FAA recently published Notice N8900.7, Revision Order 8300-10, Vol. 2, Chap. 65 and Vol. 3, Chap. 37.”Monitor Continuous Analysis and Surveillance program/revisions which is designed to address some of the oversight failures on the part of inspectors. The changes were designed to focus more attention on continuous assessment of the CAS system, which needs to be expanded. A new SMS?
Some in the industry might suggest that all of the above mentioned safety management systems be scrapped at once and integrated into one huge safety management system. Would this be a convenient solution? Or maybe we should forget about a new SMS and simply substitute all of the present systems as one group and call it the safety management system?
There is no point in starting a whole new system without scrapping all the present marginal safety systems that have been haphazardly imposed on the industry.
Federal Register Vol. 74 No. 140
FAA addresses this proposed SMS in the above captioned Federal Register.
It is asking for your comments regarding a new SMS and for input on a specific number of questions outlined in the proposed rule text.
In particular, the FAA asks for your opinion, among others, on how all of the above mentioned safety systems can be integrated into a broader SMS and thus avoid duplication. Duplication in my opinion might be avoided by simply getting rid of the old and starting with a newly designed system.
A new rule making committee (ARAC) will make recommendations regarding this new SMS. If interested in objecting to or supporting this process you should join the rule making committee and/or put in your opinions on the matter.
Go to http://www.regulations.gov and follow the instructions for sending your comments on this subject via email. You can also fax to (202) 493-2251. Re: Docket #2009-0671.
Other comments to firstname.lastname@example.org.
Stephen P. Prentice is an attorney whose practice involves FAA-NTSB issues. He has an Airframe and Powerplant certificate, is an ATP rated pilot, and is a USAF veteran. E-mail: email@example.com