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S 1268119th CongressIn Committee

Safety Starts at the Top Act of 2025

Introduced: Apr 2, 2025
Standard Summary
Comprehensive overview in 1-2 paragraphs

The Safety Starts at the Top Act of 2025 would tighten how the FAA designates and oversees organization designation holders (ODAs) under Title 49. Specifically, it adds a governance requirement for large ODA holders. For entities with at least $15 billion in annual gross revenue, the bill requires their boards to include two labor-representation directors (at least one from each labor organization representing employees directly involved in aircraft design and manufacturing) and two directors with proven aerospace safety experience and demonstrable safety outcomes. In addition, the bill obligates the FAA administrator to rescind any FAA delegation to an entity that does not meet these new requirements within 90 days after enactment. The intent is to strengthen safety oversight by embedding labor voices and established safety credentials at the top levels of large ODA holders, and to quickly remove non-compliant ODAs from FAA delegations.

Key Points

  • 1An ODA holder is an entity authorized by the FAA to perform certain functions under a delegation of authority (section 44702(d) of Title 49).
  • 2For large entities (at least $15,000,000,000 in annual gross revenue), the board must include:
  • 3- Two representatives from labor organizations, with at least one representative from each labor organization representing employees directly involved in aircraft design and manufacturing.
  • 4- Two representatives with proven aerospace safety experience and demonstrable safety outcomes.
  • 5The FAA Administrator must rescind any delegation under section 44702(d) to an entity that does not meet these new requirements no later than 90 days after enactment.
  • 6The act is titled the “Safety Starts at the Top Act of 2025” and specifically amends section 44736(c)(2) of Title 49.

Impact Areas

Primary group/area affected:- Large ODA holders (those with $15B+ in annual gross revenue) and the FAA’s oversight of aircraft design/manufacturing functions.Secondary group/area affected:- Labor organizations representing employees in aircraft design and manufacturing.- Aerospace safety professionals and individuals with demonstrated safety outcomes.Additional impacts:- Potential disruption or restructuring for existing ODAs that do not currently meet the new board composition requirements, given the 90-day rescission window.- Increased governance and compliance costs for large aerospace firms; potential changes in corporate governance and safety culture.- Possible broader implications for suppliers and customers who rely on ODA-backed design/manufacturing activities, given potential shifts in delegations.
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