In joint comments submitted to the FAA on April 11, ARSA and the Aircraft Electronics Association (AEA) opposed the potential expansion of the agency’s Safety Management System (SMS) rules contained in 14 CFR part 5 to include repair stations certificated under part 145.
The comments were submitted in response to the FAA’s Jan. 11 proposal to update and expand the requirements for SMS and require certain certificate holders and commercial air tour operators to develop and implement an SMS program. While certificated repair stations were not included in the proposed SMS rule, the FAA requested comments and information regarding a future rulemaking project to expand the applicability of 14 CFR part 5 to include repair stations.
As part of the rulemaking process, the FAA must assess and substantiate the economic burden by establishing the requirement would increase safety. The agency was unable to do so when attempting to apply quality assurance to U.S.-based repair stations in its 1999 rulemaking. Therefore, it is unlikely the FAA could validate an increase in safety to justify the burden of implementing and maintaining an SMS, particularly on small businesses.
In support of this effort, ARSA conducted a survey of its members the week of April 3. Ninety-four percent of respondents opposed a future rulemaking to expand the applicability of part 5 to repair stations, 97 percent opposed applying part 5 to all repair stations, and 96 percent opposed limiting the applicability to a certain subset of repair stations.
“Part 145 already has a robust quality management system as required by 14 CFR §§ 145.209 and 145.211. This is not to assume that the quality management system is perfect and that it could not be enhanced with continuous improvement however, the FAA is already overseeing repair station certification and operations through its Safety Assurance System with many of the 3 elements contained within SMS such as risk assessment and management, change management, and promotion and outreach,” ARSA and AEA said. “The FAA should declare 14 CFR part 145 combined with the Agency safety assurance oversight of repair station to be SMS complaint.”
To read the ARSA-AEA joint comments, click here.
For more on AEA’s SMS advocacy, click here.
To submit your own comments and access the SMS docket, click here. (Note: While the comment period closed on April 11, agencies may still consider late-filed comments.)
[/accordion]
[/accordions]
