Safety Management Systems (SMS) Scaled for Owner-Flown Operations

Safety Management Systems (SMS) has played a significant role in reducing accidents and incidents across industries and has proven effective in aviation, when adopted by the military, airlines, and corporate operators. Creating and implementing an SMS and developing a Safety Culture in owner-flown operations is a key strategy towards our goal of zero fatal accidents in the Piper PA-46 community. An SMS that has shared commitment from the aircraft owner/pilots and the Owner Pilot Association (OPA) can be implemented with the following approach and based on the Four Pillars of SMS: Safety Policy; Safety Risk Management; Safety Assurance; Safety Promotion.

For an SMS to have tangible value and reduce accidents and incidents, it must include robust elements that drive safety. Yet for owner-flown operations, it cannot be so complex that it is perceived as burdensome and is designed to fail. It also cannot be oversimplified, therefore, lacking data that drives safety decisions or lacking the development of a safety culture. Existing aviation SMS programs are designed for larger entities requiring significant investment and ongoing resources, or they are too lean and do not deliver the true potential of SMS. Leveraging the OPA, through staff and volunteer efforts to create and foster the SMS, and through owner-pilot efforts to engage in the SMS, can bridge this gap and reduce the frequency of accidents and incidents we are experiencing today.

Safety Policy

FAA Guidance: Establishes senior management's commitment to continually improve safety; defines the methods, processes, and organizational structure needed to meet safety goals.

In an owner-flown scenario, the concept of “senior management” is best structured as a shared responsibility between the aircraft owner/pilot and the OPA, as the OPA has no direct influence on the aircraft operation or the aircraft owner’s commitment to safety.  

  • The owner/pilot must be fully committed to engaging in the safety programs and each element of the SMS. They are more than a line pilot flying for an airline - they are the executive responsible for their own flight operation.

  • The OPA - its Board of Directors and its Safety Committee, in particular - play a key role in leading the SMS program development and modifications for the group of owners/pilots participating in it; ensuring ongoing funding for critical safety initiatives; and approving policies as required and appropriate. 

PMOPA’s Safety Policy will be jointly signed by the PMOPA President and each aircraft owner participating in PMOPA’s SMS program.

The OPA establishes our safety values, expectations of program participants, safety commitments/objectives/goals that will be measured under Safety Assurance, and allocates resources to facilitate the SMS program. This includes planning and preparing for emergency situations, including the development of emergency response procedures, training for emergency response teams, and regular testing of emergency response plans.

SMS Element/Description

OPA Role

Aircraft Owner/Pilot Role

Ensure High Level Commitment 

Safety is taken seriously through thought and action

  • Creates a letter that aircraft owners sign-on to expressing their support of and engagement in SMS

  • Provides financial resources to facilitate SMS 

  • Aircraft owner is the manager and provides commitment to safety performance

  • Will provide time resources to facilitate SMS

Establish Safety Objectives/Goals

Aspirational goals with a long-term view

  • Provides template for operators to identify big areas of risk specific to their operation 

  • Establishes broad safety objectives for the PA-46 aircraft fleet

  • Completes Safety Risk Profile based on their specific operations

  • Establishes safety objectives relevant to their specific operation

Methods, processes, and organizational structure

  • Describes how to manage safety in: 

  • Flight operations

  • Maintenance oversight

  • Training

  • Fatigue management

  • Applies processes applicable to their individual:

  • Flight operations

  • Maintenance oversight

  • Training

  • Fatigue management

Emergency Response Plan

  • Provides template with general information - 1 or 2 pages broadly outlining what will do

  • Completes individual information relevant to ERP 

Change Management Process

  • Outlines how management of change works (e.g., change in operations)

  • Provides feedback and recommends improvements to the program

 

Safety Risk Management

FAA Guidance: Determines the need for, and adequacy of, new or revised risk controls based on the assessment of acceptable risk1.

PMOPA and its Safety Committee will identify common hazards, risks and mitigation strategies applicable to general aviation and Piper PA-46 aircraft in particular. 

A hazard is a condition that exists (e.g., a mountainous airport). The hazard can present a risk to the aircraft operator (e.g., Controlled Flight Into Terrain). Risks are evaluated on the basis of two dimensions: 1) probability of it occurring; 2) the severity, if it occurs. In this construct, owners/pilots participating identify hazards and risks and the PMOPA Safety Committee will then categorize them, reflect the probability and severity of the hazards and risks, rank them, and prioritize efforts. Hazard and risk reporting must be streamlined and simplified to encourage reporting.  

One cornerstone of an effective SMS program is confidentiality. Any safety-related data shall be protected from inappropriate use. Additionally, 

SMS Element/Description

OPA Role

Aircraft Owner/Pilot Role

Ongoing process to identify hazards, evaluate associated risks and implement mitigations

  • Creates structure to track hazards and associated potential risks

  • After owners do risk analysis for their operations, review and rank risks based on probability & severity

  • Tailors training for risks common to the Piper PA-46 fleet

  • Provides data for unique operations and addresses high-risk, manageable operations that are not mainstream risks

  • Provide FRAT; collect and analyze data to help understand common risks within pilot community (e.g., urgency of mission; flight currency/recency)

  • Complete risk analysis related to their operations

  • Adopt risk mitigation strategies 

  • Understand FRAT; utilize FRAT

  • Flight Data Monitoring program

  • Create and facilitate FDM program

  • Analyze data

  • Generate reports and recommendations

  • Upload data

  • Review reports

  • Implement appropriate recommendations
     

 

Safety Assurance

FAA Guidance: Evaluates the continued effectiveness of implemented risk control strategies; supports the identification of new hazards1.

PMOPA’s SMS program will need to be able to measure objectives and provide targets represented as: 

  • Safety Performance Indicators, and 

  • Safety Performance Targets 

To audit our processes on a continuous basis (e.g., were what we identified as our safety objectives the right ones? Did we make a measurable improvement in our Safety Performance Indicators?) 

SMS Element/Description

OPA Role

Pilot/Aircraft Owner Role

Audits as an Evaluation Tool

  • Establishes processes and timeline for system audit

  • Reviews System Performance (are we achieving our SPTs)

  • Adjusts program indicators and targets

  • Provides ongoing feedback with respect to program processes, SPIs and SPTs

Tools

  • Provide tools for legal airplane evaluation

  • Ensures compliance and audits individual records; examples may include:

  • Aircraft Logbooks
    Pilot Logbooks / Currency / Recurrent Training

  • Required insurance coverage

  • Aircraft Registration

  • Valid pilot medical

  • 100 hour inspection

  • Is POH on Board?

 

Safety Promotion

FAA Guidance: Includes training, communication, and other actions to create a positive safety culture within all levels of the workforce1.

PMOPA’s workforce is its Safety Committee and the individual owners/pilots. In addition to developing training programs that are relevant to the safe operation of Piper PA-46 aircraft, this includes generalized training about SMS, hazard and risk reporting, evaluation and mitigation. 

SMS Element/Description

OPA Role

Pilot/Aircraft Owner Role

Training

  • Provide training

  • Participate in training

  • Identify opportunities for improvement

Communication

  • Safety content for magazine

  • Read and understand content

  • Seek clarification

Safety Culture

  • Provide status, annually, on progress towards SPTs

  • Read reports

  • identify ways for the individual to help