SMS required for operations into Bermuda?

[BoilerUP]

Boilerup is right!!

I was being sarcastic.

A competent, professional flight crew doesn't need an SMS to tell them how operate the aircraft in a safe manner, or how to mitigate operational risk, or that they should utilize industry best practices...because there's nothing on a "risk matrix" that a competent, professional flight crew hasn't already considered.

A cottage industry has sprung up around these SMS mandates to get operators in "compliance" for a fee, except that nobody (not even the "experts") can tell you exactly what the criteria are for compliance other than "If you're ISBAO, you're good."

That's unacceptable to me and it should be to pretty much everybody else.

I buy into the concept of SMS, but thus far its implementation and execution (especially for a small, one or two plane, two-four pilot operation), not to mention regulatory guidance, has been terrible.

 

[bbwest]

In that case I disagree with Boilerup. The one and two plane operations are exactly the ones that need guidance and oversight.

Too many in this business think they are smarter than the rules, they have 15k hours and dont need that or this. I submit the following trend - the professionals in this business are always listening, reading, open to doing things the best way; the others- the know it alls, who are usually more screwed up than Hogans goat, are the guys who are most resistant and are the guys who need it the most.

Why do ALL 121 operators have Safety programs? Why do ALL 135 operators have safety programs? So we in the 91 world are smarter and better than them? They need it and we don't?

Pure dillusion if you believe that.

 

[BoilerUP]

The one and two plane operations are exactly the ones that need guidance and oversight.

Guidance and oversight? Really? Guidance and oversight by whom?

I submit the following trend - the professionals in this business are always listening, reading, open to doing things the best way

I agree with that 100%...I just don't think I, or any other true aviation professional, needs a manual in a 2" binder and a per-leg risk matrix to tell us how to do those things - we've already been doing them.

Why do ALL 121 operators have Safety programs? Why do ALL 135 operators have safety programs?

Because they are air carriers, who extend themselves to the public for common carriage. As such, they have safety programs because they HAVE to per FAR in the interest of the flying public who could be put at risk by an air carrier who might place revenue ahead of safety.

My airplane isn't public.

That same argument could be made to why 91 passengers aren't screened against the No Fly List or have their luggage x-rayed. And such an argument would contain the same logical fallacies.

So we in the 91 world are smarter and better than them? They need it and we don't?

Look, I'm not saying that Part 91 operators couldn't benefit from a safety program, and I'm certainly not saying we're "smarter" or "better" than 121/135 operations. What I am saying is our operations are different than theirs, and boilerplate solutions from air carriers simply don't work for private operators. A truly effective SMS requires everybody, from the lowest person in the department to whomever the department reports to in the management structure, to buy into its concept and application. In the airline world, its easy - you fly for us you do what we say. In the 91 world, where airplanes aren't in management's core competency and its a tool instead of a revenue-generating device, and management isn't going to support something that costs them money with no tangible increase in safety (because again, a professional crew already does that which most SMS programs call for, in the span of about 30 seconds without needlessly killing any trees).

The FAA still has not issued any guidance telling Part 91 operators what their criteria for "compliance" is, and because of this, nobody knows what must be included for a program to be "APPROVED".

Why waste time and money, propping up the cottage industry of consultants & auditors that has sprung up the last couple years following the ICAO mandate, when the FAA hasn't yet required it or told us what it will need to include?