Update: SMS for Part 145 Repair Stations With EASA Approval

U.S. Part 145 Repair Stations with European Union Aviation Safety Agency (EASA) approval were required to fully implement their safety management systems (SMS) by Dec. 31, 2025, meaning the deadline has passed. Now the focus is on demonstrated effectiveness. Regulators are no longer looking at plans, they’re evaluating performance.

Commitment

Failure to have a fully developed SMS program may incur findings or lead to revocation of EASA approval during:

• EASA oversight activities
• FAA surveillance
• This falls in line with all other aviation compliance issues: Say what you will do, then do what you say.

Key to Success: Recordkeeping

The difference between SMS success and failure could come down to recordkeeping, evidence of implementation and attention to detail. NBAA Safety Committee member Amanda Ferraro, CEO of Aviation Safety Solutions, offered a word of advice to those in the early stages of SMS: “Be ready to demonstrate clear, organized and current evidence of SMS implementation – not just intent.

Organizations should be prepared to show how SMS is being implemented in practice, consistent with the documented processes and procedures. In other words, all SMS components should be review-ready for oversight by FAA or EASA authorities,” she said. The core SMS documentation consists of the SMS manual, integrated with Part 145 procedures.

Safety reporting initiates the safety risk management (SRM) process. Reported hazards are reviewed, documented and assessed for risk severity and likelihood using the approved methodology. Then mitigations are implemented, tracked and verified for effectiveness. Once risks are assessed and mitigations are implemented through SRM, the safety assurance process verifies that those mitigations are working as intended. Internal audits of operations serve as a key safety assurance tool, providing a structured and planned method to evaluate compliance with procedures, effectiveness of risk controls, and consistency of operational execution.

Training and qualification records support SMS effectiveness and regulatory compliance. SMS training should be role-based and documented so maintenance personnel, supervisors and management understand their SMS responsibilities.

Internal auditor records should verify qualifications, competency and independence through documented training and certificates. Emergency response preparedness (ERP) training records should demonstrate that employees understand their emergency roles and that leadership is qualified to manage crisis response, coordination, and communication.

ERP supports operational resilience. ERP exercise records should document exercises conducted, after-action reports, lessons learned and follow-up actions. Exercises should also include relevant external partners to validate coordination, communication and response capabilities.

It’s Mission Critical

Repair stations should shift their mindset from “meeting the rule” to using SMS as a management tool.

Jet Logistics Inc. President and Director of Operations W. Ashley Smith understands the importance of SMS. He offers the following advice to other 145s: “The concepts are simple. The execution is simple. You don’t need to spend huge sums of money on expensive and elaborate software solutions,” Smith said.

SMS is no longer a “nice thing to have.” It’s mission critical. EASA has made it clear that non-compliance with referenced requirements can lead to revocation of the EASA 145 approval.

Review NBAA resources for safety management systems at nbaa.org/sms.