AEA Balks At FAA’s SMS Proposal

 - October 28, 2009, 9:40 AM

The Aircraft Electronics Association (AEA) submitted comments to the FAA last week in response to the agency’s safety management systems proposed rulemaking.

According to Richard Peri, AEA’s v-p of government and industry affairs, the association does not support the FAA’s broad-based proposal to mandate an independent safety management system for maintenance organizations.

“The AEA believes the SMS proposal is an excessive, unwarranted and unjustified administrative burden,” he said. “The AEA supports aviation safety, and believes the proposal makes sense for the airlines; however, while the regulations could benefit from some of the elements of SMS, the proposal does not make sense for single-tiered companies.”

The AEA maintains that collecting data on an “unbound concept,” such as safety management systems is unrealistic until the agency further defines the intended scope of the program. “Based on the FAA’s previous history, the administrative burden of maintaining an independent program is indefinable and excessive. An integrated approach to upgrade the current regulations to include the elements of SMS is the only manageable approach.”

The FAA has not clearly defined the hazard SMS is intended to address but rather defines SMS to address “unknown” hazards, according to AEA. “This mandate is not within the scope of current rulemaking practices,” said Peri.

Sarah MacLeod, executive director of the Aeronautical Repair Station Association (ARSA), told AIN, “It is going to be difficult–if not impossible–for both the agency and the industry to define the system in objective terms or criteria that can be audited and enforced by the federal government. ARSA supports AEA’s concern about the impact on small business. The balance would be difficult in the best of times; we are certainly not experiencing those times right now.”

Not everyone is convinced that SMS is problematic. Don Spruston, director general of the International Business Aviation Council (IBAC), said, “Safety management systems have an inherently great safety value. IBAC incorporated SMS into its safety standard [International Standard for Business Aircraft Operations–IS-BAO] many years ago as a core best practice. The concept has been embraced by a large number of operators that have seen the many benefits such as team building. We have now had many years of experience and the concept has proved itself, although [it is} not always easy to implement.”

Spruston said that in his experience many good operators have found it easy to implement such a system as they already had most elements in place and it was only a matter of ensuring the processes are documented for all in the flight department to see. “SMS is the code of best practices for both operations and maintenance, as well as all other elements of the flight department,” he told AIN. “These good practices are now being recognized around the world by safety regulators and the initiative is being pushed by ICAO. While SMS is a good concept it will not work as intended unless it is seen as a good practice and not something ‘shoved down our throats’ as one operator recently complained to me.”