The Introduction of SMS into FAA Part 145 Approved Repair Stations

Monday, April 22, 2024

Written by Senior Consultant, John Elkin

The FAA is still on the fence about whether to insist that all 5,000 certified repair shops have safety management systems (SMS), but many U.S. shops operate globally, so they don't really have a choice.

Transport Canada (TC) and the European Union Aviation Safety Agency (EASA) already require MROs to have safety management systems in place. While TC doesn't cover all shops yet, that's going to change soon. EASA's rule goes into effect December 2024, so MROs need to have their SMS set up by then.

The next update to Maintenance Annex Guidance (MAG) is expected to include SMS requirements for over 1,000 U.S. shops that have EASA approval. This update, known as MAG 10, should be published this year, and likely put into effect by 2025.

The introduction of safety management into the maintenance arena should not be a surprise for any size organisation. If you look at the requirements, you will likely find that most organisations are managing their safety although they may not have labelled their processes with a “safety” tag. Of course, ‘Aviation Safety’ & ‘Health and Safety’ (OSH) are two very different, but complementary disciplines.

If organisations in the United States of America look across the Atlantic, or indeed the Pacific, they will find examples of approved organisations who have been operating a safety management system within their 145 approved organisations for a number of years. Within that there are of course good examples, bad examples, and average examples, and US based organisations can learn from these all.

When faced with the creation of a safety system, it is very easy to focus on the catastrophic. As worrying and beguiling as this is, it may in fact blind you to more serious and fundamental issues within the organisation.

What organisations tend to miss are those low level or low severity issues and events that have a high likelihood or indeed frequency of occurrence that encourage people within the organisation to tolerate them as they ‘always happen’ or ‘it has always been like this’ and develop their own work arounds or perhaps uncontrolled and unmanaged mitigations.

If you can capture these issues and provide effective sustainable solutions to them, then the likelihood of a more severe event occurring can be very much reduced. After all, in most serious events, there has been a series of causal or contributing factors that have built up and led to the final outcome.

Managing safety is not something to be feared, rather it should be something that is seen as best practise and should be adopted with enthusiasm along with expert support. The overview of an organisation is that an effective safety management system provides, enhanced by a well-run and effective quality or compliance monitoring system will, with a small amount of care, not only increase safety in all areas but also help to proactively identify wastes and introduce business efficiencies that can save money, and improve reputation along with other benefits such as staff satisfaction and retention.

At Baines Simmons we have a proven track record of providing world leading training, consulting, and managed support in this area, along with all those that interact and interface with maintenance organisations. If you would like to have a conversation about what we could do to help you get ahead of the game, look at the good practises that you already have, identify any gaps, and ensure that your organisation moves beyond compliance to performance in a controlled, compliant, and efficient way, please get in touch - we'd love to hear from you.