assess the associated risks
  • A process to develop and implement remedial action necessary to maintain an acceptable level of safety; and
  • Provision for continuous monitoring and regular assessment of the appropriateness and effectiveness of safety management activities

Any documents that an operator can carry, such as an SMS manual, excerpts from an operations manual that address SMS, or audits may help to demonstrate compliance in the absence of clear, standard regulations. In addition, operators that have purchased the International Standard for Business Aircraft Operations (IS-BAO), and are actively working to implement the standards, may request a letter that demonstrates their intent to meet SMS standards.

Operators that would like to request this letter or share their experiences with ramp inspections related to SMS should contact the NBAA Operations Service Group at (202) 783-9250 or

If, some years into the future, the FAA proposes mandating an SMS for non-commercial operations, NBAA will be front and center in making sure that any proposal is reasonable and actually enhances safety, and addresses any concerns raised by industry said Carr. “We are always looking for ways to continue business aviation’s steadily improving and stellar safety record, which is clearly not a reflection of minimum standards, but one of adoption of best safety practices that far exceed the requirements set by the FAA,” Carr said.