SMS is coming to Part 145; delay is not a positive tactic
Safety Management Systems (SMS) is the standard of excellence for AVIATION SAFETY; the globally revered standard for risk management seems to have stricken TERROR into those certificate holders added to the purview of 14 CFR Part 5 . The JDA team has assisted certificate holders under Part 121, Part 135 and voluntary compliance,
Our uniform experience is analogous with these expansions of the SMS purview. The certificate holder is apprehensive about voluntarily submitting to the SMS regimen—the FAA will issue an enforcement violation for failing to meet the requirements of Part 5- THAT’S THE old enforcement philosophy. Today, as with almost all of SMS, information submitted voluntarily cannot be used as the basis for a sanction. The foundation of this risk management regimen is reporting mistakes creates important lessons that will minimize these inadvertent errors.
Yes, the Syringe’s puncture creates significant apprehension, but our experience is that once vaccinated by SMS, Safety benefits!!!
Our experience has been that the fear of SMS is compatible to the fear of a syringe, its technical name is TRYPANOPHOBIA. History shows that once the inoculation has been injected, the temporary pain is forgotten. More importantly, the vaccine creates long term enhancement of the safety awareness!!! Let us help you through the introduction of SMS. Having led multiple certificate holder into establishing this disciple, here are our insights about the transition to a higher level of safety:
In 2005 JDA became one of the first 2 firms to be qualified by the FAA as a Certification Consultant and in 2009 was qualified and licensed as a MITRE Aviation Institute Safety Management System (SMS) training and implementation organization. The FAA terminated that status for all companies qualified under this program in 2025.
JDA has a comprehensive Safety Management System (SMS) portfolio that includes SMS planning, implementation and training, SMS safety culture assessments and safety gap analyses, SMS manual development, and SMS software applications. JDA’s safety culture assessment program is a groundbreaking service that provides both quantitative and qualitative benchmarks for any type of aviation organization. JDA OFFERS SMALL COMPANIES WITH LIMITED STAFF AND RESOURCES AN OUTSOURCED SAFETY DEPARTMENT THROUGH JDA’S VIRTUAL SAFETY OFFICE (VSO) PROGRAM.
Technical management, expertise and experience are critical in achieving successful new certifications. Most of the JDA team are former FAA managers, supervisors and principal inspectors. JDA team members are experienced in using the same diagnostic processes and tools as the FAA, including the FAA 8900.1 Flight Standards Information Management System and the FAA’s Safety Assurance System (SAS) Safety Attributes and the FAA SAS Data Collection Tools. Our Certification Directors and Specialists possess a unique capability of being able to “think like an FAA inspector” while being fully cognizant of the potential impact a new procedure may have on an operation and are unsurpassed in their technical knowledge in this area.
In order to assure that SMS is not just a shelf full of fancy three-ring binders in a some library distant from all the operating personnel, the JDA rubric involves all of those responsible for aviation safety, i.e. EVERYONE, in a comprehensive and collaborative process to design policies, procedures, forms and structure. An experience that heightens the likelihood that these individuals and all around them HAVE ADOPTED THE SMS CULTURE.
Yes, we have enough experience that we could hand out forms and just fill in the company’s name in the apt blanks. Participation tends to enhance the adoption throughout the organization. When everyone is inculcated into SMS, a shared involvement facilitates this consciousness of safety 24/7/365/3600.Once through the initial apprehension anxiety, your P145 will achieve even higher levels of safety.
By delaying, you risk being part of a massive bow wave of P145 SMS applications. The FAA field staffing may have been decimated by then and delay in approval may consume months of more. The MOB may not consider the inability of US facilities to allow continued authorization while waiting. Be early in line and be ready to capture the waiting business!!!
U.S. Bilateral Update Requires SMS Compliance
February 25, 2025
On Feb. 10, the Bilateral Oversight Board (BOB) for the U.S.-European Union (EU) bilateral aviation safety agreement (BASA) issued Decision No. 13. It amends BASA Annex 2 to require U.S.-based repair stations with European Union Aviation Safety Agency (EASA) approval to ESTABLISH, IMPLEMENT, AND MAINTAIN A SAFETY MANAGEMENT SYSTEM (SMS).
SMS for U.S. repair stations has been on the radar for years. The FAA issued InFo 24007 in June 2024 and announced at the 2024 FAA-EASA International Safety Conference that SMS would be required for U.S. EASA repair stations by the end of 2025. Approved maintenance organizations (AMO) in the EU are already required to have SMS. The FAA decided not to include repair stations in its expansion of 14 CFR part 5, which created a significant difference between FAA and EASA regulations. Thus, SMS was added to the BASA special conditions for U.S. based repair stations wishing to obtain or maintain an EASA certificate.
The BOB is authorized by the bilateral agreement to amend the annexes. The exact language added to Appendix 1 of Annex 2 is—
(b) The repair station shall establish, implement, and maintain a Safety Management System (SMS) acceptable to the FAA and compliant with ICAO Annex 19 as applicable to maintenance organizations. The FAA SMS Voluntary Program outlines the process and requirements.
To facilitate compliance, ARSA has partnered with the Aircraft Electronics Association (AEA) to provide ARSA members with access to AEA’s SMS tools. The AEA-managed program is constructed around the principles created by the International Civil Aviation Organization (ICAO) for adoption by the civil aviation authorities. It is consistent with the FAA’s Voluntary Program.
The BOB’s Decision isn’t the final step in the process of imposing SMS on U.S. repair stations. The authorities must still issue new Maintenance Annex Guidance (MAG) to provide direction to industry about the requirements. At last report, the MAG was nearly complete; however, the regulatory freeze imposed on federal agencies by the Trump administration likely causing delays. ARSA also expects new related guidance for FAA inspectors, but the timing is unknown.
EASA and FAA executives will update the industry on the status of SMS implementation at ARSA’s Annual Conference next month. In the meantime, to read BOB Decision No. 0013, click here. To read the consolidated text of the bilateral agreement, click here.
