The FAA talks a lot about the importance of safety management systems. It has several web pages dedicated to SMS. Newsletters dedicated to SMS. And employees certainly talk it up at internal and external meetings. But talk is cheap, as we all know. If the FAA is serious about SMS and the benefits of a structured, data-driven approach to identifying and eliminating or mitigating hazards to aviation, it needs to make SMS mandatory throughout the aviation industry. There’s no way to garner the full benefits of SMS by depending solely on volunteer adoption. For one thing, a lot of entities just won’t do it voluntarily.
Well, to date it’s pretty clear that the FAA’s failure to promulgate rules speaks volumes about its real commitment to SMS. And, no, making SMS mandatory does not mean one-size-fits-all. It would be ludicrous to expect small mom-and-pop Part 135 operators to have the same extensive SMS as major Part 121 airlines. But it’s also ludicrous to expect a universal embracing of SMS in the absence of a rule. It takes time, commitment and money to develop and implement an SMS program. Many operators I’ve spoken with who would adopt an SMS are leery of spending time and money developing an SMS without knowing when and if the FAA is going to issue rules, rules that could conflict with their own programs and require them to make expensive changes.