Part 5 sms compliance FOR 145 rEPAIR STATIONS

Safety Management Systems (SMS) are transforming aviation maintenance, but do FAA Part 145 repair stations need them? As of April 2024, the FAA’s Part 5 rule does not mandate SMS for repair stations, focusing instead on Part 135 operators, Part 91.147 air tour operators, and certain Part 21 manufacturers. This decision, finalized after extensive industry feedback, reflects concerns from groups like the Aircraft Electronics Association (AEA) and ARSA about the cost and redundancy of SMS compared to existing quality management systems (QMS). The FAA’s exclusion aligns with a 20-year-old precedent where a proposed QMS rule failed due to economic challenges, suggesting SMS may face similar hurdles for repair stations.

Despite this, voluntary adoption through the FAA’s SMS Voluntary Program (SMSVP) offers significant benefits. An SMS integrates four core components—safety policy, risk management, safety assurance, and safety promotion—plus FAA-specific documentation requirements. These elements help repair stations proactively identify hazards, streamline operations, and enhance safety culture. For U.S. repair stations, joining the SMSVP can also prepare you for international regulations, particularly if you hold or seek EASA Part 145 approvals. The program aligns with International Civil Aviation Organization (ICAO) standards, ensuring your safety practices meet global expectations.

Voluntary SMS adoption can also boost your competitive edge. Clients and regulators value proactive safety measures, and an SMS demonstrates your commitment to excellence. With the FAA requiring SMSVP participants to update their systems by May 28, 2025, now is the time to explore this option. Our team can guide you through the process, ensuring compliance with FAA standards and readiness for future regulatory shifts. Contact us to learn how SMS can elevate your repair station’s operations.

For U.S. Part 145 repair stations with EASA approvals, Safety Management Systems are not optional—they’re mandatory. The European Union Aviation Safety Agency (EASA) requires all Part 145 maintenance organizations, including those in the U.S. under the U.S.-EASA bilateral agreement, to implement an SMS compliant with ICAO Annex 19. This mandate, effective for EU-based organizations since December 2, 2022, extends to U.S. repair stations via amendments to BASA Annex 2, as outlined in Bilateral Oversight Board Decision No. 13 (February 2024). Existing EASA-approved repair stations must comply by December 31, 2025, while new applicants face immediate requirements upon the amendment’s signing.

The U.S.-EASA Maintenance Annex Guidance (MAG) is evolving to enforce this requirement, with updates expected in MAG Change 10. The FAA’s SMS Voluntary Program serves as an accepted compliance pathway, allowing U.S. repair stations to develop a single SMS that satisfies both FAA and EASA standards. This alignment reduces duplication, but non-compliance risks losing EASA approval, limiting your ability to service European clients. ARSA and AEA are advocating for a smooth transition, urging regulators to integrate SMS into existing QMS frameworks to minimize costs.

EASA’s SMS mandate reflects a global trend toward standardized safety practices, with countries like Japan leading the way for decades. For U.S. repair stations, adopting an SMS now ensures you stay ahead of regulatory changes and maintain market access. Our free SMS compliance checklist can help you assess your readiness and plan for the December 2025 deadline. Download it today to safeguard your EASA approval and strengthen your global operations.

Implementing a Safety Management System for your FAA Part 145 repair station—whether voluntary for FAA’s SMSVP or mandatory for EASA compliance—requires careful planning but delivers lasting benefits. An SMS enhances safety, streamlines compliance, and aligns with global standards, but AEA and ARSA have raised valid concerns about costs and overlap with existing quality systems. By following a structured roadmap, you can address these challenges and build an effective SMS tailored to your operations.

Start with a gap analysis to compare your current processes against FAA Part 5 or EASA Part 145 SMS standards. Focus on the four SMS pillars: establishing a clear safety policy, identifying and mitigating risks, monitoring safety performance, and promoting a safety culture. Next, develop an SMS manual, leveraging FAA’s Advisory Circular (AC) 120-92D, available at drs.faa.gov, for guidance. Train your team on hazard reporting and SMS procedures, using third-party providers for efficiency. Test your system through internal audits, then submit a declaration of compliance to your FAA office, as required for SMSVP or EASA approval.

The  below compares FAA and EASA SMS requirements to clarify your obligations:

1. AspectFAA Part 5EASA Part 145SMS RequirementVoluntary (SMSVP)Mandatory for EASA approvals
   
2. Compliance DeadlineMay 28, 2025 (SMSVP updates)Dec 31, 2025 (existing approvals)
   
3. ScopePart 135, 91.147, 21 organizations All maintenance organizations 

For EASA-approved stations, start implementation early to meet the 2025 deadline. For voluntary adopters, SMS strengthens your safety record and market position. 

Our compliance specialists can create a customized SMS plan, minimizing costs and maximizing efficiency. Reach out today to get started.