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SMS Proposed Rule: ASSE Urges FAA to Consider Existing Safety Standards

In comments sent to the Department of Transportation (DOT) on the "Safety Management System" (SMS) proposed rule, the American Society of Safety Engineers (ASSE) commends the Federal Aviation Administration (FAA) for pursuing this rule which requires FAA certificate holders, product manufacturers, applicants, and other employers with which it does business to develop safety management systems.

"Safety management systems are fully consistent with what our members know is effective in helping ensure that workplaces are safe and healthy and that an organization can achieve its other goals, whether that concerns a positive bottom line or protecting the public's interest in safe airways," said ASSE President C. Christopher Patton, CSP. "Requiring suppliers and others to meet safety requirements is not uncommon in industry and government.

"FAA's effort to require an SMS is consistent with the highest level of safety commitment," Patton wrote. "The Occupational Safety and Health Administration (OSHA) requires that companies and government agencies have in place a version of an SMS with specific elements and expectations. That a government agency like the FAA should play a role in helping advance safety among the entities with which it does business is fully consistent with ASSE’s position statement that 'government should encourage, through significant incentives and recognition, voluntary employer programs for excelling in safety and health achievement.'"

Patton, however, noted a concern that who appropriately establishes an employer's SMS is not addressed in the rule. He highlighted the need to include language in the rule that would require an SMS be done by a "competent person" as defined by OSHA as "[O]ne who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them."

"Only experienced and trained safety and health professionals have the skills to assess workplace risks and draw up an effective management system for eliminating and managing those risks," Patton said. "Appropriate professional guidance and leadership in establishing a system is a necessary element of a system’s success."

ASSE also encourages the rule to reference ANSI/ASSE Z590.2-2003: Criteria for Establishing the Scope and Functions of the Professional Safety Position, which establishes for the safety profession core competencies, certifications, credentials, levels of qualifications and credentials, and learning support resources. This standard assists employers and organizations establish and implement safety management systems.

ASSE also urged the FAA to reference appropriate voluntary consensus standards that have been adopted to advance effective safety management systems including ANSI/AIHA Z10-2005, Occupational Health and Safety Management Systems, the international consensus standards ISO/FDIS 31000 concerning risk management principles and guidelines, the IEC/FDIS 31010 concerning risk assessment techniques; and, as for the construction area, to reference several A10 standards concerning management of safety systems on construction and demolition projects, including ANSI/ASSE A10.33-2004: Safety and Health Program Requirements for Multi-Employer Projects, the ANSI/ASSE A10.38-2000 (R2007): Basic Elements of an Employer's Program to Provide a Safe and Healthful Work Environment and the ANSI/ASSE A10.39-1996(R 2005): Safety and Health Audit Program for Construction and Demolition Operations.

Go to www.asse.org for more information and a full copy of the ASSE comments on the rule.

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