Research in Engineering and Aviation

Safety Management Systems for Aviation Service Providers

April 2013

Author(s):  Steckel, R., Lercel, D., Rieser, T., Kostal, E., & Patankar, M.´╗┐


The Federal Aviation Administration (FAA) is currently developing proposed regulation for 14 Code of Federal Regulations (CFR) Part 121 operators (air carriers) to implement a Safety Management System (SMS). The FAA has developed these general requirements with the possibility that in the future, they could apply to other FAA-regulated organizations, such as 14 CFR Part 135 commuter/on- demand operators, Part 141 approved flight schools and Part 145 repair stations. Applying SMS to organizations operating in accordance with various industry and regulatory standards has many service providers concerned with potential redundancy or unnecessary efforts associated with implementing an SMS.

This report compares current regulatory requirements and a number of safety and quality programs with the SMS requirements outlined in FAA Advisory Circular (AC) 120-92A. Aviation service providers may use these comparisons to identify opportunities to leverage existing requirements and programs to meet the requirements of the AC. In addition, this report analyzes participant feedback from an FAA and Center for Aviation Safety Research (CASR) co-sponsored “Gap Analysis” conference held September 20-21, 2011 in St. Louis, Missouri. During this conference, participants from Part 145 repair stations, Part 121 and Part 135 operators, and Part 141 approved flight schools discussed concepts and strategies regarding the SMS gap analysis process and SMS implementation. Conference participants provided the FAA and CASR valuable feedback and recommendations regarding SMS. In addition, conference attendees completed a written survey measuring their attitudes and opinions regarding the topics and SMS in general.

The results of the gap analysis research, conference discussions, and post-conference survey indicate the following:

  1. Current Federal Aviation Regulations in themselves do not constitute an SMS.
  2. Some industry standards currently meet the requirements of the FAA SMS AC.
  3. A Letter of Compliance could be an alternate method of documenting a compliance with SMS program requirements.
  4. Organization may leverage existing policies and procedures to comply with SMS requirements.
  5. Other transportation industries have SMS programs, which meet or exceed the requirements of the AC.
  6. Service providers are concerned with the lack of consistency in interpretation of SMS requirements and compliance options across the FAA Flight Standards District Offices or Certificate Management Offices.

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