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aviation, Continued Operational Safety, FAA, FAA Design Approval, Manufacturing, PMA, Regulatory, Repair Stations, Safety Management Systems

Safety Management Systems: Time to Add Your Two Cents!

The FAA has put out a call for comments on the Safety Management Systems rulemaking.  This request was issued in the form of an ANPRM – Advance Notice of Proposed Rule Making – in the Federal Register

MARPA has been working on the SMS project and is represented on the SMS Aviation Rulemaking Committee (ARC).

For those unfamiliar with Safety Management Systems (or “SMS”), we wrote about it in this blog earlier this year, but here is a short summary:

A Safety Management System (SMS) is the formal process of using System Safety practices in an organization’s everyday activities to control risk.  It is like a quality assurance system that uses risk-based analysis to looks forward, predict future needs, and permit a company to commit resources today to address the future safety needs.  SMS is an approach that can be used throughout the aviation industry to meet System Safety standards set by the International Civil Aviation Organization (ICAO).  ICAO has asked states to implement SMS programs and State Safety Programs (State Safety Programs are risk-based analysis programs for national aviation authorities to use to better manage safety with the often-limited resources available to the NAAs).

ICAO has published significant guidance on implementing SMS programs; so much guidance, though, that it must be reduced significantly to a level that will permit the publication of implementing reguations.  In order to help the FAA make sense of what is necessary – and what is not necessary – within a SMS program, the FAA has issued the ANPRM in order to ask for industy’s opinions about some of the core elements of SMS.  A primary focus of this ANPRM is on collecting data about existing SMS programs, but it would also be important for companies to share information about non-SMS programs that meet the same objectives as SMS programs. 

Many MARPA members have implemented Continued Operational Safety (COS) programs that permit safety data collection and risk-based analysis of that data.  COS has always been viewed as providing the infrastructure to support a SMS program – so MARPA member data and information about their implementation of COS programs would be very useful to the FAA. 

MARPA members with comments to share about SMS should also forward copies of their comments to MARPA headquarters so we can be sure that your comments and concerns are also addressed in MARPA’s own comments on the SMS rulemaking project.

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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