2009 SMS Pilot Project (SMSPP) Analysis - FAA

8-0 Key Take-Aways from Pilot Project
8-1 Managing Change
• Spirit vs letter of the law - Industry is concerned that the FAA will not follow the spirit
of an SMS rule but will execute the letter of the rule once an SMS rule is implemented.
The MSMS team agrees that this has been an issue with other rule changes and the FAA
should embrace a robust method to implement and manage changes in the future.
• Industry is also concerned about the unintended consequences where the local FAA
offices do not move toward any newly envisioned oversight model.
8-2 SMS Progression
• Safety Assurance process – Voluntary safety reporting programs are a vital element of
an SMS. However, obtaining safety information from repair stations is difficult and is a
major concern of the pilot project participants. Most companies do not have any leverage
(other than warranty return program) to entice repair stations to report field service data
such as failures, malfunctions and defects. Their ability to proactively or predicatively
address new or potential risks and hazards from aging fielded product is nearly
impossible without new reporting rule(s) which means important data is lost.
• Organizational hazard concept – Identification of hazards associated with
organizational factors, including human performance within an organization was a
paradigm shift. Many pilot project participants had difficulty understanding that certain
organizational decisions could impact the safety of a product. They also had a tendency
to focus on product issues only and consideration of organizational factors that affect the
product was not easy for them to embrace. Understanding that SMS could affect the
whole organization was a cultural change that some participants pick up on more quickly
than others. The MSMS team’s research on hazards helped facilitate discussions about
organizational, process and product hazards and we also displayed on the wall during the
PGA meetings examples of organization, process and product hazards.
8-3 Project Management
• Collaboration - MSMS team collaborated with the D&M industry by considering their
feedback, resulting in a more streamlined and useable SMS framework. The change to
the framework was not only beneficial, but it also showed the D&M industry that the
MSMS team was willing to work together and gained more of their trust. In addition to
changes to the SMS framework the MSMS team also incorporated over 70 changes to the
pilot project guidance and processes.
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