FBO Industry Insights from the NBAA S&D Conference
/The annual NBAA Schedulers & Dispatchers (S&D) Conference offers a great opportunity to catch up with FBO clients, associates and leaders in order to get a feel for the pulse of the industry as well as issues that could impact policy and procedural changes. This year’s rendition, March 12-14 in Ft. Worth, TX, was no exception.
During the conference, we deciphered the following insights that could potentially impact the present and future of the FBO industry:
The FAA Part 139 SMS (Safety Management System) for Airports Rule
EASA’s Proposed EU-Wide Regulation on Ground Handling
For the purpose of this blog post, we will first discuss the FAA Part 139 SMS for Airports Rule and follow-up in our next blog post with an insight on the proposed EU-wide regulation on ground handling.
FAA Part 139 SMS for Airports Rule
Although the FAA Part 139 SMS for Airport Rule was published about a year ago, the buzz about implementing the rule continues to accelerate throughout the FBO industry. Given a specific time period to implement, FBOs at certain Part 139 airports are beginning to double down on their efforts to implement their own Safety Management System (SMS), if they have not done so already.
That is because the affected Part 139 Airports, as part of their SMS plan requirements, must vet their on-field suppliers of aviation services to include FBOs. Therefore, having an SMS in place is an important step for FBOs to take in order to demonstrate their ability to mitigate risk.
The final FAA Part 139 rule is somewhat complex due to the various sizes of the airports that are affected. To simplify for this blog post, the rule is applicable to the largest commercial airports first. The FAA uses the following criteria to determine which Part 139 airports fall under the new rule:
Be a Part 139 certificate holder.
Be classified as a hub or have an average of 100,000 operations per year.
Or conduct international operations other than General Aviation (GA) traffic.
With these criteria in place, about two hundred airports are currently affected.
To further explain the process, Part 139 is broken down into subparts A, B, C, D, and now the rule adds subpart E. Subpart E can be broken down into three categories: 401, 402 and 403.
Category 401 addresses applicability and identifies the types of airports that may be eligible for a waiver from the SMS requirements.
Category 402 defines the four components of the Part 139 SMS and identifies the minimum requirements of each SMS component composition:
1. Safety policy
2. Safety risk management
3. Safety assurance
4. Safety promotion
Regarding category 402, it should be noted that the composition of the SMS includes the standards agreed to by all international agencies: ICAO, EASA, FAA, etc. It establishes and maintains a safety reporting system so that the airports could have a just culture where there is no blaming the reporter for reporting something.
In other words, the reporting is done anonymously, or it is done in confidence so that there are no repercussions where the messenger is punished. The reporting system is vital and the data should be reported regularly to the accountable executive.
Per category 403, each Part 139 airport certificate holder that is required to implement an SMS, must submit either an amended Airport Certification Manual (ACM) or a standalone SMS manual, in accordance with the implementation plan. This must be done no later than 12 months after the FAA has approved the implementation plan.
As stated earlier in this blog post, what is important to remember is that qualifying Part 139 airports, under this new rule, will need to vet their vendors that interact with the airport. This would include FBOs residing on the field.
The vetting process would include a review of FBO safety and operations. Having an active SMS program in place will help facilitate and validate this process.
Our experience is that FBOs that have a current IS-BAH registration are fully recognized by Part 139 airports as having in-place a robust SMS program, making the vetting process much easier. That is because IS-BAH registered FBOs have completed an independent SMS audit and are recognized as being compliant.
Looking to the future, once the first two hundred plus Part 139 qualifying airports are fully compliant with the rule, the FAA may look at smaller airports to expand the need for having an SMS plan in place. This trickledown effect could have an impact on other FBOs over time.
For further reference, please click of this link: FAA Part 139 SMS for Airports Rule.
Please leave any comments you have about this blog post below. If you have any questions, please send us an email: John Enticknap, jenticknap@bellsouth.net, Ron Jackson, ronjacksongroup@gmail.com,
ABOUT THE BLOGGERS: John Enticknap (404-867-5518) has more than 35 years of aviation fueling and FBO services industry experience and is an IS-BAH Accredited auditor. Ron Jackson (972-979-6566) is co-founder of Aviation Business Strategies Group (ABSG) and president of The Jackson Group, a PR agency specializing in FBO marketing and customer service training.
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