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FAA, Manufacturing, PMA, Regulatory, Repair Stations, Safety Management Systems

October 21 deadline for SMS Comments is Fast Approaching

Your opportunity to file advance comments on the FAA’s SMS proposal is NOW!  Comments are dues October 21.

An SMS is the formal process of using System Safety practices in an organization’s everyday activities to control risk. Essentially, SMS is like a quality assurance system that uses risk-based analysis to look forward and predict future needs. This allows a company using SMS to commit resources in the present to address future safety needs.

SMS may not be as foreign a concept as it may initially sound. Many MARPA member companies have implemented Continued Operational Safety (COS) programs. COS programs permit safety data collection and risk-based analysis of that data and are viewed as providing the necessary infrastructure to support an SMS program.

A primary focus of this ANPRM is on collecting data about existing SMS programs. MARPA member companies’ data and information about their implementation of Continued Operation Safety (COS) programs is an example of data that would be very useful to the FAA.

MARPA member companies should forward copies of their comments to MARPA headquarters so that we can be sure your comments and concerns are also addressed in MARPA’s own comments.

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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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