Aircraft Electronics Association Submits Comments to FAA in Response to ANPR

The Aircraft Electronics Association (AEA) submitted comments to the Federal Aviation Administration last week in response to the FAA's safety management systems proposed rulemaking.

The AEA 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. 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.

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 on 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.

In addition, the agency has not clearly defined the hazard SMS is intended to address, but rather defines SMS to address "unknown" hazards. This mandate is not within the scope of current rulemaking practices. Similar to its current management of manuals and programs repair stations must maintain, the FAA is incapable of estimating any reasonable amount of administrative burden of developing, approving and managing an independent SMS program.

FMI: www.aea.net