DOT Expands SMS to Include Hazmat Safety

April 11, 2024 by Leave a comment

A new regulation has included hazmat safety within the scope of provisions expected to be addressed in an air carrier’s SMS. This could be the first step in a steady expansion of the scope of the FAA’s SMS regulation.

The FAA’s SMS regulation applies to operators and it was originally published to help them manage aviation safety issues. The SMS regulation is found in the FAA’s Part 5 regulations.

The FAA pledged to limit their oversight of SMS to only aviation safety issues under the FAA’s own regulations. If an air carrier chooses to extend their SMS to a safety issue that is not an aviation safety related activity, then the FAA would only conduct oversight of the SMS activities related to the carrier’s aviation operations conducted in accordance with the provisions of part 121. See Safety Management Systems for Domestic, Flag, and Supplemental Operations Certificate Holders, 80 FR 1307, 1311-12 (Jan. 8, 2015). In this pledge, the FAA offered examples such as security and occupational safety and health issues. Id.

There is good reason to limit the scope of the SMS. Air carrier resources are not unlimited, and in order to make SMS useful, there has to be a clear scope to the SMS, so the air carrier is not diverting safety resources to projects that do not add aviation safety value, because those projects had been identified within the “scope” of the SMS.

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has a regulation that prescribes the requirements that apply to the transportation of hazmat aboard aircraft (49 C.F.R. 175.1 et seq.). PHMSA has just added text to that regulation that says:

“(e) In addition to the requirements of this part, air carriers that are certificate holders authorized to conduct operations in accordance with 14 CFR part 121 are also required to have a Safety Management System that meets the conditions of 14 CFR part 5 and is acceptable to the Federal Aviation Administration (FAA) Administrator.”

Hazardous Materials: Harmonization With International Standards, 89 FR 25434, 25488 (April 10, 2024)

For clarity, the PHMSA explained that their intent in adding this regulatory language was to ensure that this added reference would cause air carriers to add hazmat safety to their SMS focus.

“PHMSA expects that adding a reference to these requirements in the HMR will provide additional clarity for Part 121 aircraft operators, particularly with SMS applicability to the acceptance and transport of hazardous materials at the aircraft level”

Hazardous Materials: Harmonization With International Standards, 89 FR 25434, 25459 (April 10, 2024)

To be clear, Part 121 does require hazmat training, but the direct regulation of hazmat carriage is covered outside of Part 121 (in Title 49). So this is an expansion of the stated scope of SMS for air carriers. If the U.S. Department of Transportation can expand the scope once, then they can do it again.

This is a particular concern when you consider that the FAA is working on finalizing a proposed rule that will expand SMS to other parties in the aviation industry. What other foci will be added to SMS? Could the Department of Labor add OSHA to SMS Part 5, even though OSHA rules were originally intended to be excluded from Part 5?

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FAA Publishes SMS Rule for Manufacturers and an Expanded List of Operators

January 10, 2023 by Leave a comment

Distributors may soon see some changes in their aviation manufacturers as well as their operator-customers, as the FAA will publish its Safety Management Systems (“SMS”) Notice of Proposed Rulemaking (“NPRM”) in tomorrow’s Federal Register.

This long-awaited proposed rule has been scaled back from the original scope (manufactures and maintenance organizations) and only appears to apply to:

  • Passenger-carrying operations (including those under 14 C.F.R. § 91.147, Part 121 and Part 135)
  • Type Certificate (TC) holders whose TCs are under production
  • Production Certificate holders

There will be an exception for production certificates that are based purely on a supplemental type certificate (STC), and not on any type certificate.

The proposal would also make many small changes to the existing Part 5 (SMS) standards.

