Safety management proposal foreshadows problems for GA

AOPA ePublishing

A proposal initially intended for airlines could unleash a host

of new, ill-defined requirements for general aviationÑrequirements that neither

the FAA nor the industry has the resources to implement, AOPA told the agency March 7.

In late 2010, the FAA proposed requiring Part 121 airlines “to develop and implement a safety management system” to improve its aviation related

activities. While this would at first only apply to scheduled airlines, the

agency said that it intended to extend the requirement to other air agency

certificate holders, including charters, flight schools, and repair stations.

AOPA supports promoting an industry-wide safety culture but

warned that that the broad, open-ended requirements in the proposal would open

the door for widely varying interpretation and would overburden small

businesses. In addition, AOPA wrote, the FAA already has long delays and

varying interpretations of existing, simpler regulations; adding more would be

“irresponsible and a disservice to the small business owners and aviation

community as a whole.”

An SMS includes “an organization-wide safety policy; formal

methods for identifying hazards, controlling, and continually assessing risk;

and promotion of a safety culture,” the FAA proposal said. It did not specify

how compliance would be measured.

So how would organizations comply? AOPA warned in the letter

that SMS concepts are extremely subjective. Companies would be subject to

various field inspectors’ interpretationsÑa problem that already exists, said

AOPA Vice President of Regulatory Affairs Rob Hackman.

“Today, we see a significant difference in the ‘interpretation’

of existing regulations by FAA staff that oversees general aviation

operations,” he wrote. “It will be virtually impossible to standardize

inspectors to the level necessary to evaluate a company’s SMS processes.”

Applying the SMS requirements to GA would be burdensome for both

operators and inspectors, Hackman said. Small businesses often can’t spare

employees to dedicate to meeting extensive new requirements, and there is

already a backlog of issues related to obtaining and maintaining existing air

agency certificates at FAA flight standards district offices nationwide, he

said.

The proposal stems from a 2010 law requiring rulemaking that

would implement SMSs for air carriers. AOPA urged the FAA not to consider

expanding SMS beyond that mandate for air carriers until serious questions are

answered and the industry and FAA have significant experience with air carrier

SMS. The FAA should instead consider voluntary methods for incorporating safety

programs, the association said.