While the FAA has filed a “difference” explaining that it does not have a formal safety management system (SMS) rule for aircraft operators, despite ICAO's fast-approaching November 18 deadline, it is in the process of SMS rulemaking. According to an FAA spokesman, the agency is already sponsoring voluntary SMS implementation by Part 121, 135 and 145 organizations to provide learning and experience for both industry and the FAA in SMS development, implementation and oversight. He said the agency expects to publish a Part 121 notice of proposed rulemaking “in a couple of days,” and is “considering SMS regulations for...Part 135 operators and Part 145 repair stations.” The agency has admitted that both FAA inspectors and service providers are concerned about reports of Part 135 operators being denied entry into various international airports and/or airspace due to lack of an approved SMS, but said analysis revealed that it was lack of a flight-data analysis system, more commonly known as FOQA. A flight-data analysis program has been an ICAO requirement since 2005, though this requirement has not been enforced previously by ICAO member nations. The FAA is aware of several instances where the lack of FOQA has resulted in denial of airspace entry, mostly involving larger business jets, such as Gulfstreams, Falcons and Challengers, flying under Part 135 rules.