The NPRM is published pursant to the Congressionally-mandated obligation for aviation manufacturers to establish SMS programs (Public Law 116-260 (Dec. 27, 2020)). That law required application of SMS requirements to “manufacturers that hold both a type certificate and a production certificate issued pursuant to section 44704 of title 49, United States Code, where the United States is the State of Design and State of Manufacture.” Id. at § 102(a)(1). So it applies to those who produce aircraft, engines and propellers, but on its face it does not apply to those who produce aircraft parts (which are typically produced under PMA or TSOA). Because it also applies to operators, ASA members may eventually feel that they are squeezed between two sets of business partners who are under SMS regulations.

The proposed rule would require SMS-holders to share hazard information with the relevant interfacing entities who, to the best of their knowledge, could address the hazard. An example in the NPRM has an aircraft manufacturer disseminating hazard information to its parts suppliers and software suppliers. Distributors should be wary of this provision, as it could ultimately mean that distributors may face a flow-down of SMS requirement from their business partners.

Because we anticipate such SMS-related commercial pressures on our members, as well as anticipating members who may want to voluntarily adopt SMS, ASA continues to monitor implementation of SMS programs around the world.

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SMS Rumors – SMS For Part 145 May Meet Obstacles

December 9, 2022 by Leave a comment

The aviation industry has anxiously awaited the FAA’s Safety Management Systems (SMS) rulemaking. The Notice of Proposed Rulemaking (NPRM) had been scheduled for September, 2022, and was then delayed until December of this year. It appears that the proposed SMS rule may have hit another snag.

Industry rumors are suggesting that the SMS rule may have been inadequate to meet the requirements reviewed by the White House Office of Information and Regulatory Affairs (OIRA). This is based in part on an industry critique that was filed with OIRA; the critique accused the rule of offering inadequate options to small businesses.

If these rumors are true, then it is likely that the SMS rule could be cleaved in half – with the manufacturing portion going forward (but only applying to large manufacturers) and the repair station half being held back.

Regulatory historians will recall that in 1999, the FAA proposed to add quality assurance system requirements to repair stations. That rule was scaled back to just a quality manual. The present SMS proposal for repair stations appears to suffer from some of the same issues that impacted the quality assurance systems rule about twenty years ago. The easiest way for the FAA to deal with this would be to simply go forward with the manufacturing SMS rule but remove the repair station SMS requirements until the FAA could rethink the technical evaluation.

This does not mean that SMS won’t apply to repair stations. EASA has already passed an SMS requirement (EU repair stations entered the two-year implementation period a week ago) and there are air carriers who are talking about flowing down their SMS requirements to their maintenance providers. ASA members with repair station certificates will still need to pay careful attention to their SMS obligations. But those same companies may find that they have more options to meet customer SMS requirements, including voluntary SMS programs.

This is a developing story, and we expect to have more news on SMS developments in 2023!

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European SMS Requirements for Repair Stations; Could Indirectly Affect Distributors

November 10, 2021 by Leave a comment

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.

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Congress Passes Massive Legislation With Significant Aviation Impact

December 22, 2020 by Leave a comment

Congress has passed a massive new piece of legislation that provides for appropriations throughout the government. The version that we reviewed has 5593 pages – it was not a final version (the pagination was off, among other things), but it provides a view as to what subjects are being addressed.

There is an entire division devoted to aviation matters. The section is identified as “Division V.” Not roman numeral “V.” The letter V (this is a huge document). This entire division is separate from the Covid-19 related funding matters found in the Division N, Title IV.

Division V is entitled “Aircraft Certification, Safety and Accountability.” It includes new legislation on the following points (this is a partial list only):

