Japan’s Ministry of Land, Infrastructure, Transport and Tourism (MLIT), which is the parent ministry of the Japanese Civil Aviation Bureau (JCAB), is soliciting public comment on forthcoming Japanese rules concerning Safety Management Systems (SMS). These rules would affect companies that manufacture, maintain or modify civil aircraft and aircraft parts.
MLIT intends to impose SMS requirements on MRO companies by April 1, 2011. SMS requirements would be imposed on manufacturers by November 14, 2011.
It is presently unknown how these rules would affect non-Japanese companies, but it is possible that Japan could forbid the import of parts made or maintained by companies that do not meet the Japanese SMS requirements. Under normal international standards, this requirement would be waived if the home country of the exporter (1) has published comparable SMS regulations and (2) has signed a bilateral agreement with Japan in which Japan recognizes the SMS regulatory structure of the exporting nation as being comparable to the system implemented in Japan.
We obtained a loosely-translated copy of the Japanese rulemaking publication, and it is available on our website. Interested companies are urged to submit comments to MLIT no later than the deadline of October 4, 2010. MLIT prefers to receive comments in Japanese (sorry—neither MARPA nor the Department of Commerce can recommend a Japanese translation service).
Meanwhile, Back in the ‘States
In the United States, the FAA plans to establish a Safety Management Systems (SMS) pilot program, in which manufacturers will work with the FAA to develop SMS programs, and the FAA assess what works and what does not work in such a program. The lessons learned from this effort will help influence the SMS rule that will be published by the FAA.
MARPA members who would like to participate in the FAA’s SMS pilot program should contact MARPA immediately.