Comments Due To FAA October 21st
The FAA is soliciting public comments regarding a potential
rulemaking requiring repair stations, air carriers and
manufacturers to develop and implement safety management systems
According to the FAA, a safety management system is a
structured, risk-based approach to managing safety. The
International Civil Aviation Organization (ICAO) has defined SMS as
a "systematic approach to managing safety, including the necessary
organizational structures, accountabilities, policies and
An SMS would provide a set of decision-making processes and
procedures that AEA members would use to plan, organize, direct and
control their normal, day-to-day business processes.
According to the agency, these FAA-approved decision-making
processes would enhance safety and ensure compliance with
AN SMS requires a proactive approach to discovering and
correcting problems before there are safety consequences. An SMS
also includes processes that seek to identify potential
organizational breakdowns and necessary process improvements,
allowing management to address a safety issue before a noncompliant
or unsafe condition results.
In a news release, The Aircraft Electronics Association (AEA)
says using an SMS is not a substitute for compliance with FAA
regulations or FAA oversight activities.
In the opinion of the AEA, the FAA makes it clear its proposed
rulemaking is a significant administrative and operational burden,
which will not substitute for compliance with FAA regulations or
FAA oversight activities. Therefore, the FAA is proposing a
significant additional burden without any financial, administration
or administrative benefit to AEA members. Clear, concise and
focused answers to the FAA's questions in its advanced notice of
proposed rulemaking (ANPRM) must be generated to ensure this
proposal is not simply an additional burden.
The AEA will be thoroughly reviewing and discussing this ANPRM
during its AEA East and AEA Central regional meetings. Comments are
due Oct. 21, 2009.