Wed, Mar 09, 2011
Supports Incident Management, Risk-Based Analysis Concepts
In comments to the FAA Monday regarding its proposal to mandate
Safety Management Systems (SMS) for air carriers, the Aircraft
Electronics Association (AEA) objected to the proposal as
written while supporting the general concept of incident management
and using a risk-based analysis for strategic regulatory
decisions.
Among the objections of the AEA are that they contend SMS and
labor agreements are not compatible. The accidents and incidents
cited in the NPRM suggest that there are inherent risks in the
negotiated labor agreements within the airlines. The Association
points out that if negotiated labor agreements take precedence over
proper risk assessment and mitigation strategies, SMS had failed
before it begins.
AEA also says the regulation as proposed is undefined. The
proposal defines Hazard as "a condition that can lead to injury,
illness or death to people; damage to or loss of a system,
equipment, or property; or damage to the environment." ICAO binds
their definition of hazard within the criterion of Annex 6; safe
operations of aircraft. By establishing an independent new Federal
Aviation Regulation (FAR) Part 5, the FAA has chosen to be vague
and misleading in its scope of aviation hazards which will lead to
misinterpretation and over-regulating.
And finally, the Association says it is disappointed with
the Agency for this misleading representation of the "independent"
ICAO mandate. The Agency's portrayal of this mandate as if it is
completely governed by an independent international body (ICAO) is
false and misleading to the American public and should be
thoroughly reviewed by the Office of Management and Budget, Office
of Information and Regulatory Affairs.
AEA says the SMS proposal as written will lead to differing
interpretations. There is no way to objectively enforce this rule.
The proposal mandates a Safety Management System; however, it does
not define the safety goal that SMS is intended to achieve. As
defined in the ICAO Annex 6 criteria, SMS is a path to enhance the
overall industry system safety mandate. The FAA's proposal does not
assume this logical approach to SMS, but rather the Agency proposes
and markets SMS as a product in and of itself.
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