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Understanding FAA's Part 5 Safety Management System Requirements

Written by Michael Sidler | May 19, 2024 4:59:14 AM

 

The Federal Aviation Administration (FAA) is proposing significant expansions to the Aviation Safety Management Systems (SMS) requirements under Part 5, extending beyond the current scope that primarily covers Part 121 air carriers. This proposed rule aims to enhance aviation safety by bringing more segments of the industry under the SMS umbrella. Here’s a breakdown of the key points and implications of this proposal.

Expanded Applicability

The proposed rule will broaden the existing Part 5 Aviation Safety Management Systems requirements to include:

    • Part 135 Operators: This includes commuter and on-demand operations, extending SMS mandates to a critical segment of the aviation industry responsible for numerous short-haul and on-demand flights.
    • Certain Part 21 Certificate Holders: Specifically, those that hold both a Type Certificate (TC) and Production Certificate (PC) for the same aircraft, engine, or propeller.
    • Part 91.147 Air Tour Operators: Operators with a Letter of Agreement (LOA) will also fall under the new SMS requirements.
Proposed Changes to Part 5 Aviation Safety Management Systems

Several changes have been proposed to the existing Part 5 SMS requirements to ensure a more comprehensive approach to aviation safety management:

  • Code of Ethics: Introduction of a code of ethics emphasizing safety as the highest priority.
  • Confidential Employee Reporting System: Enhancements to ensure employees can report safety concerns without fear of reprisal.
  • SMS Implementation Plan: Part 21 TC and PC holders are required to submit an SMS implementation plan by December 27, 2024.
  • Reporting Summaries: TC and PC holders must submit summaries of confidential employee reports every six months.
  • Definition of “Hazard”: Revised to align more closely with International Civil Aviation Organization (ICAO) standards.
  • System Description Requirements: Detailed documentation of aviation processes, products, environment, personnel, and more will be mandated.
Rationale and Industry Input on FAA SMS Expansions

The FAA has identified several drivers behind this expanded Aviation Safety Management System mandate, including potential safety benefits, recommendations from the National Transportation Safety Board (NTSB), and compliance with the Aircraft Certification Safety and Accountability Act. The proposal seeks to gather industry input on various challenges, particularly for smaller operators. This input will help refine the applicability and ensure the requirements are practical and effective.

The FAA is considering feedback on potentially limiting the applicability for some Part 135 and 91.147 operators and extending SMS requirements to other certificate holders such as those with Supplemental Type Certificates (STC), Technical Standard Order Authorizations (TSOA), and Parts Manufacturer Approvals (PMA).

Conclusion: Preparing for the Expanded FAA Part 5 SMS Requirements

The FAA's proposed expansion of Aviation Safety Management System requirements aims to create a more consistent and proactive safety management culture across the aviation industry. By extending Part 5 regulations to include more operators and certificate holders, the FAA seeks to mitigate risks and enhance overall safety. As the industry provides feedback, these proposals will be refined to address practical implementation challenges while maintaining a strong focus on safety.

By adopting these expanded SMS requirements, the FAA aims to foster a safer and more resilient aviation industry, better equipped to anticipate and mitigate risks before they result in incidents or accidents. Stay informed and engaged to ensure your operations comply with these crucial aviation safety standards.

Citations:
  1. NBAA: FAA's Proposed SMS Mandate
  2. FAA: SMS Specifics by Aviation Industry Type
  3. Vertical Mag: FAA Issues Final Rule Mandating SMS for Part 135 Operators
  4. NBAA: SMS Information
  5. ECFR: Title 14 Part 5