Your 4-Step Guide to Understanding Part 139 SMS Compliance

By |2018-07-31T22:16:16+00:00August 24th, 2016|Tags: , , |

If you’re working at a commercial airport, you’ve probably heard about the Safety Management System (SMS) proposed rule the FAA issued in July. In an effort to enhance safety and meet international standards, the FAA issued a Supplemental Notice of Proposed Rulemaking (SNPRM) to require most airports certificated under Title 14 Code of Federal Regulations Part 139 to establish an SMS.

An SMS is a formal, top-down business-like approach to managing risk. Learn more about SMS and the benefits and challenges in my previous blog post.

When the final rule is published – anticipated in 2017 – Part 139 airports will be required to update their Airport Certification Manual to meet the new regulation’s requirements for operations within the movement and non-movement areas of the airport.

So, what are the top four things you need to know about the proposed rule?

  1. The rule applies to the more than 250 US airports that fall into any of the following three categories:
    • Large, Medium, or Small Hubs in the NPIAS
    • International airports according to Customs and Border Protection’s definitions
    • Airports with more than 100,000 annual operations
  2. If your airport falls into one of these three categories, then you must create an Implementation Plan within 12 months of the effective date, and the plan must be submitted to FAA for approval.

    You must subsequently submit an SMS Manual or appropriate revisions to your Airport Certification Manual within 24 months of the effective date. The SMS program would be required to cover movement areas and non-movement areas, as well as on-airport fuel farms.

  3. The Implementation Plan would be approved by FAA to ensure it contains all relevant elements. The individual airport would then need to decide whether to create a freestanding SMS Manual or add the required SMS components to their Airport Certification Manual. The SMS (Manual or components within the Airport Certification Manual) would merely be “accepted” by FAA, with proper cross referencing to the Airport Certification Manual. Complying via an Airport Certification Manual revision would need FAA approval.

    The implementation plan will require the airports to outline their plan and schedule for how they plan to:

    • Develop their program, and train employees
    • Establish a confidential reporting system
    • Follow specific risk management processes
    • Continually monitor results
    • Identify an Accountable Executive who would have responsibility for compliance
  4. Compliance with the SMS Manual would be checked by the Airport’s Certification Inspector every year as part of the airport’s routine annual certification inspection.

Commenting on the FAA proposed ruling:

The FAA has requested feedback from the industry about the proposed rule. These sections include:

  • Applicability to airports
  • Types of data or other information Airports could report to a national database
  • How many individuals at each airport, and what types of employees, may need comprehensive training in SMS
  • How the Accountable Executive is defined
  • Whether the two-year implementation timeline is appropriate

The FAA has said the most helpful comments reference a specific portion of the proposal, explain the reason for any recommended change, and include supporting data. If you’d like to comment on a specific section, you can do so on the regulations website.

If you’d like to leave a comment but need assistance formulating them to maximize their impact, our experts can help you. Let us know how we can help you before Sept. 12, 2016.

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About the author

Ken Ibold
Ken Ibold
Ken is an aviation planner responsible for the execution of safety management systems, FAA licensed commercial spaceports, airport master plans, feasibility studies, capital improvement plan development, and airport layout plans. As an expert in aviation safety and risk management, he’s recognized as an aviation safety subject matter expert by national media. He’s a qualified facilitator for FAA Airports Division Safety Risk Management panels, and he’s authored several technical papers, articles, and two books.

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