Safety Management Systems at Airports

In Part Two of our two-part series on Safety Management Systems, we focus on FAA requirements for airports. Early adopters are reporting positive results, and—spoiler alert—collaboration will be key to compliance.

Following the FAA Safety Organization’s final rule for Part 121 airline operators in 2015, the agency published its final ruling on Safety Management Systems (SMS) for some Part 139 airports in February 2023. It applies to airports that are:

• classified as a hub; or
• have a three-year rolling average of 100,000 operations per year; or
• have international operations other than general aviation-only traffic.

An SMS emphasizes safety management as a fundamental business process to be considered in the same manner as other aspects of business management, says FAA materials. It is the formal, top-down business-like approach to managing safety risk, which includes a systematic approach to managing safety, including the necessary organizational structures, accountabilities, policies and procedures.

By recognizing the organization’s role in accident prevention, SMS provide both certificate holders and the FAA:

• a structured means of safety risk management decision making;
• a means of demonstrating safety management capability before system failures occur;
• increased confidence in risk controls through structured safety assurance processes;
• an effective interface for knowledge sharing between regulator and certificate holder; and,
• a safety promotion framework to support a sound safety culture.

Ramping Up

FAA took a methodical, collaborative approach to the new SMS requirement, beginning with FAA-funded pilot studies at more than 30 airports. Those that participated in the pilot studies were eligible for Airport Improvement Program grants to cover the cost of developing an initial SMS plan but did not need to apply for a grant to participate. 

The first pilot occurred in 2007, the second in 2008. In December 2009, FAA announced its plan to conduct a Part 139 SMS Implementation Study to examine how airports implement the elements of the Safety Risk Management and Safety Assurance components throughout their airfield environment.

Using lessons learned from the initial pilot studies, FAA issued a Notice of Proposed Rulemaking in October 2010, which netted valuable comments that prompted the agency to develop an improved proposal. To allow additional comments on those revisions, FAA issued a Supplemental Notice of Proposed Rulemaking in July 2016. The final rule issued last year is based on the comments received following that notice and a third open comment period in 2021.

Sacramento International Airport (SMF) is one of the airports that participated in an initial SMS pilot program and spent more than five years developing its system. SMS Manager Ron Reichel joined Sacramento County Department of Airports in October 2017, bringing with him prior SMS experience from the federal level. “They were being proactive,” Reichel says of SMF leadership. “They were trying to get ahead of it. The rule wasn’t out yet, so we had time to build the program slowly without having timelines associated with it.”

Dallas Love Field (DAL) is another frontrunner in SMS compliance. Javier Centeno, superintendent of Airport Operations at DAL, explains that leadership at the airport had a strong desire to enhance safety and be proactive, so it closely monitored the development of the SMS rule over the years. In late 2020, the city of Dallas, which owns and operates DAL, engaged Landry Consulting to develop and implement all the components of an SMS. “We are lucky to have leadership support, which is a big thing,” Centeno notes. “Without that support, we couldn’t have been ahead of the game.”

Landry has been actively involved in SMS research and development since 2007, including contributing to regulatory review and FAA collaboration.

Relying on Relationships

FAA notes that one of the defining characteristics of an SMS is the emphasis on risk management. Through reporting and data collection, airports can analyze, assess and control risk. The concept of SMS is all about decision making, according to FAA. It has to be a decision maker’s tool, not a traditional safety program separate and distinct from business and operational decision making.

Further, the agency wants safety to move from both the top down and the bottom up. Everyone from the receptionist and ramp worker to pilots, managers and FAA inspectors has a role to perform.

“SMS is based on relationships,” Reichel stresses. “You have got to build trusted relationships. The first time you talk to somebody about a problem shouldn’t be the first time you’ve ever talked to them.”

Beginning with senior leadership, Reichel worked his way through the SMF organization to ensure that all teams, especially frontline personnel, understood the requirements and what would need to be done to meet them. “You need senior leadership commitment for it to work,” he says. Likewise, the SMS manager has to build trusted relationships with airport tenants. “You can’t have efficient or effective communication unless you trust each other.”

During his presentations and conversations, Reichel would explain what SMS is and then ask people, “If you were king for a day, what would you change?”

The answers helped create an organizational structure and identify risks, and allowed Reichel to start building a reporting process and documentation tool in a slow and deliberate manner. “We were pretty busy with hazard reports the first three years,” he recalls. “I would say, pace yourself as you go forward. That’s what we did.”

