FAA began SMS implementation in 2005,  but FAA officials informed ICAO that the agency and industry would not  be able to meet the 2009 deadline. FAA’s Internal Implementation of SMS Continues, While Aviation Industry Segments Are in Various Stages of Voluntary Implementation

		FAA Organizations Continue SMS Implementation

Five FAA organizations are proceeding with SMS implementation. The Air Traffic Organization completed SMS implementation in 2010 and  now uses SMS-based processes to identify hazards, enact mitigations,  and assess the extent to which the mitigations are working. For example, Flight Standards  is developing for an SMS-based oversight system for commercial air  carriers. These three industry segments,  according to FAA officials and industry stakeholders, may be waiting for  additional guidance or rules, which may not be finalized for a number of  years, if the time frames for finalizing the air carrier and airport SMS rules  are any indication. The DOT Significant Rulemaking Report for June  2014 indicated that FAA anticipates publishing the final rule in September  2014. While FAA’s rulemaking to require SMS at all 545 certificated airports has  been delayed, FAA officials estimated that 9 of the nation’s largest  certificated airports were voluntarily implementing SMS as of April 2014. FAA is considering changes in the  proposed rule’s applicability and to some proposed requirements,  including SMS implementation options for various sizes of certificated  airports. FAA and Stakeholders Cited Rulemaking, Data Issues, and Stakeholder Uncertainty as Key Challenges to Implementing SMS

		FAA Cited Challenges in Completing SMS Rulemaking

FAA officials stated that a primary challenge in developing SMS rules for  commercial air carriers and certificated airports is developing the benefit- cost analyses. In 2010, we recommended that FAA develop a  comprehensive plan that addresses how data fits into FAA’s  implementation of a proactive approach to safety oversight. In  addition, we found that uncertainty about the FAA’s final rule  requirements raised some additional concerns with the stakeholders we  interviewed, and half of the stakeholders said that of the four SMS  components, the safety risk management is the most challenging to  implement because of the time and analyses required to identify and  mitigate risks. While  acknowledging that its oversight role will be changing, FAA has not yet  completed plans for overseeing industry’s implementation of SMS,  including plans to develop guidance and train inspectors about their SMS  oversight functions and responsibilities. Nine of the aviation industry  stakeholders and three industry trade groups we interviewed expressed  concerns that FAA inspectors will not be prepared to oversee industry  implementation of SMS. However, even though the publication of the final SMS rule for  air carriers is expected before the end of the year—currently planned for  September 2014—Flight Standards has not yet established guidance for  inspectors for overseeing commercial air carriers’ implementation of SMS  or updated its inspector training program to incorporate such guidance. We found in 2010 that ensuring  consistency in regulatory interpretations has been a long-standing issue  for FAA. Fourteen of the 20  stakeholders told us that identifying and assessing SMS costs was a  challenge. SMS Training for Industry

Although we did not ask specifically about any internal training programs  developed by the 20 aviation stakeholders we spoke with, four  stakeholders cited some difficulties with obtaining needed SMS training  for their staff, including allocating time and resources for the training and  finding training that was specific to their segment of the industry. According to FAA officials, they have considered the training needs of  industry stakeholders and provided some training through the pilot  projects. FAA plans  to disseminate additional SMS guidance for air carriers and airports when  final rules for these industry segments are published. The Airports Organization noted that it continually updates  its SMS website, and Flight Standards indicated that it is allowing its most  significant forum with the aviation industry, InfoShare, to focus more on  SMS implementation and management. Recommendation for Executive Action

To maximize the effectiveness and potential benefits of SMS  implementation, we recommend that the Secretary of Transportation  direct the FAA Administrator to take the following action:
Develop a plan to provide oversight of industry implementation of  SMS, a plan that includes providing guidance and training to the  relevant FAA inspectors by the time final SMS rules for industry  sectors (commercial air carriers, certificated airports, repair stations,  design and manufacturing firms) are published. Agency Comments

We provided DOT with a draft of this report for review and comment. DOT provided technical corrections and clarifications, which we  incorporated as appropriate. Appendix I: Objectives, Scope, and Methodology

