FAA Unveils Expanded SMS Mandate Covering Manufacturers

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Credit: FAA

WASHINGTON—The FAA’s long-awaited rule expanding safety management systems (SMSs) beyond scheduled airlines would give affected manufacturers until late 2025 to implement the organization-wide programs, while Part 135 operators and Part 91 air tour operators would face a deadline two years after a final rule’s publication.

A draft of the rule, set for public release in the coming days, “would extend the requirement for an SMS to all certificate holders operating under the rules for commuter and on-demand operations, commercial air tour operators, production certificate (PC) holders that are holders or licensees of a type certificate (TC) for the same product, and holders of a TC who license out that TC for production,” the agency wrote in the proposed regulation’s preamble. “These entities would receive the greatest safety benefits of an SMS as they are best situated to prevent future incidents and aviation accidents.”

The rule would also change current SMS requirements that Part 121 operators have had for several years. Under the proposal, organizations would develop “a system description,” which the FAA defines as “a summary of aviation-related processes and activities and a description of interfacing persons that contribute to the safety of the organization’s aviation-related products and services.” 

In addition, an SMS system analysis would be expanded to factor in “interfaces” within the system. This could include between two employee groups, or between a system’s hardware and software, the FAA said.

“Understanding the interfaces while conducting a system analysis is important because the system analysis serves as the basis for identifying and analyzing hazards and their associated risk,” the agency said. “As the aviation system becomes more complex, dynamic, and integrated, understanding these interfaces can assist in the identification of related hazards and improve safety overall. An SMS that looks both inward and outward is more effective at identifying hazards, a core function of any operational SMS.”

Under FAA’s proposal, Part 121 operators would have 12 months following a final rule to update their SMSs with the new requirements. Part 135 and 91.147 air tour operators would have 24 months “to develop and implement an SMS” and “submit a statement of compliance.”

Holders of TCs and PCs for the same product as well as TC holders that license others to obtain PCs would need to submit SMS plans for approval by Dec. 27, 2024, and implement them by Dec. 27, 2025. Manufacturers that fall into these categories following new approvals would have a year to comply.

Acceptable implementation plans must “include a description of how the person intends to comply” with SMS requirements “and for the person to make available, upon request, all necessary information and data that demonstrates that the SMS has been or will be implemented in accordance with the implementation plan.”

The FAA’s proposal is the latest step in an effort the agency began in 2014 but paused before a draft rule was published. Currently, the agency will review and “accept” a company’s SMS structure. GE Aerospace, Boeing, Bell, Pratt & Whitney and Sikorsky are among the manufacturers affected by the new rule that have approved programs.

Mandating SMSs for manufacturers was part of a 2020 law aimed at reforming FAA certification. The legislation did not extend to any aircraft operators, however.

“Expanding Safety Management Systems to other players in the aviation industry will reduce accidents and incidents and save lives,” Acting FAA Administrator Billy Nolen said. “As safe and efficient as our system is today, we must always strive to achieve the next level of safety.”

Sean Broderick

Senior Air Transport & Safety Editor Sean Broderick covers aviation safety, MRO, and the airline business from Aviation Week Network's Washington, D.C. office.