The next step at SMF was reaching out to airport stakeholders, including the airlines, airfield maintenance staff, planning and engineering departments, ARFF personnel, ground support equipment operators, security and access control personnel and more. The wide cross-section of participants helped build a Safety Action Team to share information and develop objectives and goals for the emerging safety program. “SMS has really progressed in the airline industry,” notes Reichel. “So when you talk to the airlines, it’s going to be an easier conversation. They’re already familiar with it.” 

Overall, however, Reichel stresses that it was a slow process. Talking to various stakeholders was very valuable because it’s a great way to share information, identify potential issues and develop action items, he adds.

A risk assessment that affects other tenants on the ramp, for example, would involve all of those stakeholders to discuss issues, decisions and potential follow-up actions. “I try to use a round robin technique to make sure everybody has a chance to speak,” Reichel explains. “Everybody has a vote.” Once a hazard that requires action is identified, the group performs a risk assessment and discusses potential mitigation strategies.

Assurance, one of the SMS regulation’s key tenets, has caused some confusion in the industry. For Reichel, assurance has several components: a confidential reporting system, annual assurance audits, the ability to analyze numerous sources of data, and continuous communication with leadership. By compiling data from airside notices of violations, incidents, and hazard reports onto a single dashboard or spreadsheet, an airport can recognize possible trends, red flags or areas that might need addressing. At SMF, personnel chart the airport’s safety objectives on the same dashboard to easily compare the data and bring about continuous improvement and positive change. 

Reichel advises other airports to take a metered approach to risk assessments rather than trying to perform too many too quickly. “You can oversaturate your groups,” he cautions. “You have to be patient. A quick implementation may overwhelm staff and stakeholders.”

Finally, Reichel stresses the importance of implementing a confidential reporting system or portal. He suspects that small airports may be able to rely on paper forms for this, but larger airports will likely have to tap their IT department or bring in an outside vendor. SMF is currently implementing ProDIGIQ software for its SMS, Part 139 and maintenance work order systems.

What’s Happening in Dallas

The team at DAL started its SMS journey in 2020, which Centeno says has provided the airport a lot of time to think about the process.

With the guidance of Landry Consulting, the airport conducted a safety inventory of existing processes and procedures, and also established a systematic review process and project schedule. The goal was two-fold: to educate the airport team and to ensure it was meeting regulatory requirements.

In 2021, DAL and Landry developed a gap analysis that provided a roadmap for improvements, and created an audit inspection checklist and organizational chart to develop an implementation plan. Meetings with external and internal stakeholders were conducted, and roles and responsibilities of all parties were established. An accountable executive was also identified, as required by the 2023 FAA regulation. Joanne Landry, principal at Landry Consulting, says it’s important to focus on building the compliance pieces like software and processes, but also to keep in mind the end user—the people who will be “living SMS” versus implementing it.

The team began drafting an SMS manual as well as a logo and website to build airport-wide engagement. In 2021, DAL executed an agreement with software developer Veoci to develop a cloud-based system for collecting and managing its SMS data. “We wanted a solution customized to our facility, not a universal software, with reporting features to collect safety information from all users,” Centeno says.

Working together, DAL and Landry developed an SMS plan specific to the airport, which was then digitized into the Veoci system. Landry built a process flow diagram with detailed steps and functional requirements for reporting, analyzing and mitigating hazards. The airport digitized the process map page by page. 

Centeno recommends using a custom system like this but acknowledges that developing one requires more time and resources.

The Aviation Operations Technology Division was responsible for funding, deployment, development and overall project management of the Veoci platform. Project Manager Paul Sullivan notes that his team’s primary mission was to make sure the application modules were rigorously tested against conflicts in process, data and workflows. The result is an operational platform that connects every division to a Part 139 work order and a general work order system.

Scott Rosen, Veoci solutions engineer at the time of the project, notes the Veoci software keeps track of the entire safety reporting process for compliance. “Anything that takes place with a recorded safety hazard or risk is going to be reported through our system,” he says. DAL safety personnel then determine the level of the risk.

Miguel Escalon, quality and safety management systems manager at DAL, explains this data-driven system allows the safety team to analyze information, constantly improve and mitigate situations, and try to minimize risk.