Our objective was to review the implementation of safety management  systems (SMS) in the U.S. aviation industry and provide an update on  SMS implementation within the Federal Aviation Administration (FAA). 2. 3. What additional actions do aviation stakeholders believe FAA could  take to improve SMS implementation and potential effectiveness? To assess the status of SMS implementation within FAA and for key  segments of the aviation industry, we reviewed FAA orders and advisory  circulars on SMS and reports on its SMS pilot projects for commercial air  carriers, certificated airports, repair stations, and design and  manufacturing firms and from the SMS rulemaking projects for certificated  airports and commercial air carriers. To determine the key challenges FAA and the aviation industry face in  implementing SMS as well as additional actions FAA and other  stakeholders may take to improve the implementation and potential  effectiveness of SMS, we interviewed officials from FAA, FAA employee,  and industry groups. Aviation Safety: Additional FAA Efforts Could Enhance Safety Risk  Management. Aviation Safety: Enhanced Oversight and Improved Availability of Risk- Based Data Could Further Improve Safety.
Why GAO Did This Study

The U.S. aviation system is one of the safest in the world, reflecting the work of FAA, industry, and others to continually improve safety. To further enhance safety, in 2005, FAA began adopting a proactive, data-driven, risk-based approach to managing safety, referred to as SMS, and has proposed rules that would require SMS implementation for certain segments of the aviation industry.
GAO was asked to review SMS implementation in the aviation industry. This report addresses (1) the status of SMS implementation at FAA and in the aviation industry; (2) key challenges that FAA and industry face in implementing SMS; and (3) actions aviation stakeholders believe FAA could take to improve SMS implementation. GAO reviewed FAA documents and interviewed FAA officials. GAO also interviewed representatives from 20 selected aviation stakeholders, including commercial air carriers, certificated airports, repair stations, and design and manufacturing firms. Because the stakeholders were non-statistically selected based on their size, SMS implementation, and the industry segment represented, their views cannot be generalized to the industry or any industry segment.

What GAO Found

The Federal Aviation Administration's (FAA) Air Traffic Organization completed Safety Management System (SMS) implementation in 2010, and five other FAA organizations are implementing it now. SMS is an approach to collect and analyze safety data to identify hazards, manage risks, and take corrective action before an accident occurs. FAA's implementation activities include developing internal SMS guidance and procedures and using them to, among other things, identify hazards in the aviation system and provide oversight of the aviation industry. For example, FAA's Flight Standards Service is developing an SMS-based oversight system for the commercial air carriers it oversees. Although SMS is not yet required for commercial air carriers, airports, or any other industry segment, some are voluntarily implementing SMS as part of several FAA pilot projects. Of the 83 commercial air carriers, 77 are in the process of implementing SMS. FAA anticipates publishing a final rule in September 2014 requiring commercial air carriers to implement SMS. To a lesser extent, other industry segments are voluntarily implementing SMS. For example, according to FAA, 9 of the nation's largest airports are implementing SMS. FAA issued a proposed rule for airport SMS implementation, but development of a final rule has been delayed, and FAA has not yet determined if it will propose rules for other industry segments. Stakeholders and FAA officials speculated that the other industry segments may be waiting to implement SMS until FAA issues additional guidance or a final rule.
According to FAA officials, completing the rulemaking processes for commercial air carriers and airports has been a primary challenge to industry SMS implementation. Officials stated that one reason for delay has been difficulty in developing the benefit-cost analyses required for significant regulatory action. However, FAA is revisiting these analyses through the ongoing rulemaking process. Uncertainty about FAA plans for SMS oversight was among the key challenges for aviation industry SMS implementation. Although some inspector training has been provided, representatives from 9 of the 20 stakeholders GAO interviewed cited concerns that FAA inspectors may not be adequately trained to oversee industry SMS activities, and 6 expressed concerns that inspectors throughout FAA may not consistently interpret SMS regulations. However, FAA has not completed plans for its SMS oversight activities, including inspector training, and officials stated that they would not do so until the final rule is published. Without adequate planning of oversight and training of inspectors, FAA could find itself unprepared to meet its oversight responsibilities when final SMS rules are published.
Twelve of the 20 aviation stakeholders GAO spoke with identified additional FAA actions that could improve their SMS implementation efforts. For example, 4 stakeholders stated that providing SMS training to their employees was a challenge, and 2 suggested that FAA could assist by providing them access to FAA's SMS training. FAA indicated that it is considering industry stakeholder training needs and provided training through the pilot projects. Fourteen stakeholders were pleased with FAA's collaboration and communication, but 6 of them stated that this effort could be broadened. FAA updates its SMS website information, and FAA's most significant industry SMS forum is focusing more on SMS implementation.

What GAO Recommends

GAO recommends that FAA develop a plan for overseeing industry SMS implementation that includes providing guidance and training for FAA inspectors by the time final rules are published. GAO provided DOT with a draft of this report for comment. DOT provided technical corrections which were incorporated as appropriate.