S. 1268Senate119th Congress (2025-2027)In Committee

Safety Starts at the Top Act of 2025

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Updated November 24, 2025 at 1:24 AM UTC

The Safety Starts at the Top Act of 2025 changes the rules for who can hold an Organization Designation Authorization (ODA) under the Federal Aviation Administration. It adds new board‑membership requirements for large aviation firms (those earning $15 billion or more), mandating labor and safety expertise representation. The FAA must also revoke any existing ODA delegations that don’t comply within 90 days, affecting large aircraft manufacturers and other aviation organizations that hold such authorizations.

Key Provisions

For any entity with at least $15 billion in annual gross revenue that holds an Organization Designation Authorization (ODA), the FAA Administrator must require the company to certify each year that its board of directors includes:
Two representatives from labor organizations, with at least one representing workers directly involved in aircraft design and manufacturing.
Two directors who have proven experience in aerospace safety and a record of safety‑related results.
The FAA Administrator must, within 90 days of the law taking effect, cancel any ODA delegation to a company that does not meet these board‑composition requirements.

Legislative Activity

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1 earlier action

SenateIntro Referral Latest Action

Read twice and referred to the Committee on Commerce, Science, and Transportation.

Commerce, Science, and Transportation Committee

April 2, 2025

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SenateIntro Referral

Introduced in Senate

April 2, 2025

SenateIntro Referral

Read twice and referred to the Committee on Commerce, Science, and Transportation.

Commerce, Science, and Transportation Committee

April 2, 2025

Bill Text

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Introduced in SenateIssued April 2, 2025

119th CONGRESS

1st Session

S. 1268

IN THE SENATE OF THE UNITED STATES

April 2, 2025

Mr. Markey introduced the following bill; which was read twice and referred to the Committee on Commerce, Science, and Transportation

A BILL

To amend title 49 of the United States Code, to revise the qualifications for organization designation authorization holders, and for other purposes.

Short title

This Act may be cited as the Safety Starts at the Top Act of 2025.

Qualifications for ODA holders

(a)

In general

Section 44736(c)(2) of title 49, United States Code, is amended to read as follows:

(2)

ODA holder

The term ODA holder means an entity that—

(A)

is authorized to perform functions pursuant to a delegation made by the Administrator of the FAA under section 44702(d); and

(B)

in the case of an entity with at least $15,000,000,000 in annual gross revenue, certifies to the Administrator, on an annual basis, that the board of directors of such entity includes—

(i)

two representatives from labor organizations, including 1 representative from each labor organization that represents the employees of such entity that are directly involved in the design and manufacturing of aircraft; and

(ii)

two representatives with proven experience in aerospace safety and demonstrable outcomes related to such experience.

(b)

Review of existing ODA holders

Not later than 90 days after the date of enactment of this section, the Administrator of the Federal Aviation Administration shall rescind any delegation made under section 44702(d) of title 49, United States Code, to an entity that does not meet the requirements under paragraph (2) of such section 44736(c)(2), as amended by subsection (a).