April 11, 2023
The Honorable Billy Nolen
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
RE: Safety Management Systems, Docket No. FAA-2021-0419
Acting Administrator Nolen:
On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Aviation Administration’s (FAA) proposed rule regarding Safety Management Systems (SMS). TTD consists of 37 affiliated unions, including those representing aviation and mechanical crafts. Additionally, we endorse the comments filed by our affiliated union, the Transport Workers Union of America (TWU).
As TWU stated in their comments, “As SMS is expanding to cover nearly the entire airline sector, leaving repair stations out of these requirements deprives the FAA and stakeholders of vital safety information. It also incentivizes outsourcing airline maintenance operations to non-SMS properties – a significant loophole clearly not envisioned by the FAA in the original SMS rule.”
TTD agrees that all Part 145 repair stations should be covered by FAA’s SMS rulemaking. The International Civil Aeronautics Organization (ICAO) has cited SMS as a best practice, and this assessment does not change due to the location of the repair station. It is vital that all aviation and mechanical workers have confidence in the quality and safety of repairs performed at all repair stations. We strongly oppose exempting facilities outside of the United States or others from these requirements.
For these reasons, we urge the FAA to extend SMS requirements to all Part 145 repair stations. We appreciate the opportunity to comment on this proposed rule and look forward to working with the FAA in the future.