The software keeps track of an entire workflow process from start to finish, Rosen adds. “Anytime some sort of safety risk comes into the system, it follows a series of steps based on the severity of that risk.” Because DAL’s system is integrated with Part 139 operations, any time a hazard is reported, staff can reference the information across the entire system. “It creates a streamlined process of capturing all the information related to a safety event and also enables them to automate more of their solutions,” Rosen says.

“As airports seek new solutions and they need an SMS process in place, our system helps alleviate a lot of those pain points like communication, reporting and effectively knowing where all that data is located,” he adds.

So far this year, DAL has received approval of its implementation plan and is continuing to implement the functions of its SMS manual. “We have done some small pieces, step by step, but it’s a new system and it will require time,” Centeno says.

While the airport has implemented some pieces of its SMS, others are still pending. Escalon notes that DAL is one of the few airports to include occupational safety in its SMS program, applying it to terminal areas and remote buildings. The program also covers Dallas Executive Airport and the elevated Dallas Heliport/Vertiport, which are also operated by the city.

Positive Results

According to FAA, an SMS provides the framework to support a positive safety culture and includes repeatable and systematic processes to proactively manage safety. Furthermore, decision-making processes are structured, consistent, defendable, measurable and data driven. Hazards are identified and safety risk controls are implemented before an accident or incident occurs. Safety assurance processes provide a means for continuous safety oversight, allowing for efficient, smooth and safe airfield operations.

At SMF, the new regulatory requirement is having a positive effect on the safety culture and is encouraging further engagement on the issue. “It increases employee morale and motivation,” Reichel reports. Once employees see that reporting a hazard leads to positive action and makes their job safer, they will be more motivated to report, he explains. “If you’re fixing things, it makes them feel good and gives the SMS credibility.”

The reduction of risks associated with foreign object debris (FOD) had been particularly noticeable. In 2018, the airport averaged 267 pounds of FOD per month. In 2023, with SMS components being implemented, it averaged just 128 pounds per month. “Over the years, we were able to really, really energize our tenants, and we’ve got tons of support now,” Reichel explains. “That’s a big win.”  

Leaders at DAL are similarly optimistic about the effect SMS has had on the airport—especially employee morale and performance. “I see more opportunities because of SMS, and we are excited as a team,” says Centeno. “Everyone wants to be recognized and supports the data-driven system.”

Communication, collaboration and action have allowed employees to see firsthand how an effective SMS can benefit them. “We see a new safety culture starting now,” Centeno reports. Sharing information with internal and external stakeholders is extremely important, he adds.

From a management aspect, Centeno notes that SMS lowers liabilities and costs because the airport is identifying issues before they become hazards. “It’s a big improvement for operations.” 

Collaboration is Critical

Centeno and Reichel recommend participating in industry workshops and working collaboratively with other airports and FAA when developing and implementing an SMS.

Centeno emphasizes the importance of collaboration, even though every airport is unique and faces its own distinct challenges. Airports can learn from one another, but the strategies for internal and external collaboration will differ for each, he explains.

“SMS improves collaboration for identifying and mitigating safety issues,” says Reichel, again noting the need for internal and external collaboration.

For airports unsure where to begin, Reichel says the implementation plan in Advisory Circular 150/5200-37A lays out all the requirements and is a great place to start. “If you follow Appendix C of this AC and build your plans based on it, you’ll have a compliant program,” he assures. Reichel also suggests reaching out to other airports to create networks and learn from their experiences. “I’ve learned a lot from my peers and have been able to incorporate their lessons learned and best practices into our program,” he relates.

Centeno says that DAL has received phenomenal guidance and support from FAA partners and advises other airports to work with their local FAA inspectors. He also suggests reaching out to airport colleagues who have already been through the process.

“Fundamentally, safety improves when airports and airlines work together to resolve safety issues,” adds Landry. “The most effective way I have seen the collaboration work is through safety working groups and committees, recurring meetings, logging and tracking safety issues and creating work groups that assess and resolve the issues together.” Open sharing among airports has been immeasurably beneficial, she adds.

Reichel encourages SMS managers to complete SMS training from sources like AAAE and USC Viterbi. He also recommends The Effective Facilitator by Leadership Strategies to help new SMS managers with formal risk assessments. “[It] gives some valuable insight on how to facilitate a meeting with multiple participants,” he notes.

Training and resources are critical to success, Landry agrees. “Someone doesn’t become an SMS expert overnight. The most effective way we’ve seen is education and skills development through workshops and case studies.”