NBAA Examines FAA’s Proposed SMS Rulemaking, Calls for Comment Period Extension

Contact: Dan Hubbard, 202-783-9360,

Washington, DC, Jan. 18, 2023 – The National Business Aviation Association (NBAA) continues to review a notice of proposed rulemaking (NPRM) to extend requirements for implementing a new safety management system (SMS) beyond Part 121 airline operators to other commercial aviation entities, including many business aircraft operations.

The NPRM, issued Jan. 10 by the Federal Aviation Administration (FAA), would update and expand 14 CFR Part 5 SMS requirements to certain Part 21 certificate holders, Part 135 air charter operations and companies holding a letter of authorization to conduct air tour operations under Part 91.147.

Review the FAA’s SMS NPRM.

SMS can assist operators in proactively identifying potential hazards and ensuring that a process is put in place to effectively manage them. The FAA has required U.S. airlines to implement SMS since 2018, with Congress calling on the agency in 2020 to extend those requirements to other commercial aviation operations.

“Safety is a core value for the business aviation community, and for nearly two decades, NBAA has been strongly supportive of the benefits that stem from the adoption of SMS,” noted association Director, Safety and Flight Operations Mark Larsen, CAM. “Further, NBAA’s participation on the FAA’s SMS Aviation Rulemaking Committee in 2010, and our contributions to that panel’s final report, helped to shape current SMS requirements.”

An effective, structured SMS is also at the core of the International Standards for Business Aviation Operations, or IS-BAO. Established by the International Business Aviation Council and its member associations, IS-BAO is a recommended code of best practices designed to help flight departments worldwide achieve high levels of safety and professionalism.

“We’ve seen how SMS directly benefits the safety of business aviation stakeholders that have adopted such programs voluntarily,” Larsen continued. “Their experiences also highlight that, for any SMS to be a truly effective solution, it must be tailored to the size and complexity of the operation. Our review of the FAA’s NPRM will closely examine if such scalability would be possible under the changes proposed by the agency.”

Citing the extensive scope of operations affected by the proposal, Larsen further called on the FAA to extend the public comment period for the NPRM past the current March 13, 2023, deadline.

“We believe industry has a crucial role to play in helping make SMS a workable solution for the broad array of operations that would be affected by this proposal,” he said. “Additional time will be needed to fully evaluate the proposed additions for Part 5 and their impact on affected stakeholders.”


Founded in 1947 and based in Washington, DC, the National Business Aviation Association (NBAA) is the leading organization for companies that rely on general aviation aircraft to help make their businesses more efficient, productive and successful. The association represents more than 10,000 company and professional members and provides more than 100 products and services to the business aviation community, including the NBAA Business Aviation Convention & Exhibition (NBAA-BACE), the world’s largest civil aviation trade show. Learn more about NBAA at

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