Last week, the FAA published a final rule that expands Safety Management System (SMS) requirements to several categories of commercial passenger-carrying operations. Specifically, this rule change will expand the applicability of the SMS rule to Part 135 on-demand operators, 91.147 air tour operations, and certain Part 21 certificate holders.
EAA submitted comments to the Notice of Proposed Rulemaking (NPRM), primarily raising concerns about the scalability of SMS and the application to a wide variety of operations under this expansion, including small single-pilot operations. As stated in these comments, “SMS is an excellent tool when organizations fully embrace it and use it to build a better safety culture, but EAA is concerned that for some organizations these requirements could be seen simply as additional workload if not implemented on an appropriate scale.” The FAA addressed these concerns by adjusting certain elements of the final rule to better accommodate smaller operations.
As the rule goes into effect, EAA will continue to monitor the application of SMS requirements and the burden of compliance on the full range of operations. EAA supports the use of SMS as an extremely useful tool for many operations, and hopes that this rule will provide a reasonable framework for these operations to promote safety.