  • The FAA must initiate a Safety Management Systems (SMS) rulemaking within 30 days and must issue a final SMS rule within 24 months. This is a much faster schedule than the FAA’s current path, and may prevent the FAA from relying on some of the best practices being developed through the current SMS pilot program. The SMS requirement is limited only to companies that hold both type certificate and production certificate, although the FAA may choose to expand the scope of the proposed rule.
  • A number of changes related to ODAs (mostly limited to transport aircraft ODAs), including:
    • a requirement that all ODA unit members must be approved by the FAA. I was part of the ARAC group that created the draft regulations and policy for ODA (Subpart 183(d)), and the original concept was that mature ODAs would be able to rely on their internal mechanisms to assess, train, and appoint competent unit members using FAA-approved processes. This was intended to allow ODAs to train and develop their next generation of unit members. Putting the FAA into the appointment loop by statute eliminates one element of an ODA’s control over its future development.
    • ODAs and the ODA program will be subject to extra review
    • In order to minimize interference by an ODA holder with the ODA unit members, it is now illegal to interfere with a unit member. Interference is defined to include “harassment, beratement, or threats, that a reasonable person would conclude was intended to improperly influence or prejudice an ODA unit member’s performance of his or her duties” and also “non-ODA unit duties” that might conflict with performance of the ODA duties (this may lead to a de facto requirement to relieve ODA unit members of any non-ODA duties).
  • Where there are critical features identified for a transport aircraft, the FAA may not delegate findings related to such systems until the FAA has reviewed and validated any underlying human factors assumptions.
  • Type certificate applicants and holders will be required to disclose certain safety critical information and will be required to disclose changes in that information (including newly discovered safety information). This appears to expand the current disclosure requirements under 14 C.F.R. 21.3. New punitive laws for this issue makes a violation punishable by a million-dollar civil penalty.
  • A new dispute resolution process for design approval activities. An important element of this is that dispute resolution decisions will NOT be subject to judicial review, which could leave parties without a first amendment mechanism for petitioning for redress of grievances in certain circumstances.
  • Codification of the two-year disqualification period for former FAA employees who want to work in the private sector.
  • Requirement for new rulemaking on systems safety assessments for transport airplane projects.
  • New whistleblower protections
  • A heightened focus on human factors
  • New standards for Part 147 schools (those that teach A &P Mechanics) (ASA joined in the ATEC efforts to promote this goal)

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Another Reason for Distributors to Pay Attention to Safety Management Systems (SMS)

December 21, 2020 by Leave a comment

The Aviation Suppliers Association (ASA) has been promoting the adoption of risk management systems that would integrate with Safety Management Systems. One reason for this is because SMS can be a useful tool for managing safety; but another reason is because the business partners of distributors are expected to adopt SMS and distributors need to be able to work with their business partners’ SMS mechanisms.

An important driver for the ASA recommendations is the knowledge that SMS is coming. ICAO recommneded SMS almost 20 years ago, and ten years ago ICAO consolidated its SMS recommendations into one resource: Annex 19. The world’s aviation authorities have been seriously studying SMS for years, now; several have already implemented SMS for certain industry sectors and more SMS regulations are on the way.

EASA has taken the next step toward implementing a Safety Management Systems (SMS) rule for manufacturers and repair stations. Today, EASA proposed EASA SMS Opinion 04/2020. That Opinion was submitted to the European Commission for implementation.

Under that opinion. EASA proposes to modify the EU aviation manufacturing regulation, and the EU aviation maintenance regulation, to incorporate SMS. The proposed changes would also accomplish other objectives, like better alignment with other regulatory structures.

Air carriers in many countries have already adopted SMS programs. For distributors, this EASA proposal means that both the source of parts (the manufacturers) and the customers (the air carriers and repair stations) will be adopting Safety Management Systems. Past experience has shown that when the rest of aviation adopts a common approach to safety, that tends to result in application of the common approach to distribution, either through flow-down or through indirect pressure. With this in mind, it is likely that SMS will find its way into the aircraft parts distribution world and in support of this eventuality ASA has been offering SMS resources to its members for a number of years.

The next step is for the European Commission to adopt those changes. We do not yet know the precise timeline for that implementation, but the proposal has suggested implementation in the third quarter of 2021 (this timeline is not binding on the European Commission). Once the proposal is adopted by the Commission, EASA proposes that the amending regulations become applicable one year after adoption by the Commission.

The most notable SMS changes to the European aviation regulations are meant to:

  • Incorporate safety risk management, safety performance and continuous improvement elements into the EU regulations;
  • Foster an organizational safety culture in repair stations, design organizations, and production organizations; and
  • Streamline the oversight requirements for government agencies.

