We are pleased to provide access to our discussion paper on FAA’s SNPRM regarding SMS.

On July 14, 2016, the Federal Aviation Administration (FAA) published a Supplemental Notice of Proposed Rulemaking (SNPRM) that modifies its 2010 proposal requiring airports to require a Safety Management System (SMS) for the entire airfield environment, including movement and non-movement areas.  The proposal addresses some, and ignores other, comments submitted by airports on the original proposal.  A revised version of Draft Advisory Circular (AC) 150/5200-37A, Safety Management Systems for Airports was also issued at the same time.  One significant change is that the new proposal would affect only about half, rather than all, commercial airports in the country.  For the FAA’s tentative list of affected airports, click here.  Kaplan Kirsch & Rockwell is preparing a white paper on the new proposal and assisting clients in preparing comments, which are due on September 12, 2016.  Once published, the white paper will be available on our website.  Meanwhile, please contact Peter Kirsch for further information or for assistance in preparing comments on the new SMS proposal.