Who does AC 120-92A apply to, and is it mandatory?
Changes to AC 120-92A
With the recent release of AC 120-92A, the FAA has made significant design and alignment modifications that describe safety management according to the structure established by ICAO. Although the content of the new circular remains largely intact from its predecessor (AC 120-92), the approach has improved significantly. The most notable difference from the old advisory circular to the revised version is its:
- Clear definition of Safety Management
- SMS implementation expectations
- SMS performance objectives
- SMS design objectives
Is a Safety Management System Mandatory?
Of course the fact that it is an Advisory Circular indicates its voluntary posture, but its application is clearly spelled out. Stating its applicability to aviation service providers, both certificated and non-certificated operators, the new circular goes on to clarify that safety management applies to all organizations that are exposed to risk such as:
- Air carriers
- Maintenance repair organizations
- Air taxi operators
- Single pilot operators
- Corporate flight departments
- Repair stations
- Pilot schools
- Approved training organizations
Regarding CFR regulation, the message is also very clear: AC 120-92A is not mandatory and does not constitute a regulation. Development and implementation of an SMS is voluntary.
One Size Does Not Fit All
Maintaining a theme of flexibility for safety system design, the circular “stresses what the organization must do to implement a robust SMS rather than how it will be accomplished.” The previously described application across all aviation service providers demands a system containing inherent scalability; the single business jet owner/operator, large corporation flight department, charter operator, and EMS provider must all find commonality and consistent applicability in their safety management system (SMS) design. Each aviation service provider’s business characteristics are unique, so for an SMS to add value it must be developed with that distinctiveness in mind. By creating a detailed process focused blueprint in AC 120-92A, flexibility is inherent. Although each SMS requires nuance, it must also be harmonized with existing standards and designs. This is especially critical when considering the importance of international recognition. Safety management has moved forward rapidly in other nation’s aviation authorities, and of course the ICAO Annex 6 has placed a requirement upon member states to regulate SMS. In order to meet those international expectations, AC 120-92A is completely aligned, in concept and format, with the four component/twelve element SMS framework promoted by ICAO. The framework presented in the circular provides functional objectives and expectations for each component and element, setting in place standardization for regulators, and internal and external auditors.
Building a Safety Culture
Keep in mind, SMS design and function can be effective without being overly complex. For the smallest operations, a paper system or log file that tracks safety information may prove effective. Regardless of the operations size, accomplishing safety objectives does require that an organization:
- Conduct internal audits
- Continuously monitor risk and safety issues
- Review documents
- Perform safety risk analysis and assessments
- Review training
Of course, no safety effort will be successful without the commitment and dedication management’s “personal and material involvement in quality and safety activities.” Combining this management commitment with a way for employees to transfer knowledge, via timely report submission, of safety deficiencies forms the cornerstone of safety communication. If employees, without fear of reprisal, can report hazards, issues and concerns, as well as occurrences, incidents, etc., and propose safety solutions and improvements, then effective risk management is possible. Weaving these communications into the described processes contained in AC-120-92A will help organize the corrective actions and risk controls essential to every operation’s safety management.
Written By: Steve Witowski
PRISM Director of Safety Systems
August 24, 2010