One of the key features of SMS for regulated parties is the identification of hazards – including future hazards – and the current mitigation of the risks posed by those predicted hazards. EASA notes that during the COVID-19 pandemic, they’ve noticed that an organization’s ability to effectively identify and manage emerging risks has proven to be an efficient tool for returning to normal operations. This is offered as a support for the value proposition associated with the introduction of SMS regulations.

EASA also posted its Comment-Response Document (CRD) for the SMS rule on its website, today. That document explains a number of the decisions that were made in the development of the SMS proposal.

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International Team Developing Safety Management Tools to Facilitate SMS/SSP Implementation (SM-ICG)

June 14, 2019 by Leave a comment

The world’s authorities are working together to harmonize the way that they develop and implement state safety programs. This will lead to a better worldwide understanding of Safety Management Systems (SMS), and it is resulting in tools meant to make it easier for companies to implement SMS programs, and for national aviation authorities to develop and run their state safety programs.  This is tremendously important for the next generation of aviation safety.

On the third day of the EASA/FAA International Safety Conference in Cologne, a panel discussed the activities of the Safety Management International Collaboration Group (SM-ICG). Andrew Larsen is the SM-ICG Chair, and he also works for Transport Canada. The SM-ICG was created to promote a common global understanding of safety management principles, and to facilitate their application across the international aviation community.

Amer Younassi, who manages the FAA’s Aircraft Certification International Division, was one of the SM-ICG founders. He intended the group to facilitate collaboration on the development of safety management and state safety programs, and he is particularly proud of the fact that the SM-ICG has grown to reflect a truly international community of experts.

Safety management is still new to the aviation community, and so it is critical to share the lessons that are being learned in order to facilitate success across the international community. The SM-ICG allows collaboration on the development of a common understanding of both SMS and state safety programs (SSP).

SM-ICG was founded in 2009 by FAA, EASA and TCCA, and SM-ICG has grown to a membership of 18 different regulatory authorities. ICAO serves as both an observer and an advisor to the group.

SM-ICG has been working to standardize terminology associated with SMS and SSPs, so that we can discuss SMS internationally without getting confused because we use the same terms to mean different things. Getting authorities to agree to common definitions has been a real success in the effort to harmonize international understanding of safety management. SM-ICG has also produced tools for safety performance measurement, both at the SMS level and at the state safety program level. Many authorities are using the SM-ICG tool as their primary tool for evaluating SMS programs, and the FAA used it to assess and endorse the NAS 9927 SMS standard. SM-ICG documents have been important to the development of FAA SMS guidance like FAA Order 8000.369 (Safety Management Systems) and FAA Order 8040.4 (Safety Risk Management Policy).

They are working on a number of projects, including ways to measure performance in a state safety program, hazard taxonomy examples, safety culture self-assessment tools, and a discussion of the role of the safety manager in the SMS program (ranging from a discussion of what is in their scope to recommendations about ways for the safety manager to communicate).

Younassi has found that the SM-ICG has been successful in developing tools that reflect an international experience with SMS and SSPs. He has found the SM-ICG tools to be useful to the regulators, and several of them are actively used by the FAA. These include SMS Inspector Competency Guidance, which has assisted the FAA in both identifying qualified FAA candidates and also in training the FAA inspector workforce. In fact, the FAA has developed job descriptions based on SMS Inspector Competency Guidance, and other countries are using this guidance to develop syllabi for inspector training.

Use of the SM-ICG tools is voluntary. The SM-ICG feels that successful SMSs and SSPs need to be customized to the implementers. But the tools being developed are meant to make implementation easier.

ASA asked about how SM-ICG can support smaller companies to ensre that SMS remains scalable. SM-ICG has recognized that there are very small entities in the industry, and this has always been on the mind of the participants. To support scalability, they’ve developed some tools with small businesses in mind, but Younassi admits that there are other tools that should be developed to specifically support the small business community. Larsen feels that one way that SM-ICG can assist smaller entities is to provide examples in their tools that focus on smaller SMS implementations.

