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aviation, Continued Operational Safety, EASA, Manufacturing, Repair Stations, Safety Management Systems

EASA Begins the Process of Implementing SMS Rules

The European Aviation Safety Agency (EASA) has formally begun the process of implementing Safety Management System (SMS) regulations.

EASA issued the Terms of Reference (TOR) for task number MDM.055 on July 18, 2011.  This task anticipates the creation of adequate rules and guidance material to permit EASA to implement a set of SMS rules.

The Terms of Reference do not specifically explain to whom the SMS rules created under this project would apply – they merely mention some of the parties to whom ICAO has recommended apply it.  This is a more important omission than some people may understand, and it provides EASA with the ability to dynamically change the scope of application as necessary during the course of the rulemaking project without amending the TOR.  Under current ICAO recommendations, SMS should apply to air carriers, repair stations, manufacturers and airports.  In the United States, the FAA made the decision to create two different SMS rules – one for airports, and then a second one for air carriers that is intended to be later applied to repair stations and manufacturers.  EASA has said that it is amending COMMISSION REGULATION (EC) No 2042/2003 of 20 November 2003. This regulation applies to design and production organizations as well as maintenance organizations (but not to air carriers). EASA is clearly leaving itself open to any reasonable implementation strategy.

EASA has established its own goals for the task group, as follows:

  • Review the rules and AMC to clearly distinguish between essential safety elements and non-essential implementation aspects; rebalance as necessary (implementing rule to AMC or AMC to implementing rule).
  • Adopt the provisions on processing alternative means of compliance, as proposed with Part-AR and Part-OR (AR.120/OR.120), to enhance transparency and support standardisation.
  • Evaluate the possibility for persons to apply for the approval of such alternative means of compliance, where this is currently not foreseen in Part-AR.
  • Implement in Section A the management system provisions as proposed with Part-OR to ensure compliance with the relevant ICAO standards on SMS. SMS elements shall be fully integrated with the organisations’ management system.
  • As part of SMS implementation review and further develop as appropriate provisions addressing human factors, in particular to provide further guidance on how approved maintenance organisations should take into account human performance limitations, such as maintenance engineer fatigue5.
  • Improve consistency in organisation approvals and review the concept of small/large organisation to align with the approach proposed with Part-OR (complex/non-complex organisation, where size is not the only criterion to be considered).
  • Implement in Section B relevant provisions linked with the implementation of an SSP in the framework of the European Aviation Safety Programme (EASP), based on the proposal made with Part-AR.

This SMS project will be worked internally within EASA, although EASA has reserved to itself the right to call informal meetings with industry or National Aviation Authorities for additional feedback.  This internal project mechanism is consistent with the process recently used by Japan to create its SMS rules for repair stations (they offered the proposed rules for notice and comment but did not otherwise seek input from the international community).  It is different from the FAA’s approach in the United States … the FAA formed an Aviation Rulemaking Committee (ARC) made up of industry and FAA and took advice from the ARC on how to formulate the air carrier SMS rules.

EASA has a very aggressive timetable set for the SMS project.  They expect to issue a Notice of Proposed Amendment (NPA) to seek public comment in the second quarter of 2012.


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.


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