Safety Management Systems work on the premise that the organizations that design, build, maintain and operate an aircraft are responsible for its safety. Regulators write and enforce laws and designate themselves as responsible for aviation safety. These two models are then at odds with regulators producing more regulations and oversight to improve safety and operators and manufactures taking responsibility to implement proactive safety.
In general, safety managers are lower on the corporate ladder than department heads, who may resist changes in implementation due to being accustomed to older systems. There tends to be an adversarial culture between regulators and manufacturers, a culture perpetuated by both sides. Clear responsibilities, new infrastructure, and trust among parties are crucial for the successful implementation of Safety Management Systems. This issue is present in multiple industries, including aviation.
In the event there is a discrepancy in corrective actions issued by a manufacturer and the regulator, the regulator will consider this a noncompliance. Therefore, the safest course of action for an operator is waiting for the Airworthiness Directive and complying, rather than taking the risk of implementing the Manufacturers Service Bulletin that may not be exactly the same as the AD with certain authorities. However, this can lead to an overdependence on safety management systems and regulations for decision-making, slowing response times.
- Delays in implementing needed safety enhancements and/or mitigations indicated by in-service data trends due to fear of non-compliance with regulations and the resulting financial penalties.
- The reluctance by organizations to share data in a common platform is a major impediment in the implementation of SMS.
- Operators may ignore Service Bulletins from manufacturers unless backed by a requirement from the authority. Service Bulletins are often modified multiple times prior to the release of an Airworthiness Directive resulting in delays compromising safety.