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EASA Proposes New SMS (and other) Changes to Part 21 and Part 145

April 24, 2019 by Leave a comment

EASA has issued a Notice of Proposed Amendment (NPA) that would establish new SMS regulations for repair stations and manufacturers.

This NPA proposes to apply safety management systems (SMS) to Part-145 approved maintenance organizations, and to production and design organizations approved under Subparts G and J of Part 21.  It introduces elements of SMS into each set of regulations, but also makes a number of other changes in each, as well.

The proposed repair station SMS rules are published in section C of the NPA.  Many of the changes to EASA Part 145 appear to reflect terminology and cosmetic changes to make the existing regulations better reflect the terminology of SMS.  Some language from the CAMO regulations has been adopted for the repair station regulations.  There would be new regulations for airworthiness review staff.  Some changes are meant to better address risks posed by personnel fatigue and by external working teams.  Some of the oversight mechanisms (EASA Part 145.B) have been changed, and this will likely have indirect effects on the operations of repair stations.  There are also proposed changes to record-keeping requirements.  There are also significant changes to the occurrence reporting systems for repair stations.

Most distributors will be pleased to know that EASA 145.A.42 – which governs the documentation required for parts – will not change under this proposed rule.

Once the regulations go into force, existing EASA 145 organizations will have two years to modify their systems in order to comply with the new regulations.  This will likely have delayed effect on US-based EASA 145 organizations, because those organizations are required to comply with US regulations and the additional special conditions (as described in the Maintenance Annex, and also consistent with the implementation guidance in the Maintenance Annex Guidance); but the change in the EASA regulations could lead to a subsequent change in the special conditions.

The proposed manufacturer SMS rules are published in section B of the NPA.

Changes include an expansion of mandatory reporting system to require collection, investigation and analysis of all voluntary reports, in addition to mandatory reports.  It would expand the system to include requirements for reporting and managing internal errors and other hazards that do not fall under the traditional failures, malfunctions, defects and adverse effects occurrences that have been reported in the past.  While it is clearly meant well, this change could have the unintended effect of inhibiting voluntary reports, because of the new collection, investigation and analysis burden associated with these voluntary reports.

The new regulation would also impose on the production approval holder a duplicative collection, investigation, analysis and reporting obligation (currently the burden belongs to the design approval holder).

The reports made to the competent authority will also need to safeguard the identity of the reporter, which could inhibit subsequent investigation by the competent authority.

The new regulations will feature expanded record-keeping requirements and also a requirement for arrangements (like contractual requirements) that make all “partners, supplier and subcontractors” open to competent authority investigations.  This could mean that US suppliers to Airbus, for example would need to permit EASA investigators free access to audit or investigate at any time.

This is not a complete list of all of the proposed changes – it is worthwhile for anyone in the aviation industry to review these changes carefully as they may have wide-ranging effects.  There are also draft Acceptable Means of Compliance (AMC) and Guidance Material (GM) for each Part in the NPA.

The public is permitted to submit comments using the automated Comment-Response Tool (CRT).  The deadline for comments on this NPA is July 17, 2019.

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FAA Publishes SMS Rule

January 7, 2015 by Leave a comment

Tomorrow (January 8), the FAA will publish its SMS final rule for air carriers.

The industry has been waiting several years for this rule.  In fact, Congress mandated this air carrier SMS rule in 2010, with a final rule date not later than August 1, 2012.

Scope

The new rule applies to part 121 carriers, and requires them to submit an implementation plan to the FAA for review no later than September 9, 2015.  The implementation plan must be approved no later than March 9, 2016.  The plan must be fully implemented not later than March 9, 2018.

The FAA has estimated that the 90 domestic Part 121 air carriers will spend about 82 million dollars implementing and running SMS programs over the next ten years.  But these estimates are based on a man-power analysis that seems a little light.  Compliance with FAA requirements often takes more effort than what the FAA is estimating in its cost-benefit analysis.

