Background When communicating with the US Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT PHMSA) an assumption is often made regarding HazMat Security Plans. The agency tends to assume one is required, catching even experienced personnel off guard when requesting renewals or undergoing an audit by the DOT. Requirements The requirement for a […]
The FAA recently published Information For Operators (InFO) 24007, clarifying the Safety Management System (SMS) compliance date. Existing US Repair Stations with an EASA certificate must implement a SMS by December 31, 2025. Maintenance Annex Guidance (MAG) Change 10, which includes the SMS requirement, must be implemented by October 10, 2025. Therefore, EASA manual supplements […]
Problem On June 4th, 2024 Tym’s LLC formally requested clarification for a Letter of Interpretation (LoI) issued by the US Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) regarding the use of Overpack for compressed gas cylinders. On January 3, 2025 the agency issued a revised Letter of Interpretation, based on our concerns. […]
Change 10 of the Maintenance Annex Guidance (MAG) between the FAA and EASA has been released. It outlines the long-awaited instructions for compliance with the Safety Management System (SMS) requirement codified in Annex 2 of the US/EU bilateral agreement EASA MAG Change 10 goes into effect on October 10, 2025… only a few months away […]
Problem On June 4th, 2024 Tym’s LLC formally requested clarification for a Letter of Interpretation (LoI) issued by the US Department of Transportation, Pipeline and Hazardous Materials Safety Administration (DOT PHMSA) regarding the use of Overpack for compressed gas cylinders. A generous portion of our website outlines this engagement here. The back-and-forth on this topic […]
After 10 months of back-and-forth with the US Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) regarding Letter of Interpretation No. 24-0010, we finally have some conclusions regarding the use of Overpack for aviation compressed gas cylinders. Tym’s Request Resulted in Revised Letter of Interpretation On January 3, 2025, the agency issued […]
If you operate a US Repair Station with an EASA Certificate, no doubt you’ve heard about the
new special condition in the forthcoming Maintenance Annex Guidance (MAG) that requires you
to establish, implement, and maintain a Safety Management System (SMS).
There are several great trade associations that assist small and medium-sized businesses with
complex regulatory requirements in their operational domain.
We receive regular requests regarding Safety Management System (SMS) implementation from
domestic FAA repair stations with EASA approval granted via the EU/US bilateral agreement.
We suspect that this will continue, and greatly increase, based on the upcoming deadline to
implement SMS for US repair stations on December 31, 2025 (as published in FAA Information
for Operators (InFO) 24007).
According to a Federal Aviation Administration (FAA) final rule published on December 18, 2024
titled ”Drug and Alcohol Testing of Certificated Repair Station Employees Located Outside of the
United States,” the FAA announced a formal requirement that international regulatory authorities
and repair stations have been dreading for years.