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ICAO Safety Management System (SMS) Compliance Options

By Harry Driscoll
updated 01/29/2023 01:23 AM ET

It must be noted that for Private (non-commercial) Jet Operators i.e. Part 91 (US); Annex 6 Part II has NO provision for audits or approval by the state's regulator (i.e. FAA).

What it does say is that OPERATORS shall... have an Operations Manual incorporating some 18+ items including an SMS program.

The SMS program is described in ICAO Annex 6 Part II section 3 and clearly places the onus on the operator to develop the SMS and specifies certain minimum content.

Countries who acknowledge the pertinent ICAO SARPS, will base any ramp checks on the ICAO standards. Some countries may consider an IS-BAO registered operator as compliant; however, IS-BAO is NOT the only means of compliance. The real test will be adherence to ICAO SARPS- Annex 6 Part II.

In the case of Commercial Jet Operators (i.e. Part 135 US); Annex 6 Part II does not apply. Commercial Operators are bound under Annex 6 Part I where the rules for SMS are quite different. Annex 6 Part I places the State (i.e. US FAA) with responsibility for making specific regulations for the Commercial Operators to adhere to when developing their program.

These regulations will include acceptance and oversight by the FAA and inspectors assigned to the certificate holder. (The US is getting close to enacting FAR 121 regulations. An ANPRM was issued last year and subsequently, a NPRM was issued and recently the comment period was extended.)

Hope this offers some clarification and reduces misunderstanding.

Harry Driscoll & Associates have successfully achieved compliance for owners of: Gulfstreams, Global Express, Challengers, Learjets, Falcons, Hawkers Citations and others.

They now offer the ICAO Annex 6 Part II SMS compliance programs using either the ICAO Standard or the IS-BAO Standard as preferred by the operator.

Send questions or comments to compliance@harrydriscoll.com.

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