March 24, 2023

With an April 11 deadline looming to submit comments to the FAA, NBAA is soliciting feedback from members on the agency’s proposal to require all Part 135 operators, certain Part 21 certificate holders and §91.147 air tour operators to implement a safety management system (SMS).

The mandates extend well beyond the FAA’s requirements for safety programs to date. NBAA has long been supportive of safety management systems; however. the association and its member companies have significant concerns about the proposed rule as currently written.

NBAA director of safety and flight operations, Mark Larsen, CAM, in detailing the FAA’s proposal, noted that the agency:

  • Needs to provide for scalability and flexibility for the smallest operators
  • Must align with ICAO standards, creating new and diverging requirements for organizations with a mature ICAO-aligned SMS
  • Needs to recognize existing systems and processes, potentially resulting in the need to revise effective processes in organizations with an active SMS

“We share with the FAA the need to keep safety in focus, on the ground and in the air,” Larsen said. “We also know that the best approaches to safety systems come from collaboration between stakeholders in government and industry. NBAA has worked with the FAA on its safety planning, but we need charter companies, air-tour businesses and others to make their voices heard on this issue.”