Aerospace Industries Association of America, Inc. 

1000 Wilson Blvd., Suite 1700, Arlington, VA 22209 

Tel (703) 358-1000 Fax (703) 358-1011 

Internet: http://www.aia-aerospace.org 

General Aviation Manufacturers Association

Internet: http://www.GAMA.aero 

Rond Point Schuman 6 

B-1040 Brussels, Belgium 

Tel +32 (0) 2 234 77 09 

1400 K Street NW, Ste 801 

Washington, DC 20005 

Tel +1(202) 393-1500 

January 20, 2011 

Scott Van Buren 

Chief System Engineer for Aviation Safety 

Office of Accident Investigation and Prevention (AVP) 

Federal Aviation Administration 

800 Independence Avenue, SW., 

Washington, DC 20591 

SUBJECT: AIA/GAMA Request for Comment Extension to NPRM 10-15, 

Safety Management Systems (Docket No. FAA–2009–0671) 

The Aerospace Industries Association (AIA) and General Aviation Manufacturers Association 

(GAMA) represent manufacturers of commercial and general aviation aircraft, engines, avionics 

and components who also provide airworthiness and maintenance services to nearly every 

commercial and general aviation operator in the U.S. AIA/GAMA respectfully request the 

Federal Aviation Administration (FAA) extend the comment period for the review of NPRM 10-

15, Safety Management Systems [SMS] for Part 121 Certificate Holders (75FR68224) for an 

additional 60-days, as it is necessary in the interest of the aviation organizations that may be 

directly affected by this proposed rule and the traveling public. AIA/GAMA offer the following 

comments in support of this request. 

This NPRM proposes to establish a brand new FAR part 5, creating a general framework for 

SMS requirements with initial applicability to require each part 121 air carrier to develop and 

implement an SMS. However, the FAA clearly states that "Although this proposal extends only 

to part 121 operators, the FAA has developed these general requirements with the intent that in 

the future, they could be applied to other FAA-regulated entities, such as part 135 operators, 

part 145 repair stations, and part 21 aircraft design and manufacturing organizations and 

approval holders, consistent with ICAO requirements... FAA solicits comments on possible 

future application of these general requirements (75FR68232).” This proposal and the new part 

5 will serve as the foundation for SMS requirements for the foreseeable future, so it is extremely 

important that it’s initial establishment take due consideration of its intended application across 

the broader industry. 

AIA/GAMA are submitting this request for an extension to the comment period because we 

believe it is necessary in order to provide an adequate opportunity for our member companies 

and all other FAA-regulated entities, such as part 145 repair stations and part 21 aircraft design 

and production approval holder organizations. The additional time is necessary for industry 

outreach to assure that there is awareness of this NPRM and understanding that although the 

title extends only to part 121 operators, FAA states on the ninth page of the proposal the intent 

to apply these requirements to many other organizations in the future and specifically requests 

their comments. 

GAMA 11-09 
AIA/GAMA Request for Comment Extension, NPRM 10-15 Safety Management Systems Page 2 of 3 

January 20, 2011 

The SMS proposal is a significant rule in terms of its complexity and potential impact upon 

nearly every facet of an aviation organization including safety, regulatory compliance and 

business management decision making processes. There is a significant "learning curve" for 

any organization who wishes to comment upon this NPRM to understand the proposed 

requirements, obligations and costs, and intended benefits associated with SMS. Adequate 

time is necessary for industry to become familiar with the proposal and to provide substantive 

comments and recommendations which results in better rules in the interest of aviation safety 

and the traveling public. 

Equally important are comments and questions raised by industry to ensure a common 

understanding of the intent of the regulatory language and methods of compliance. This 

information needs to be clearly communicated during this rulemaking process so as to ensure 

efficient implementation which will achieve the desired benefits. Part 5 are performance-based 

requirements with the objective of providing scalability and flexibility across a broad range of 

organization size and complexity and to recognize processes that companies already have in 

place. Therefore, it is particularly important that FAA receive comments from the broadest 

range of companies possible. The NPRM references related draft documents (initial regulatory 

evaluation, AC120-92-NPRM, and Order 8900.1 Chapter X) available from the docket, which 

provide a lot of information regarding FAA’s interpretation and envisioned implementation of the 

proposed SMS requirements. However, additional time is necessary if industry is to be able to 

perform an adequate review and comment to these draft documents. 

The FAA Aircraft Certification Service (AIR) has been developing a manufacturer SMS (MSMS) 

pilot program to build experience with the practical implementation of SMS requirements upon 

part 21 design and production organizations. AIR plans to make the MSMS implementation 

tools and guidance available on the FAA’s website once the initial kick-off meetings with the first 

pilot program company is completed next week. These MSMS pilot materials will provide 

significant information and understanding regarding the application of SMS requirements to part 

21 design and production organizations and will be very important and helpful in the 

development of substantive comments and recommendations in response to the SMS NPRM. 

Therefore, additional time is necessary for the FAA MSMS pilot implementation tools and 

guidance to be made available to industry to take into consideration. 

AIA/GAMA member companies endorse the principles and concepts of SMS and have 

supported FAA’s consideration of possible SMS requirements through participation on the SMS 

Aviation Rulemaking Committee (SMS-ARC). However, the broad range of industry sectors 

represented on the SMS-ARC have also expressed concerns about the potential difficulty, 

complexity and burden of regulatory compliance with new SMS requirements without 

commensurate safety benefit. Therefore, it is extremely important that FAA provide adequate 

opportunity for the broad industry to review and understand the SMS NPRM and related draft 

implementation materials and develop substantive comments and recommendations and raise 

questions as needed. The unfortunate timing of this NPRM having been put out for comment 

over the holiday season has only further exacerbated the limited amount of time industry has 

available for review and comment. 

AIA/GAMA respectfully request that the Federal Aviation Administration (FAA) extend the 

comment period for the review of NPRM 10-15, Safety Management Systems [SMS] for Part 

121 Certificate Holders (75FR68224) for an additional 60-days as it is necessary in the interest 

of the aviation organizations that may be directly affected by this proposed rule and the traveling 
AIA/GAMA Request for Comment Extension, NPRM 10-15 Safety Management Systems Page 3 of 3 

January 20, 2011 

public. We appreciate your consideration of this request and look forward to continued 

collaborative efforts between FAA and industry toward the development and implementation of 

safety management systems. 

Sincerely yours, 

Todd Sigler Walter Desrosier 

Asst. Vice President, Civil Aviation Vice President, Engineering & Maintenance 

Aerospace Industries Association General Aviation Manufacturers Association 

(AIA) (GAMA)

Copy: 

Peggy Gilligan 

Associate Administrator for Regulation & Certification 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591 

Tony Fazio 

Director, Accident Investigation and Prevention 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington, DC 20591