To lawyers and quality geeks, the careful selection of words one uses to communicate is a source of constant musing. Because of this I’m amazed that preflight passenger briefings continue to use a curious mixture of potentially confusing words for the inexperienced passenger. For example, “posted placards”. Huh? What’s a placard? Also, “no congregating around the forward lavatory”. Congregating? Are they expressing a religious restriction? I’m offended. Why not just plainly call a placard- signs, or for congregating- assembling or flocking or massing…so my thesaurus says.

Thankfully for those in the global aviation community, use of the term Safety Management System or SMS evokes no such ambiguity or confusion.

I recently had a pleasurable experience assisting a firm in Brasil implement a SMS for their Repair Station. In Europe and in Canada too, the applicable civil aviation authorities are mandating SMS systems for Maintenance Organisations. Indeed, it is being mandated by Civil Aviation Authorities globally for Maintenance Organisations…except in the USA.

Before anyone wags their finger at me, I must point out that air carriers in the USA have indeed been required to implement SMS’s. For example, this FAR:

“5.1: Applicability. (a) A certificate holder under part 119 of this chapter authorized to conduct operations in accordance with the requirements of part 121 of this chapter must have a Safety Management System that meets the requirements of this part and is acceptable to the Administrator by March 9, 2018”

While US 121’s are in sync with global SMS trends, this is not so with US 145’s; there is no such requirement for Repair Stations.

So what is a SMS? According to the definition in this FAR:

“5.5: Safety Management System (SMS) means the formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of safety risk controls. It includes systematic procedures, practices, and policies for the management of safety risk.”

The purpose of this article is not to introduce you to SMS principles which are profound, but to focus on the issue that USA 145s are not currently required to implement these systems.

Global voices and various alphabet groups have a way of influencing perceived imbalances. Let’s look at some interesting issues to illustrate my point.

During the heyday of US labor groups bemoaning the profligate outsourcing of maintenance work to firms outside the USA, it was common to hear in the halls of Congress, complaints by those labor groups that it was unfair and unsafe for US maintenance organizations to compete against foreign maintenance organisations because those foreign firms were not required to have drug and alcohol testing programs as modeled by US firms.

What if:

What if those foreign maintenance firms today said that it was unfair and unsafe to compete against US 145 maintenance organizations because they’re not required to implement SMS as is modeled by the rest of the world? After all, implementing a SMS is not cheap. Hmmm…

Further stirring the pot; another idea to dwell upon: Many years ago the FAA gave the industry the expectation that when part 21 was re-written, it would mandate Production Approval Holding (PAH) manufacturers to issue 8130-3 tags as is generally required and practiced by other Civil Aviation Authorities around the world. For example Form 1’s. Along came the FAR 21 rewrite sans the 8130-3 requirement.

Roll forward several years and along came the now famous “EASA MAG” requirement imposing upon US, EASA Approved Repair Stations the requirement to have 8130-3 tags on parts from those PAHs, even though the FAA had not facilitated that process. Wow, that was an interesting way to make the US harmonize with what the rest of the world was doing.

So, you may ask, why the sudden renewed interest in SMS?

EASA has issued a Notice of Proposed Amendment (NPA) that would update or establish new SMS regulations for repair stations and manufacturers^{1, 2, 3}.

Let’s connect the dots. According to a recent article³:

“Once the regulations go into force, existing EASA 145 organizations will have two years to modify their systems in order to comply with the new regulations.This will likely have delayed effect on US-based EASA 145 organizations, because those organizations are required to comply with US regulations and the additional special conditions (as described in the Maintenance Annex, and also consistent with the implementation guidance in the Maintenance Annex Guidance); but the change in the EASA regulations could lead to a subsequent change in the special conditions.”

Clearly then, there is the possibility that SMS may trickle down to USA EASA Approved Repair Stations through the instrumentality of the Maintenance Annex Guidance (MAG), in much the same way 8130-3’s for PAH’s did. To be clear, if this occurred it would only affect US EASA Approved Repair Stations.

On the other hand, the FAA has not been idle regarding the idea of SMS for Repair Stations and in fact has been active with other global groups such as the Safety Management International Collaboration Group. At this moment the FAA has been working with a few US Repair Stations who are voluntarily implementing SMS and testing the waters on how recognition could be given to such firms.

Is implementation of SMS systems for Repair Stations a bad thing?

Devotees of safety and quality will no doubt quickly respond in the positive; it’s a good thing. In the past, regarding the 8130-3’s for PAH’s, we heard that the reason for not doing so in the Part 21 rewrite was because many manufacturers said it would cost too much. There is the possibility that in the US, the lack of a regulation to implement SMS for part 145 Repair Stations has a similar basis. Thankfully, nearly all guidance on implementing SMS for Repair Stations is based on the size of the firm, so small repair stations won’t have to implement the same amount of processes and procedures as would large firms. For example, see “SMS Systems for Small Organizations⁴”.

Finally, for US Repair Stations which are ISO/AS accredited such as 9001, 9100, and 9110, you will immediately take notice of a significant feature of SMS which is Risk identification, management, and mitigation. Royboy would advise you cross reference your ISO/AS P&P’s to the SMS P&P’s to avoid duplication and bring a degree of harmony to both systems.

PS: Back to our sidebar about in-flight announcements. I often wonder if pilots, upon passing their union probation, are required to sign an agreement in which passengers will be referred to as “Folks”? This is mainly a US phenomenon.

So…all the placards seem to indicate that the world is congregating around the idea of SMS systems for everyone. That’s all folks.

Over ‘n out

Roy ‘Royboy’ Resto

www.AimSolutionsConsulting.com

¹ https://www.mro-network.com/safety-regulatory/new-easa-sms-rules-could-alter-us-part-makers-obligations

² https://pmaparts.wordpress.com/2019/04/25/easa-proposes-sms-rules-us-manufacturers-should-study-these-carefully/?utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+marpa+%28MARPA+Web+Log%29

³ https://aviationsuppliers.wordpress.com/2019/04/24/easa-proposes-new-sms-and-other-changes-to-part-21-and-part-145/

⁴ https://www.skybrary.aero/bookshelf/books/3055.pdf