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A Possible Look for SMS Regulations

The FAA-Industry Aviation Rulemaking Committee (ARC) for Safety Management Systems (SMS) meets this week in Dallas.  The purpose of the meeting is to consolidate three reports into a single industry recommendation concerning SMS.

The three reports come from three working groups: design and manufacturing, maintenance, and operators.  While in Dallas, the Aviation Rulemaking Committee will examine these reports and vote on final recommendations to the FAA with respect to a Safety Management Systems regulation.

Safety Management Systems (or SMS) is an ICAO ‘mandate’ and is something that the civil aviation authorities of the world have been directed to incorporate into their regulations.  In the United States, it is appearing that we must adopt some sort of SMS regulation in order to avoid being hit with multiple inconsistent SMS standards from each of our foreign trading partners (which could impede our ability to sell aircraft parts outside the United States).

As ICAO envisions it, SMS would be imposed on repair stations, air carriers and manufacturers.

One element of the proposals is draft language to implement the ICAO recommendation in the US regulations. Here is one way that the regulations could look, if implemented by the FAA according to one recommendation:

Title 14
Chapter 1
Subchapter L [new]
Part 195

195.1 Safety Management System

(a) This Part applies to any person that is required, under this Chapter, to have a safety management system.
(b) The procedures described in this Part shall be known, collectively, as a safety management system.
(c) A person required by this Chapter to have a safety management system may incorporate some, none or all of its procedures in any other manual or collection of procedures maintained by the person.
(d) Where the procedures required under this part are substantially similar to procedures required by other regulations, a single procedure may meet the requirements of two or more requirements.
(e) The procedures required by this part will reflect the size, culture, special operating requirements and business practices of the party implementing the safety management system, and therefore may differ among similarly situated persons based on the differing practices of each person.

195.3 Definitions

(a) Regulated Party, for purposes of this Part, means a person who is required by this Chapter to have a safety management system.

195.5 Safety Policy

The Regulated Party shall have the following Safety Policy data and procedures:

(a) An internal procedures for reporting safety issues;
(b) A procedure for periodic review of the safety policy and objectives, to ensure that they remain relevant and appropriate to the organization
(c) An organizational chart that identifies, the title, duties and responsibilities of

(1) the Accountable Manager who is responsible for the implementation and maintenance of the SMS;
(2) each management person who has authority to make decisions regarding safety risk tolerability;
(3) each management person who is accountable for implementing safety policy
(4) each management person who is accountable for ensuring that safety policy is implemented

(d) A procedure for appointing the Accountable Manager;
(e) Where emergency response procedures are necessary, procedures for

(1) transitioning from normal to emergency operations, and returning to normal operations,;
(2) coordination of emergency response planning;

(f) A description of the safety policy, safety objectives, safety performance indicators and safety performance targets of the Regulated Party;

195.7. Safety risk management

The Regulated Party shall have the following Safety Risk Management
procedures:

(a) A procedure for collecting safety data and identifying aviation safety hazards associated with the Regulated Party’s operations
(b) A procedure for reviewing aviation safety hazards associated with the Regulated Party’s operations and identifying appropriate controls of the aviation safety risks posed by each aviation safety hazard.

195.9 Safety assurance

The Regulated Party shall have the following Safety Assurance procedures:

(a) A procedure for verifying the safety performance of the organization and validating the effectiveness of the safety risk controls in reference to the safety performance indicators and safety performance targets of the Safety Policy.
(b) A procedure for managing change within the organization to assure that change does not adversely affect safety performance
(c) A procedure for using safety data to improve the Regulated Party’s Safety Management System

195.11 Safety promotion

The Regulated Party shall have the following Safety Promotion procedures:

(a) A procedure for training the Regulated Party’s safety-related personnel to assure that they are competent to perform their SMS duties.
(b) A procedure for safety communication that ensures

(1) that all safety-related personnel are fully aware of the Regulated Party’s safety management system, and
(2) that the Regulated Party’s safety information is conveyed to appropriate personnel.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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  1. Pingback: Your Input Needed: How Can the FAA Manufacturing Regulations Better Protect Safety? « MARPA - December 18, 2012

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