By Jeff Guzzetti
You may have seen the news clip last month in Aviation Maintenance announcing that the FAA now recognizes AAR’s Aviation Services as the first independent MRO to have a fully functional Safety Management System (SMS). “AAR´s SMS implementation meets the expectations of the Flight Standards Service SMS Voluntary Program guidance,” the FAA stated. “Thank you for your continued commitment to improve aviation safety … and congratulations on your momentous achievement.”
Momentous indeed. Airworthiness is a critical aspect of aviation safety. This noteworthy achievement should grab the attention of our industry because of the example it sets for other MROs to prevent aircraft accidents and injuries. AAR is the largest independent MRO operator in North America and the third largest in the world. The company employs over 3,000 technicians and provides maintenance for over 950 aircraft and 24,000 components every year.
The recent “Part 5” requirement to implement a SMS has only been levied on Part 121 major airline operations and maintenance. Other aviation entities such as MROs, Part 135 operators and training providers do not (yet) require SMS. Still, AAR went ahead and volunteered to meet the mandate anyway by participating in FAA’s SMS Voluntary Program.
This is no easy task – especially for a large MRO and especially if you want to do it right. Don’t believe me? Spend some time poking around FAA’s internet page entitled “Voluntary Implementation of SMS which can be found here:
https://www.faa.gov/about/initiatives/sms/specifics_by_aviation_industry_type/air_operators/
As a former FAA and NTSB investigator, I know first-hand that accidents occur due to the unique operating environment of an organization. SMS is a process in which day-to-day safety issues are discovered, analyzed and corrected internally by the organization, not its regulator. With its emphasis on risk management, SMS fills the gaps between “common cause” risk factors that are addressed by traditional regulations and those that are more elusive within an individual operation.
SMS is a fundamental shift in the way companies do business in that it emphasizes safety management in the same manner as business management. It may be too much to expect, but I believe everyone in aviation should be able to rattle off the four components of a SMS as if they were required memory items:
- Safety Policy— Establishing senior management’s commitment to continually improve safety
- Safety Risk Management — Identifying and assessing hazards in order to control their risks
- Safety Assurance — Evaluating risk control strategies with audits and self-reporting
- Safety Promotion— Training and communications to promote a positive safety culture
The first type of recognition into the FAA’s SMS Voluntary Program is as an “Active Participant” which is attained when the local FAA certificate management team (CMT) acknowledges the MRO’s “Implementation Plan” and the CMT’s “Validation Project Plan” for SMS. The second and final step is the SMS “Active Conformance” acknowledgement — achieved once both plans have been executed as intended and the SMS has been validated by the FAA for its design and performance.
In AAR’s case, the company’s Rockford, Miami and Oklahoma facilities began their SMS development process in late 2018. The Rockford facility received “Active Conformance” status while Miami and Oklahoma City are “Active Participants.” The fourth of AAR’s four U.S. facilities is in Indianapolis and it will soon be joining the other three within a few months. Safety is journey, not a destination, and AAR gets it.
AAR’s achievement is all the more impressive given its circumstances several years ago when it under public scrutiny for not always emulating the best safety and compliance practices. You may remember the negative publicity about an Allegiant Airlines jet that nearly lost control on takeoff from Las Vegas in August 2015. The investigation revealed that the airline’s maintenance provider at that time – AAR — failed to insert a cotter pin on a critical flight control component and have another technician conduct a secondary inspection to ensure it was installed. Other repetitive maintenance issues were also discovered. AAR was on the cusp of being fined by the FAA and having its MRO certificate suspended.
Today is a different story. Kudos to AAR for committing to the arduous journey of voluntarily implementing a SMS. AAR is already reaping the benefits. “Employees are excited about SMS because it provides an easy way to share their thoughts on how we can take our quality and safety practices to the next level,” a representative of AAR recently told me. “It helps to create a culture [where] people want to work every day.”
Improving and promoting an organization’s safety culture is key because it is the “glue that binds” people together toward a goal that is larger than themselves. A quick glance at AAR’s annual reports and public records show that performance goals for safety have been established, its stated corporate value is “Quality First, Safety Always,” and FAA enforcement actions are nearly non-existent.
That said, I offer this unsolicited word of caution to AAR and any other MRO or organization that seeks an effective SMS program. In safety management, everyone has a role to play; however, the expectations that lead to a positive safety culture are created and maintained at the top of the organization. Leadership enables success only by its continuous adherence to what they profess, how they allocate resources, where they align their organizational goals and when they exude a strident unwillingness to compromise. Without the continuous commitment of all levels of management, an effective safety program cannot exist. SMS should not merely be a binder of slogans and processes that collects dust on a shelf. It must be fully integrated into the fabric of an MRO’s daily operations.
To conclude, I congratulate AAR for this achievement, and I am hopeful they will reach – and maintain — “active conformance” at its other MRO locations. Implementing the SMS framework is scalable with the size and complexity of any MOR or organization. AAR has paved the way. I look forward to seeing many other independent MROs follow their path to safety.