Bahrami admits SAS hiccups but ask MROs to appreciate the data’s safety value

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Risk-based Oversight Progressing, But Work Remains, FAA Says

SMS/ASIAS/SAS change with challenges

Bahrami recognizes SAS needs work

Asks MROs to see data’s benefits

Change is a difficult process. Plato, the Greek expert in regulatory regimes, once noted “necessity is the mother of invention.” While certain inexorable realities compel the FAA leadership to the new Oversight Regime, their field personnel and industry may not be as aware of the sine qua non. Thus, they may not be as motivated to adapt. At the MRO Americas, speaking to the Part 145 segment, the FAA #1 safety regulator tried to make his case for Part 145 participation while acknowledging that  SAS is being revised in response to industry concerns.


The Greek philosopher’s contemporary regulatory platonic followers–Peggy Gilligan, her immediate disciple, Ali Bahrami and their senior executives–faced with certain necessities ( the top two–small work force and a higher level of safety) brought them to initiate SMS/ASIAS/SAS. The new regulatory system looks to meta data base with analytics which can forecast trends which pose risks for which solutions must be designed, collaboratively.

The Aviation Safety Inspectors attained their positions based on radically different skill sets. The AVS and AGC leaders have implemented practical approaches to manage this transition. There is no doubt that time will be required to get all 11,000 field personnel on the same page.


Bahrami ‘s audience was the holders of Part 145 authority. Some of them are large with substantial support systems, capable of coping with the new data burden of SAS. However, there are a number of small, specialized, but extremely capable repair shops. Additional overhead mandated by SAS may be more expensive than they can afford.

This segment of aviation is well represented by the Aeronautical Repair Station Association and they used the Paperwork Reduction Act to compel the FAA to justify the burden of DCTs, an element of SAS. OMB is reviewing this FAA request.


Mr. Bahrami acknowledged that a “[t]he idea behind the system is good, but we’re learning. We’re still in the very early stages… agency is listening to industry feedback as part of making the new approach more effective ” Trying to explain the need for the DCT and other sources of information, the FAA Associate Administrator of Aviation Safety pointed out that “the system will help FAA prioritize surveillance based on what’s happening at airlines and repair stations, putting more emphasis on certificate holders that show signs of risk, such as inconsistent procedures. But SAS’s most important element–data collection–continues to present challenges.”

He urged the Part 145s to consider that “more than 100 operators participate in the data-sharing program, but only two–AAR Corp. and HAECO Americas–are MRO providers while all of the U.S. airlines have Safety Management Systems (SMS) in place. He promised to go back and take a look at some of the issues raised at the most recent InfoShare safety lessons-learned gathering.

The GAO has recommended that

FAA should: (1) develop and implement a process for incorporating into SAS volume data for U.S. airlines’ maintenance contracted 
to repair stations and (2) develop a process to evaluate the effectiveness of SAS. FAA disagreed with the first recommendation, 
noting it considered other volume-related data, and agreed with the second recommendation. GAO continues to believe the recommendation 
is valid as discussed in this report.

Change is difficult, and the speed of acceptance varies with the company’s understanding of the need and its capacity to deal with the new necessity. Hopefully, all involved can devise a win/win solution; for SMS/ASIAS/SAS poses great potential to reduce aviation safety risks.



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