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FAA, Manufacturing, Policy, Safety Management Systems

FAA Begins SMS Manufacturing Pilot Project

The FAA provided us with a briefing on the current status of the Manufacturing SMS Pilot Project, which is now starting.

The Manufacturing SMS Pilot Project will run for up to 24 months.  It is designed to support the FAA’s ability to respond to the ICAO 2013 deadline for implementing SMS rules for manufacturers. The pilot project involves production approval holders (including at least two PMA holders) working with the FAA on developing SMS programs according to the rough guidelines developed by the FAA for purposes of the pilot project.

During this period, one of the objectives of the Manufacturing SMS Pilot Project is to determine if a regulation is needed, and if it is needed then to determine to whom it should be applicable.  In going through the process, FAA hopes to identify lessons learned in order to be able to support a final project.  Another important goal of the pilot project will be to develop FAA assessment and oversight methodologies.

The Aircraft Certification Office and the Windsor Locks MIDO are actively involved in the Pratt & Whitney SMS pilot project.  FAA is finding that the FAA employees “are all over the map with respect to SMS knowledge.”  So the FAA is hoping to gain knowledge and understanding about how the FAA would need to train their own workforce in a large-scale implementation of SMS.

The FAA Manufacturing SMS Pilot Project is the first manufacturing pilot project in the world.  Transport Canada has had discussions with its manufacturers about their voluntary implementations, but has not undertaken a formal pilot project.

The first company to participate in the pilot project is Pratt & Whitney.  Pratt just completed their initial briefings with the FAA in January.

FAA will publish outreach materials including “lessons learned” online, so that the public can follow the developments and comment on them.

http://www.faa.gov/about/initiatives/sms/pilot_projects/guidance

The FAA remains on a continuing resolution for funding purposes, and current budget cut expectations would require FAA cuts.  Administrator Babbitt has committed to SMS as a FAA priority, so it will probably not get eliminated, but everyone knows that the FAA is going to have to do some cutting and the scope of the pilot project could be cut (e.g. from 10-12 participants down to 5-6 participants).

About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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