Mon, Oct 26, 2009
Aircraft Electronics Association Submits Comments to FAA in
Response to ANPR
The Aircraft Electronics Association (AEA) submitted comments
to the Federal Aviation Administration last week in response to the
FAA's safety management systems proposed rulemaking.
The AEA does not support the FAA's broad-based proposal to
mandate an independent safety management system for maintenance
organizations. The AEA believes the SMS proposal is an excessive,
unwarranted and unjustified administrative burden. The AEA supports
aviation safety, and believes the proposal makes sense for the
airlines; however, while the regulations could benefit from some of
the elements of SMS, the proposal does not make sense for
single-tiered companies.
Collecting data on an unbound "concept," such as safety
management systems, is unrealistic until the agency further defines
the intended scope of the program. Based on the FAA's previous
history, the administrative burden on maintaining an independent
program is indefinable and excessive. An integrated approach to
upgrade the current regulations to include the elements of SMS is
the only manageable approach.
In addition, the agency has not clearly defined the hazard SMS
is intended to address, but rather defines SMS to address "unknown"
hazards. This mandate is not within the scope of current rulemaking
practices. Similar to its current management of manuals and
programs repair stations must maintain, the FAA is incapable of
estimating any reasonable amount of administrative burden of
developing, approving and managing an independent SMS program.
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