This act mandates that large organizations holding FAA Organization Designation Authorization (ODA) must include labor and aerospace safety representatives on their boards of directors or face revocation of their authorization.
Edward "Ed" Markey
Senator
MA
The Safety Starts at the Top Act of 2025 updates the qualifications for large organizations holding certain FAA delegations (ODA holders). Specifically, entities with over \$15 billion in annual revenue must now ensure their board of directors includes labor representatives and aerospace safety experts. The FAA is required to promptly review and rescind delegations from any current ODA holder that fails to meet these new board composition standards within 90 days of enactment.
The “Safety Starts at the Top Act of 2025” is taking aim at the biggest players in aviation manufacturing, specifically those organizations that hold an Organizational Designation Authorization (ODA). Think of an ODA holder as a company—often a major aircraft manufacturer—that the FAA has authorized to perform its own safety certifications. This bill fundamentally changes who qualifies for this critical self-certification status, especially if you’re a giant in the industry.
If an ODA holder pulls in at least $15 billion in annual gross revenue, the bill mandates a major overhaul of its board of directors. These massive companies must now certify annually that their board includes four specific, non-negotiable seats: two representatives from labor organizations that represent employees directly involved in designing and building aircraft, and two representatives with proven, results-driven experience in aerospace safety. This provision (Section 2) is a direct attempt to embed safety and worker perspective right at the highest level of corporate decision-making.
For the companies affected—and there aren't many that hit that $15 billion threshold—this is a significant structural shift. It means the people who actually turn wrenches, design the software, and build the planes will have a direct voice in the boardroom, alongside seasoned safety experts. The idea is that if you put the people closest to the safety issues and the people with the most relevant expertise on the board, the company’s priorities will shift from pure quarterly profits to long-term safety integrity. For the rest of us, this is a big deal because we are the consumers of their products—the flying public.
Perhaps the most immediate and impactful part of this section is the deadline. The FAA Administrator is required to review every existing ODA holder within 90 days of the bill becoming law. If a current ODA holder is one of those $15 billion+ giants and doesn't meet these new board composition requirements, the FAA must immediately cancel (rescind) their delegation. This is a tight turn-around. Ninety days is barely enough time to schedule a board meeting, let alone restructure corporate governance and vet four highly specialized new directors. This tight deadline ensures the rule isn't phased in over years but hits the industry like a flash flood, forcing rapid compliance or loss of the ability to self-certify.
The intent here is clearly to boost safety oversight by injecting expertise and accountability at the top. However, the bill introduces a couple of practical challenges. First, the requirement for “proven experience in aerospace safety” that shows “real results” is vague. The FAA Administrator will have to define what counts as 'proven' and 'real results,' and those definitions could easily become a point of contention or legal challenge. Second, the labor requirement specifies representatives from “each labor organization” involved in design and building. If a company has multiple unions, this could quickly complicate the board composition. Ultimately, while it aims to make air travel safer by changing who makes the decisions, the bill places a heavy, immediate compliance burden on the few massive corporations it targets.