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Aircraft Parts, Continued Operational Safety, FAA, Regulatory, Safety Management Systems

Can You Implement a SMS program?

Can you implement a Safety Management System in your facility?

We have been working with the FAA on developing a SMS program that will meet the recommendations of ICAO. This is an issue that could be very important to many manufacturers because if the FAA fails to implement a SMS regulation, then we run the risk that companies may be subject to foreign SMS regulations; whereas if the US implements an CAO-compliance SMS program, then there is a strong arguent to be made by the US that foreign countries should accept US SMS programs as comparable to their own.

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.

The provisions of SMS, as proposed, are similar in many ways to the COS systems that many PMA holders have implemented.

It looks like the FAA is likely to propose a rule that would require certain certificate holders (Part 21, 121, 135, 145) to implement SMS programs. FAA had collected comments from the industry about SMS.  The comments were a mixed bag of positive and negative comments.  There is a possibility that the FAA may propose a rule that simply requires companies to adopt systems that meet the following elements:

1 Safety policy and objectives

1.1 – Management commitment and responsibility
1.2 – Safety accountabilities of managers
1.3 – Appointment of key safety personnel
1.4 – SMS implementation plan
1.5 – Coordination of emergency response planning

1.6 – Documentation

2 Safety risk management

2.1 – Hazard identification processes
2.2 – Risk assessment and mitigation processes

3 Safety assurance

3.1 – Safety performance monitoring and measurement
3.2 – The management of change

3.3 – Continuous improvement of the SMS

4 Safety promotion

4.1 – Training and education
4.2 – Safety communication

What do you think?  Can you implement a program that meets all of these elements?  Let us know, so we can take your comments into account in developing the recommendation that we will provide to the FAA.


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 Air Carrier Purchasing Conference, and the Modification and Replacement Parts Association. He also represents private clients drawn from the spectrum of the aviation industry.



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

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