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EAA Feels SMS Not Ready for Prime Time

March 10, 2011 — In comments submitted to the FAA this past week, EAA states the part 121 air carrier Safety Management System (SMS) proposal presented to the public is not ready for prime time.

EAA’s main concern centers on the FAA’s failure to adopt a key recommendation of the SMS Aviation Rulemaking Committee’s (ARC) final report dated March 31, 2010: that guidance be provided for accommodating the minimal management and oversight capabilities of small GA businesses. The ARC recommendation stressed “the importance of creating a regulatory framework that is scalable and flexible to accommodate a broad range of organizations, from small operators and manufacturers to large organizations holding multiple types of FAA certificates or approvals. This would ensure that the level of SMS-required complexity imposed on a small organization would not interfere with the organization’s ability to pursue its business, or impose a degree of SMS data analysis that would result in insufficient time left to develop, implement, and monitor risk mitigation procedures.”

The ARC recommended the SMS program be incorporated into all aviation industries starting with part 121 air carriers. EAA is concerned that SMS will be imposed on other industries such as repair stations, flight schools, EMS helicopter operations, aircraft manufacturers, and others without waiting for the lessons learned from this part 121 proposal.

Failure to incorporate scalability, flexibility, and guidance to ensure accommodation for small businesses will potentially have an adverse impact on part 91 GA businesses and manufacturers should the FAA elect to mandate SMS for this segment of the industry. The scalability issue is raised in the proposed AC 120-92, but since all ACs are advisory in nature, the scalability issue could be ignored in the course of implementation. EAA maintains that these issues must be addressed.

Read the full text of EAA’s comments here.


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