With MRO SMS Mandates, Scalable Sells

Those in the U.S. MRO segment that favor a scalable approach to a safety management system (SMS) mandate will take comfort in the results of this survey.
Conducted by St. Louis University's Center for Aviation Safety Research (CASR), the survey is part of FAA's effort to determine how to proceed with SMS rulemaking beyond airlines and airports. (Rulemakings for them--under Part 121 and Part 139, specifically--are underway, with draft regulations published in October 2010.)
Two of the CASR survey's major takeaways: 65.4% of the 440 respondents believe that repair stations working on Part 121 aircraft should have an SMS, while 55.1% believe the same for facilities that service Part 135 operators.

Among those that work on transport category aircraft, which account for about 7% of the U.S.-registered fleet, 54.8% percent say they would "likely" voluntarily implement SMS, as would 42.2% of all respondents. Only 13.0% of the respondents already have SMS in place at their facilities.

While there’s plenty of variety among U.S. airlines and commercial airports, those groups look homogeneous next to the 4,100-odd FAA-approved repair stations. 

About 45% of FAA repair shops are textbook small businesses with fewer than 10 employees. At the other end of the spectrum, about 350 repair stations (9%) have payrolls with at least 200 people. 

Further complicating the issue: staff size doesn't directly correlate with the type of work done. The CASR survey found that about 52% of the facilities represented in the survey handle some transport category work, yet 75% of them have fewer than 100 employees. 

Creating an effective rule that covers such a variety of organizations is tough enough. Ensuring that rule rests soundly on the International Civil Aviation Organization's four-plank SMS platform--hazard identification, safety performance monitoring, remedial action when performance slips, and constant improvement--strikes some as fantasy.

"It is like mandating morality," says Sarah MacLeod, executive director of the Aeronautical Repair Station Association. "It looks good on paper, but it is impossible to enforce uniformly, let alone even-handedly." 

The idea of a scalable U.S. SMS rule isn't new. When FAA canvassed industry on suggested SMS approaches in 2009, many in the maintenance world suggested such an approach. 

Pratt & Whitney in its comments on FAA's 2009 query said it backs an "appropriately scaled" SMS program based on an organization's "level of activity" and type of work.

Business aircraft MRO specialist Duncan Aviation said it would only back an SMS mandate if it is "scalable to the operation employing it" and cost-free when not in use.

CASR's survey results suggest that a scalable approach to Part 145 SMS would be well-received--that is, as well-received as any new mandate can be.

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