NBAA SMS Class

[G4G5]

Here's the deal with the SMS: It needs to be IBAC certified.

The issue is the FAA has decided not to get involved with the approval process so you have no one to turn to with in the FAA for guidance. This only becomes an issue IF you fly internationally. If your flying is domestic only then you have no SMS requirements to meet.

This is their latest take on the subject:
"Additionally, operators of large and turbojet airplanes that fly internationally have a requirement to establish an SMS."

http://www.dca.gov.bm/Lists/Announcements/Attachments/98/FAA InFo SMS and Annex 6 Part 2.pdf

If you fly internationally you need to follow ICAO Annex rules which state that you need to abide by the rules of the nation in which you are flying.

"§ 91.703, operators are responsible for compliance with foreign countries’ flight rules and international standards when operating outside of the United States."

If that country wants an SMS, then it has to be an approved SMS, and since the FAA does not approve SMS's you really only have two choices.

Choice one is IBAC, they have the only ICAO recognized SMS approval process. This is the reason why many folks are getting the ISBAO (branch of ICAO) approved manual because a chapter within the manual is dedicated to your companies SMS. Get ISBAO approval and get international SMS approval. Or you could send in your SMS to IBAC and ask for approval.

Choice two is to go directly to the nation in which you plan to travel and have them approve your SMS manual. You can send your flight ops manual directly to the French or Canadian or Bermudian versions of the FAA for approval.

The Bermudian Department of Civil Aviation issued this letter of Guidance on the topic.

http://www.airsynapsis.com/Services/IS-BAO/Bermuda DCA Article 85 Summer Update.pdf

Take a close look at page 3:

The First paragraph explains the ISBAO process is the preferred method.

In the second paragraph they are very clear that they do not want to get involved with approving your manual. I spoke with them directly, due to lack of adequate staffing they have set the price so outrageously high that they are forcing you to use the ISBAO/IBAC process.

But if you really want yours approved they will except your $1500 a day for 10 days to go over and review your manual. Then another $1500 a day, plus $750 a day for travel, plus all expenses to come out to your facility and conduct the audit.

Now when you start to consider the fact that this is just how one country plans on dealing with the SMS issue, then it's quite clear that creating your own internal manual and dealing with the independent certification process to comply with the ICAO Annex requirements is not the way to go.

Now if the FAA had a set they could have applied for relief from the ICAO annex and this would not have become an issue but as we all have seen over the past 10+ years the FAA is now just a branch of EASA. The Europeans are driving the bus get on or get run over.

 

[AA717driver]

So G-200 and the clowns like him think they are smarter than Dr Tony Kern, Ed Bolen, John Sheehan and a hundred other leaders out there in business aviation.

Safety programs work - period. So Southwest, Delta, United, Net Jets, Pepsico, Home Depot, Exxon, and nearly every quality flight department out there - G200 says they are all wrong and he is right? If you worked in my flight dept and spouted nonsense like that I'd ask you to seek employment elsewhere.

Put me in the category of "clown". As I've said before, this is simply an effort to 'legislate' safety while neglecting to foster good piloting skills and get rid of those with bad piloting skills. You cannot codify common sense. You cannot be a good, safe pilot without common sense. This is just another attempt to pound the square peg into the round hole.

AND, most (if not all) of these types of programs are generated by denizens of training departments who want a project to work on that will keep them out of the cockpit as long as possible. In the airlines, in particular, the bulk of those in training and management are simply pilots who don't want to fly. They have to justify their jobs so they come up with programs like this.

And, once those types have retired, they go to work for the FAA or some other acronymed organization and lobby to get "their" program mandated by the government.

Never trust a Flight Attendant with a chipped tooth or a pilot with a Masters in Aviation Management.

TC

ETA: Having had more stupid, do-nothing programs foisted on me than pay raises in my career, I'm over this.

 

[AA717driver]

The funny part is that he was a recently retired airline pilot from United. I try not to view these retired airline pilots in a bad light with regards to corporate ops, but crap like this makes you wonder.

Unfortunately, I'm afraid it's going to get worse with all the age 65 retirees shuffling out the door in the next couple of years.

They hear about my experiences while furloughed and their eyes light up. Fortunately, the cost of admission usually stops them in their tracks...

TC