Quality Assurance, Safety Management Systems and the FAA

The FAA has finally released its FAR Part 145 Notice of Proposed Rule Making (NPRM) 2006-26408. The NPRM was initially issued in 2006 and withdrawn in 2009 because the FAA felt it did not adequately address the current repair station operating environment. The new proposal covers three major areas plus several other changes
1. The system of Ratings.
2. The certification Requirements.
3. Repair stations providing maintenance to air carriers.

The original 2006 NPRM proposed a requirement for a formal Quality System to improve safety, this requirement is not included in this proposed NPRM. The rationale is that the FAA is developing the Safety Management Systems (SMS) rules and those will cover repair stations operating under Part 145. It is felt that if a Quality System is mandated now it will have to be modified once SMS rules are produced, which is not an efficient use of repair station resources.

SMS requires compliance with the following requirements
1. Identify safety hazards, assess and mitigate risks.
2. Ensure that remedial action necessary to maintain an acceptable level of safety is implemented.
3. Provide for continuous monitoring and regular assessment of the safety level achieved.
4. Aim to make continuous improvement to the overall level of safety.
However SMS requires a Quality Assurance Program and policy that is consistent with and supports the fulfilment of the activities of SMS, including annual internal audits.

In the original NPRM the FAA proposed an expansion of the existing Quality Control system to include a Quality System that assures compliance with regulations and internal processes and procedures. Any findings are addressed and corrections/corrective actions taken to ensure compliance and improve the effectiveness of the procedures. It also requires management oversight and follow up to ensure effective corrective actions and continuous improvement. This requires an internal annual audit plan and periodic management reviews.

SMS requires a Quality Assurance system, but it is directed towards the safety function, and does not cover the other aspects of the operation. It can be argued that all actions or inactions affect safety and therefore SMS will mandate by default an all encompassing Independent Quality Assurance regime.

Considering that the origins of this NPRM date back to 1999 and has been issued and withdrawn several times; to wait for the release of the SMS rules could mean a wait of a few more years and a QA System will not be mandated until the turn of the decade.