European SMS Requirements for Repair Stations; Could Indirectly Affect Distributors

According to EASA sources, Safety Management Systems (SMS) requirements should be published as a part of the EASA repair station regulations before the end of the year. The part 145 SMS requirements will likely be published by the European Commission this calendar year, with associated AMCs and GMs coming from EASA. 

The EASA SMS rule for repair stations is expected to be applicable 20 days after the publication date (that’s when compliance is permitted).  Compliance with the EASA SMS rule is expected to be required one year later (385 days after the publication date).  The initial one-year period will be for initial implementing of SMS programs.

After initial implementation, the applicable authorities will audit and provide feedback to help get repair stations into full compliance. Each EASA Part 145 organization will have a two-year period for implementing missing elements with the help of the authorities (e.g. for implementing corrective action in response to authority findings). 

This is a new program so we expect that there will be findings issued against the implementers by the authorities.  The two-year transition period is meant to be a period during which all of the authority findings should be closed.

This should not have an immediate effect on US-based EASA 145 organizations because of the way that the US-EU maintenance agreement (and guidance) is structured; but the essence of that agreement is that both regulatory systems are substantially similar, so the addition of SMS to the EU system opens the door to further negotiations. This is somewhat mitigated by the fact that the United States plans to issue an SMS Notice of Proposed Rulemaking (NPRM) for repair station SMS in September 2022.

By the end of 2024, the European Community expects that all EASA Part 145 organizations should be in full compliance with SMS.

SMS requires communications with business partners, so distributors, and others, who do business with European repair stations should not be surprised if they start seeing communications seeking hazard data, and asking about mitigation strategies for known (or recently discovered) hazards. ASA has already provided SMS training for the community, and will be providing more. ASA plans to provide more SMS-related resources for its members to support their smooth coordination with customers’ SMS programs.