FAA Expands SAS to Include Part 147 Certificate Holders

**Updated Oct. 21, 2020***
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The Safety Assurance System (SAS) is an FAA oversight tool for certification and surveillance. It is most well known by industry as a software tool to collect data through utilization of Data Collection Tools (DCTs). The purpose of the program is to facilitate a risk-based, data-supported approach to oversight and standardize evaluation protocols.

Part 135, 142, and 145 certificate holders are currently subject to the SAS approach. Representatives of those sectors have argued that implementation missed the mark given questions are not weighted and therefore the system does not ensure resources are focused on the most vulnerable. Industry also contends that the prescriptive nature of the DCTs is contrary to the FAA’s movement towards performance-based rules, and that the majority of the questions are based in guidance and policy, not in regulations.

While the FAA contends that "SAS is not a separate safety standard and does not impose additional requirements on certificate holders," those subject to the oversight system have raised concerns that while industry's use of the portal is "voluntary," the DCT's are not optional for the safety inspectors and there is an unspoken expectation that the certificate holders complete them, especially if it means assisting the inspector in an expeditious document review.

For part 147 holders, the expansion could mean more man hours required for certification and/or FAA audits. (For example, a charter operator reported that it was asked to complete over 570 SAS questions in response to its request for an operations manual revision.) Given those realities, industry has asked the FAA to add industry representation to FAA internal SAS groups, or at the very least develop a list of stakeholders to provide feedback on how to improve the system.

While ATEC engages with regulators on these issues, the community is encouraged to review the SAS elements applicable to part 147 certificate holders, and report back concerns or comments:

SAS FS Data Collection Tools (DCTs)
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DCTs applicable to part 147 certificate holders: 

• SP 1.0 147K AW Organizational Management (6 - 9/8/20)
• ED 1.1.6 147K AW Safety Program (5 - 5/28/20)
• EP 1.1.6 147K AW Safety Program (5 - 3/19/20)
• ED 1.3.1 147K AW Part 119 Required Personnel (4 - 5/28/20)
• EP 1.3.1 147K AW Required Personnel (4 - 5/28/20)
• ED 1.3.4 147K AW Computer-Based Recordkeeping System (4 - 5/28/20)
• EP 1.3.4 147K AW Computer-Based Recordkeeping System (3 - 5/28/20)
• ED 1.3.5 147K AW AMTS Certificate Requirements (3 - 5/28/20)
• EP 1.3.5 147K AW AMTS Certificate Requirements (3 - 5/28/20)
• EP 1.5.1 147K AW Accountable Executive (1 - 12/27/19)
• EP 1.5.2 147K AW Emergency Response (1 - 12/27/19)
• EP 1.5.3 147K AW SMS Recordkeeping (1 - 12/27/19)
• SP 4.0 147K AW Technical Operations (6 - 9/8/20)
• ED 4.1.5 147K AW AMTS Training of Mechanics (5 - 5/28/20)
• EP 4.1.5 147K AW AMTS Training of Mechanics (5 - 5/28/20)
• ED 4.5.4 147K AW Housing and Facilities (5 - 5/28/20)
• EP 4.5.4 147K AW Housing and Facilities (4 - 5/28/20)​