a requirement to implement SMS in three of FAA’s business lines—the  Air Traffic Organization (ATO), the Aviation Safety Organization (AVS),  and the Office of Airports (ARP)—and a goal to implement SMS policy in  all appropriate FAA organizations, which include the Office of Commercial  Space Transportation (AST) and the Office of NextGen (ANG). FAA and Its Business Lines Are at Different Stages of SMS Implementation

ATO completed its implementation of SMS, but FAA and several of its  other business lines and offices are in the early stages of implementation. Most FAA business lines and offices have guidance and plans for SMS  implementation in place and have begun to integrate SMS-related  practices into their operations, but many tasks remain and aviation  officials and experts with whom we spoke project that full SMS  implementation will take many years. FAA Recently Finalized Its Agency-Wide Implementation Plan, but Full SMS Implementation Is Likely to Take Many Years

FAA finalized its agency-wide plan for SMS implementation in April 2012. FAA’s SMS Approach Is Consistent with Many but Not All Key Practices for Successful Project Implementation

There are a number of key practices and implementation steps that can  help agencies successfully plan for and implement new projects, including  large scale transformative ones, such as FAA’s implementation of SMS. FAA  currently has many of these key factors in place, such as established  support from top leadership and a clear project mission; however, it has  only partially addressed other key practices, such as providing needed  expertise and technology, and has yet to establish SMS performance  measures (see fig. However, we identified six challenges that could negatively affect FAA’s  efforts to implement SMS in a timely and efficient manner:   1)  the large scope and complexity of SMS implementation,   2)  resource and capacity constraints,   3)  standardization of policies and processes,   4)  data sharing and protection,  5)  data quality and usefulness, and   6)  development of performance measures to evaluate SMS  effectiveness. Resources and Capacity

SMS implementation across FAA will require some skills that agency  employees currently do not have, yet FAA has not formally assessed the  skills of its workforce to identify any gaps in the expertise required to  implement SMS or determined how to fill those gaps. FAA officials acknowledged that this is  a challenge for the agency and noted that the agency plans to provide  additional training to inspectors related to oversight of SMS. Although FAA has some data  protections in place, such as those established by the FAA Modernization  and Reform Act of 2012, which protects data that airports and air carriers  submit to FAA for SMS from federal Freedom of Information Act (FOIA)  requests, any data airports collect and any data air carriers share with  airports could be subject to state-specific FOIA laws. The magnitude of  SMS’s potential impact on aviation oversight and the complexity of  implementation are both a benefit and a drawback for FAA, as SMS  implementation could help ensure the continued safety of the U.S.  aviation system, but could also affect implementation time frames for  other large initiatives as the agency works in a resource-limited  environment. To align strategic goals with employee efforts, develop a system to  evaluate employees’ performance as it relates to SMS. Appendix I: Objectives, Scope, and Methodology

Our objective was to assess the Federal Aviation Administration’s (FAA)  implementation of Safety Management Systems (SMS) and provide  information on potential implementation challenges. (2)  To what extent have FAA’s SMS efforts been consistent with key  practices for successful planning and implementation of a new  program? (3)  What challenges does FAA face in implementing SMS? We reviewed prior GAO work on performance  measurement and workforce analysis, Department of Transportation  Inspector General reports and NTSB recommendations related to SMS.
Why GAO Did This Study

The nation's aviation system is one of the safest in the world, but with air travel projected to increase over the next 20 years, efforts to ensure the continued safety of aviation are increasingly important. The FAA is seeking to further enhance safety by shifting to a data-driven, risk-based safety oversight approach--referred to as SMS. SMS implementation is required for FAA and several of its business lines and the agency is taking steps to require industry implementation.
As requested, this report addresses (1) the status of FAA's implementation of SMS, (2) the extent to which FAA's SMS efforts have been consistent with key practices for successful planning and implementation of a new program, and (3) challenges FAA faces in implementing SMS. To address these issues, GAO reviewed FAA SMS documents, compared FAA efforts to key practices, and interviewed agency and industry officials.

What GAO Found

The Federal Aviation Administration (FAA) and its business lines and offices are in different stages of their implementation of Safety Management Systems (SMS). FAA finalized its agency-wide implementation plan in April 2012, and the Air Traffic Organization (ATO) has completed its SMS implementation, but other FAA SMS efforts are in the early stages. FAA business lines, such as the Aviation Safety Organization (AVS) and the Office of Airports (ARP), have SMS guidance and plans largely in place and have begun to integrate related practices into their operations, but many implementation tasks remain incomplete, and officials and experts project that full SMS implementation could take many years.
There are a number of key practices that can help agencies plan for and efficiently implement new projects, including large scale transformations such as FAA's SMS implementation, and FAA has many in place. For example, FAA has support from top leadership and a clear project mission. However, FAA has only partially addressed other key practices such as developing a project plan to track SMS implementation, and FAA has not addressed performance-related practices such as establishing SMS performance measures or links between employees' performance standards and SMS.
Several challenges remain that may affect FAA's ability to effectively implement SMS. FAA is taking steps to address some challenges and stakeholder concerns, but challenges related to data sharing and data quality; capacity to conduct SMS-based analyses and oversight; and standardization of policies and procedures could negatively affect FAA's efforts to implement SMS in a timely and efficient manner. Further, FAA officials stated that SMS implementation will require some skills that agency employees do not have, but FAA has not yet assessed the skills of its workforce to identify specific gaps in employee expertise. In addition, while existing federal law protects any data collected for SMS, any data airports collect could be subject to state-specific Freedom of Information Act laws, a gap that could create a disincentive for airports to fully participate in SMS implementation.

What GAO Recommends

GAO recommends that FAA develop systems to: track SMS implementation, evaluate employee performance as it relates to SMS, and assess whether SMS meets its goals and objectives; conduct a workforce analysis for SMS; and consider strategies to address airports' data concerns. The Department of Transportation agreed to consider the recommendations and provided clarifying information about SMS, which GAO incorporated.