Dominic Acevedo, Reva Air Ambulance director of safety, discusses the value of a validated safety management system for air ambulance operators.
The aviation industry has been changing rapidly for the last decade and, through regulation, safety management has started to envelop all commercial operators. In 2010, Bermuda Civil Aviation initiated a requirement for all operators involved in FAR Part 91 and 125 or equivalent to be compliant with ICAO Annex 6, Part 2, Section 3. One of the changes that we will be looking at is the requirement to have a safety management system (SMS) in place. An operator could quickly comply with this requirement by going through a third-party SMS provider to receive a certificate of compliance. However, a manual on a bookshelf is not an implemented programme. Some years later, the European Aviation Safety Agency (EASA) and the US Federal Aviation Administration (FAA) recognised this and began the rule-making process for commercial operators to have a validated SMS in place.
In 2014, EASA published a new requirement for a single EU-wide safety authorisation that would allow commercial operators to fly to and from the EU. This authorisation is called Part TCO (third country operator) and had a mandate of 24 November 2014 to apply for the authorisation. Those operators who were fortunate enough to apply and receive their TCO number must ensure they are part of the SMS Volunteer Program under the FAA or have a fully validated programme under EASA. Failure to meet these requirements would prevent a commercial operator from flying to and from the EU after 26 November 2016.
The FAA currently has a set of implementation standards under CFR Part 5 for FAR Part 135 Operators who would like to be validated. In my opinion, after having gone through half of this process [at the time of writing], it is well worth the effort. This process brings the operator and the FAA closer together as a team and enhances the working relationship between them. It forces the operator to implement all the standards and to be able to demonstrate them to the FAA for final validation. There is no hiding non-compliance, and questions should be asked of any operator out there before they are hired for a transport.
“Do you have an SMS?” should not be the only question to ask an operator, but also, “Is your SMS validated?” A validated SMS would have the four pillars in place: safety policy and objectives; safety risk management; safety assurance; and safety promotion. There is a difference between saying you have an SMS and proving it. Safety is the priority.