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Opinion: MROs Should Layer SMS Into Existing Quality Systems
U.S. repair stations will be required to implement safety management systems by December 2025.
An effective safety management system cannot be “bolted on” to existing manuals and procedures, ARSA Executive Director Sarah MacLeod explained in her digital Inside MRO column in August. The editorial continued ARSA’s series—which appears in installments in its own communications as well as in the pages of the industry trade press—explaining its safety management system implementation philosophy.
The series kicked off with the rush created in June when a European Union Aviation Safety Agency (EASA) announcement from the stage of the International Aviation Safety Conference and an FAA Information for Operators started the clock on a December 2025 deadline for U.S. repair stations to implement safety management systems (SMS) to comply with the EASA-FAA bilateral agreement. Although the actual requirement has not yet been included in the EASA-FAA Maintenance Annex Guidance’s Special Conditions, pragmatism demands taking that deadline seriously.
In her “bolted on” editorial, MacLeod hinted at differences between American and European regulators’ approaches to SMS: “On one side are the regulators who believe an agency’s role is to find compliance through a corporate culture more conducive to open communications—the backbone of safety management. The other, government (which do you think?), takes the more hidebound approach of hunting noncompliance and forcing corrective action based on guidance or preference rather than the safety analysis required by the rules.”
Regardless of which regulator is the competent authority, a repair station or approved maintenance organization would do well to layer its SMS within existing quality control systems. At its core, safety management is a human factors discipline, training in which is already required for U.S. facilities holding EASA certification under the bilateral. Those certificate holders integrate “lessons learned” from within the quality system into “lessons received” by personnel to prevent future escapes—a considerable step toward SMS implementation. Closing the gap between how things work in a repair station’s systems and applying it to what the company does to control organizational risk is the key to a successful program.
ARSA’s ongoing communications about SMS installation are dissecting the PEAR Human Factors Model—People, Environment, Actions, Resources—as a foundation for safety risk management. In a maintenance facility, each element in this model helps focus the organization on airworthiness. Tending to these characteristics ultimately enables the company to “do . . . work in such a manner and use materials of such a quality that the condition of the aircraft, airframe, aircraft engine, propeller or appliance worked on will be at least equal to its original or properly altered condition,” according to §43.13(b). This performance standard is attained through human factors as a foundation of SMS.
SMS implementation is not a new project and should not result in a separate manual sitting on the shelf. Between now and December 2025, U.S. repair stations can take simple steps to layer the “new” requirement into existing quality systems—which have for the last century been quite effective at managing safety.
Brett Levanto is vice president of operations at Obadal, Filler, MacLeod & Klein, managing firm and client communications in conjunction with regulatory and legislative policy initiatives. He provides strategic and logistical support for the Aeronautical Repair Station Association.
