Safety Management Systems (SMS) is being adopted as a standard practice across the manufacturing industry. We will be discussing SMS at the Annual Conference in November. This is a review of the status of SMS regulations for manufacturers in some jurisdictions.
United States
The FAA is expected to take their existing SMS rule (which applies to Part 121 air carriers) and amend it to make it applicable to manufacturers (as well as repair stations and other operators). It will be extended to manufacturers of aircraft, engines and propellers.
The FAA has been promising that they will issue their proposed SMS rule for manufacturers by September 2022; however, the proposed rule is still at the White House Office of Management and Budget (OMB). Currently, the new timetable suggests that the SMS NPRM will likely be issued in December.
The draft proposed rule is likely to exclude PMA and TSOA manufacturers. This is not something that is precisely known; rather it is a prediction based on the material that has already been published on the subject by ICAO and the FAA.
There are both safety and commercial advantages to SMS, so if the FAA rule excludes PMA, then some manufacturers in the PMA community may find that they want to voluntarily adopt SMS. MARPA has committed to support such efforts, and has had discussions with the FAA about how MARPA could facilitate a voluntary SMS program for PMA and/or TSOA manufacturers.
Canada
Transport Canada (TCCA) is pursuing its own rule-making for manufacturers’ SMS and is currently working on wording. A draft regulation may be available by the end of 2022. TCCA is working completion and implementation of a final rule in the 2024-2025 range
European Union
The EU published its SMS regulations and is in the implementation process. Their rules for the manufacturing community include rules for the regulated manufacturers and rules for the regulators. EASA expects regulated manufacturers to have SMS systems by March 7, 2023. EU-regulated manufacturers will have until March 7, 2025 to close out all nonconformities. Thus there is an expectation of full EU manufacturing industry compliance to the SMS requirements by this date.
The EU safety management obligation arises under the production organization approval (POA) rules and the design organization approval (DOA) rules, so it appears to apply to all European Parts Approvals (EPAs) as well as design and production organization approvals for complete products. This is a wider scope than the expected scope of the United States rule.
ICAO
The base standard for SMS was published by ICAO. It currently resides in Annex 19 to the Convention on International Civil Aviation (Chicago Convention). This standard is the basis for internationally-harmonized forms of SMS regulations. ICAO is working on an amendment 2 to the Annex 19, and will be going out for state consultation on this amendment in February 2023.
Opportunities to Get Involved
An international standard for complying with the SMS rules has been published as SM-0001 (rev. B). An international committee is meeting to examine the standard and improve it towards a rev. C release. The international committee has several working groups looking at specific aspects of the standard, including:
- Safety Policy and Objectives
- Safety Risk Management
- Safety Assurance
- Safety Promotion
- Interface Between Organizations
- Maintenance
- SMS Implementation Strategies
- Maturity Assessment and Oversight
If you have an interest in joining one of these working groups, then please let us know, as we could use more PMA representation and participation on the working groups.
In addition, when the FAA NPRM is released, there will be an opportunity to file public comments on the proposed rule. MARPA will be filing comments so please plan on sharing your thoughts with MARPA so we can reflect the industry’s concerns.
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