By Brent I. Clark and Craig B. Simonsen

Private jet plane in the blue skySeyfarth Synopsis: The FAA has gotten closer to a conceptual model for the safety management system requirements and standards that will be required for certified airports.

At the World Safety Organization International Environmental and Occupational Safety and Health Symposium this week we attended a session on the Federal Aviation Administration’s recent Supplemental Notice of Proposed Rulemaking (SNPRM) on safety management systems  (SMS) for certificated airports. 81 Fed. Reg. 45872 (July 14, 2016) . The session was presented by William G. Thompson, the OSHA/SMS Manager at the Fort Lauderdale-Hollywood International Airport.

The SNRPM was an update for the original Advanced Notice of Rulemaking, published in October 2010. 75 Fed. Reg. 62008. In its news release on the SMS update, the FAA indicated that “SMS is a formal approach to managing an organization’s safety through four key components – safety policy, safety risk management, safety assurance, and safety promotion. Through the SNPRM, the FAA proposes to integrate proactive hazard identification and risk-management based principles into the day-to-day operations at airports.”

Thompson, in his review of the updates, said that the proposal would now regulate about half as many airports, dropping from 600 covered airports to about 300. In addition, the proposal would now allow more time to submit an implementation plan, going from 6 months to 12 months, and to plan implementation, going from 18 months to 24 months.

To view public comments on the SNPRM, go using docket no. FAA-2010-0997.

For more information on this or any related topic please contact the authors, your Seyfarth attorney, or any member of the OSHA Compliance, Enforcement & Litigation Team.