European SMS Proposal Will Likely Affect Distributors

An EASA safety management proposal has become a vehicle for a long list of changes to the EASA regulations – changes that could impact aircraft parts distributors all over the world.

EASA has issued a Notice of Proposed Amendment (NPA) that would integrate Safety Management Systems (SMS) into Part 145 maintenance organizations.  This NPA would represent a significant change to the language of Part 145.  The introduction to the rule change is 42 pages long, and the actual rule change is 142 pages long(!)  This rulemaking document is accompanied by a sister document that modifies Part M (continuing airworthiness organizations) and also a third  document that provides an explanation as well as a regulatory impact statement.  That is a total of 432 pages of rulemaking documentation for the integration of SMS into the EASA maintenance and continuing airworthiness regulations.

Despite the length (or perhaps because of it), the rule will bear attention by everyone in the aircraft parts distribution community.  In addition to integration of the traditional SMS elements, some of the areas where there are changes being made that will likely affect aircraft parts distributors include:

  • Standard parts
  • Raw materials and consumable parts
  • Traceability
  • Packaging requirements for parts and labeling requirements for the packaging
  • Control and disposition of unserviceable components
  • Return of data plates and serial numbers (for mutilated parts) to manufacturers

The proposal also appears to impose on Part 145 certain continuing airworthiness obligations that are traditionally delegated to Part M organizations.

EASA has asked for comments using the automated Comment-Response Tool (CRT).   The deadline for submission of comments is April 22, 2013.

References:

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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