This regulation should serve as a template for later SMS rules for manufacturers and repair stations.  An ICAO Standard and Recommended Practice (SARP) requires SMS regulations to be applied against air carriers, manufacturers and repair stations.  Many discussions of those rules have centered around reliance on the same Part 5 SMS rule that serves as the core of this rulemaking activity.

Recordkeeping

There are significant new record-keeping requirements in this rule.  The FAA is required to get OMB approval before it can impose new record-keeping requirements.  The rulemaking preamble admits that the OMB approval has not yet been issued, but promises to publish the OMB approval number when (if) it is issued.  The industry should keep careful watch on this – it has happened in the past that the FAA has sought to enforce record-keeping requirements before the OMB approval number was issued (or in the absence of such an approval number).  If the OMB approval number is not published by the time the implementation plans are due (in September) then air carriers may want to submit implementation plans without recordkeeping components.

The new records that must be created and maintained by air carriers will include:

  • records of outputs of safety risk management processes
  • records of outputs of safety assurance processes
  • records of all training

In addition, air carriers will be required to develop and maintain communication mechanisms that accomplish the following, and records of all of these communications must also be maintained:

  • Ensure that employees are aware of the SMS policies, processes, and tools that are relevant totheir responsibilities
  • Convey hazard information relevant to each employee’s responsibilities
  • Explains why each safety action has been taken (the FAA has not defined this term, “safety action,” but preambulatory language suggests that any reactive or proactive action taken to enhance safety may meet this description, so this could include each piloting decision, each dispatch decision, and even the decision to purchase a part from one vendor instead of another vendor)
  • Explain why each safety procedure is introduced or changed
  • Explain the reason for each safety procedure change

How Might This Affect Distribution?

A lot of the specifics about SMS are left open to interpretation. As a consequence, it is impossible to predict with any accuracy what sort of data requests will be directed from air carriers to their distributors. But it is not absurd to believe that some air carriers may impose data requirements on distributors in order to support their safety risk and safety assurance obligations.

On the other hand, this might be good for aircraft parts distribution. If air carriers are required to justify their safety decisions, and this extends to parts procurement decision, then a decision to purchase from an accredited distributor is justifiable, based on the FAA’s determination that such purchase is a sound safety practice (not to mention the FAA audit of the AC 00-56 program which found the program to be effective).

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Comments Filed at Home and Abroad

July 6, 2013 by Leave a comment

ASA continues to work diligently to promote and promote and protect its members’ interests both at home and abroad. In the past month ASA has filed comments on a proposed rule change by NASA, as well as a Notice of Proposed Amendment with EASA.

On June 17, ASA filed comments with NASA regarding the proposed definition of “counterfeit goods” detailed in the proposed “NASA FAR Supplement Regulatory Review No. 1.”  The issue of counterfeit goods in aerospace and received a significant amount of attention in recent years.  As we have explained previously, efforts by Congress and the Administration to curtail the presence of counterfeit parts in the supply chain has the potential to impose significant burdens on distributors.

One way to mitigate that burden is to ensure that everyone has a clear understanding of what is—and more importantly, what is not—a counterfeit good.  ASA is working hard on multiple fronts to ensure that the definition of a counterfeit part remains concise, narrow, and legally accurate, to avoid imposing unnecessary and unhelpful burdens on the industry.

ASA also offered comments on EASA’s recent Part 145 NPA.  The objective of the sweeping NPA is to incorporate SMS principles into Part 145, and the proposed changes have the potential to touch not only repair stations, but also distributors and manufacturers.  ASA made numerous suggestions related to the various proposals in the hopes of assisting EASA in order to assist in a more gradual incorporation of these changes, as well as to address proposals that appeared to fall outside the scope of SMS.

ASA looks forward to working with these agencies to craft regulations that promote safety and benefit the industry.

 

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