PolicyBrief
S. 1268
119th CongressApr 2nd 2025
Safety Starts at the Top Act of 2025
IN COMMITTEE

The "Safety Starts at the Top Act of 2025" mandates that large aviation companies seeking FAA authorization must include labor and safety representatives on their boards to enhance aviation safety oversight.

Edward "Ed" Markey
D

Edward "Ed" Markey

Senator

MA

LEGISLATION

New Bill Targets Boards at Big Aviation Firms: Mandates Labor, Safety Seats for $15B+ Companies

The proposed 'Safety Starts at the Top Act of 2025' aims to reshape the leadership structure at major companies involved in aircraft design and manufacturing. Specifically, it amends Title 49, Section 44736(c)(2) of the U.S. Code, setting new board composition requirements for certain entities holding an Organization Designation Authorization (ODA). ODA holders are essentially companies authorized by the Federal Aviation Administration (FAA) to perform specific certification and oversight functions on the agency's behalf.

New Faces in the Boardroom

So, what's the big change? For ODA holders pulling in $15 billion or more in annual gross revenue, this bill mandates a specific board structure. According to Section 2, these large entities must annually certify to the FAA that their board includes four specific types of members: two representatives from labor organizations (specifically, one from each union representing employees directly involved in aircraft design and manufacturing) and two individuals with 'proven aerospace safety experience.' This means companies handling critical FAA-delegated tasks, if they meet the revenue threshold, will need to ensure these voices are formally part of their top-level decision-making.

The 'Why' Behind the Mandate

The core idea seems to be embedding direct safety and labor perspectives into the governance of companies performing FAA-delegated functions. By requiring board seats for aerospace safety experts and representatives of the workforce designing and building the planes, the legislation aims to ensure these critical viewpoints influence corporate strategy and oversight, particularly concerning safety protocols and design integrity. It’s essentially adding specific checks and balances right at the corporate leadership level for these major players.

Compliance Clock and Potential Hurdles

This isn't just a suggestion; it has teeth. Section 2 requires the FAA Administrator to revoke the ODA delegation for any entity not meeting these new board requirements within 90 days of the bill's enactment. This adds urgency for large ODA holders to potentially restructure their boards. While the goal is enhanced safety oversight, questions remain. The bill doesn't explicitly define 'proven aerospace safety experience,' leaving room for interpretation. Companies will need to navigate finding qualified board members who meet these criteria and ensuring the integration of these new perspectives aligns with existing governance structures. The focus is clearly on the largest firms in the sector, given the $15 billion revenue threshold.