Today, with SMS mandates on the horizon for part 135 operators, 14 CFR § 91.147 operators, and certain part 21 certificate holders, many people still think their SMS needs to be developed internally. So they spend 3 days attending an expensive class, study the 148-page Advisory Circular AC 120-92D, perform a ‘gap analysis’, and come home with an SMS Manual that can be ‘paired with any software’ – perhaps, but not without significantly more work. The real surprise comes when FAA shows up with their SMS data collection tools (DCTs) and operators discover that while they may comply with Part 5, they are far from conforming with the SMS design validation DCTs that FAA uses to check for seven essential safety attributes.
