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Aircraft Parts, aviation, Continued Operational Safety, FAA, FAA Design Approval, FAA Production Approval, Manufacturing, Regulatory, Repair Stations, Safety Management Systems

New Safety Management Systems (SMS) Rule

The new Safety Management Systems (SMS) regulation will be published on Friday April 26. A pre-publication version of the rule is currently available for inspection.

The new regulation will expand the applicability of FAA’s SMS rule to include type certificate (TC) holders and production certificate (PC) holders. It will also expand the scope to include operators who had not previously been included in the rule (such as commercial air tour operators, and commuter and on-demand operators).

The FAA is not yet extending this rule to PMA and TSOA, but in the statement in which the FAA explains that it is not applying SMS to PMA and TSOA, the agency explicitly explains that “FAA agrees with many commenters that other areas of the aerospace system could benefit from SMS.” The FAA justified refraining from extending the rule to PMA and TSOA by explaining that the FAA does not yet have the data to support this extension:

“At this time the FAA does not have sufficient information to support a safety justification for expanding this rule to STC, TSOA, and PMA holders.”

Nonetheless, it appears likely that the FAA will seek this data and return to regulating holders of STC, PMA and TSOA in the future. The FAA also warned that it would consider applying Part 5 to repair stations under its deliberative process. We already know that the FAA and EASA plan to add SMS as a special condition in the Maintenance Annex, and plan to require repair station in the United States with EASA 145 privileges to participate in the FAA’s voluntary SMS program as a condition of retaining their EASA privileges. This chapter of the implementation of SMS in the United States may be closing, but the next chapter is already beginning.

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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