Research in Engineering and Aviation
Applicability-Based Model for Safety Management Systems Compliance by Part 145 Repair Stations
Since the early discussions regarding SMS compliance in the repair station industry, there has been an unbridgeable divide between small (under 30 employees) repair stations and medium to larger (30 or more employees) repair stations. Essentially, the small repair stations believe that the proposed SMS regulations will be overly burdensome, expensive, and may not improve safety. Medium to larger repair stations, on the other hand, believe that SMS regulations can be complied with using existing systems and resources, but more importantly, such compliance is essential for their business and safety interests. The FAA, as a regulator, is in a bind because the ICAO has required all member states to comply with the SMS requirement, but it is unable get the SMS regulation through the legislative process. Considering the demographic distribution of repair stations (small versus medium/large), it would be impossible to move the SMS regulation forward without securing support from the small operators, and the small operators are not likely to support this regulation until there is way for these organizations to scale their compliance based on complexity of the organization. Therefore, this report presents an applicability-based compliance model for SMS compliance in part 145 repair stations.
The Applicability-based Model classifies repair stations based on their aircraft category approval: Normal, Utility, and Acrobatic categories generally represent less complex aircraft and these approvals generally coincide with smaller operators; while Commuter and Transport categories generally coincide with more complex aircraft and medium to larger operators. Since the category of aircraft is easily and consistently understood across the repair station industry as well as the various FAA offices, it is the most consistent classification system. It is estimated that about 70 percent of the domestic repair stations are covered by normal, utility, or acrobatic category and employ less than 30 individuals. If SMS adoption is voluntary for this group of repair stations and mandatory for those with commuter or transport category certifications, the medium to larger repair stations that are enthusiastic about the SMS regulations will readily approve and adopt the regulation. Concurrently, about 10% of the smaller repair stations will adopt the SMS regulations on a voluntary basis, about 40% of the smaller repair stations will choose to adopt a scaled-down version of SMS (called SMSLite), and the remaining 10% of the smaller repair stations will choose no SMS based on low size and complexity.
At the present time, the Applicability-based Model seems to be the only viable approach to moving the SMS regulation through the legislative process and complying with the ICAO mandate.