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Safety Management System Implementation Guide

Comprehensive guide to developing and implementing an effective SMS for Part 135 operations

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About SMS Four Pillars of SMS Implementation Process Documentation Tools & Templates Sustaining SMS SMS Training Industry Best Practices SMS in Jetfolio Common Deficiencies

About Safety Management Systems

What is a Safety Management System?

A Safety Management System (SMS) is a formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of safety risk controls. It includes systematic procedures, practices, and policies for the management of safety.

SMS Definition (ICAO)

"A systematic approach to managing safety, including the necessary organizational structures, accountabilities, responsibilities, policies, and procedures."

Why SMS for Part 135 Operators?

Benefits of SMS Implementation

  • Proactive Safety: Identify and mitigate hazards before they cause incidents
  • Data-Driven Decisions: Make safety decisions based on actual operational data
  • Regulatory Compliance: Meet current and future FAA requirements
  • Cost Reduction: Fewer accidents and incidents reduce insurance and operational costs
  • Safety Culture: Build organizational culture focused on continuous safety improvement
  • Competitive Advantage: Demonstrate safety commitment to customers and stakeholders
  • Risk Management: Systematic approach to identifying and controlling operational risks

Is SMS Required for Part 135?

Yes — the deadline is 28 May 2027

The 2024 SMS final rule extended 14 CFR Part 5 to Part 135. § 5.1(b) applies Part 5 to any person holding or applying for a Part 119 certificate authorizing Part 135 operations — there is no seat-count threshold and no on-demand carve-out.

What § 5.9(a) requires of an existing certificate holder:

  • § 5.9(a)(1): “Develop and implement an SMS that meets the requirements of this part no later than May 28, 2027.”
  • § 5.9(a)(2): Submit to the FAA “a declaration of compliance with this part in a form and manner acceptable to the Administrator no later than May 28, 2027.”

Operators certificated on or after 28 May 2024 do not get the transition window — they must have a conforming SMS from the outset.

Where that leaves you today

Until 28 May 2027 an existing Part 135 certificate holder is not yet in violation for operating without a conforming SMS, so participation is effectively voluntary in the interim. It is not optional in the long run, and the declaration of compliance falls due on the same date as implementation — there is no grace period between building the system and attesting to it. Treat the transition window as build time, not as an exemption.

SMS Regulatory Framework

The Four Pillars of SMS

Every SMS is built on four foundational pillars, each containing specific components that work together to create a comprehensive safety management framework.

Pillar 1: Safety Policy

Safety Policy & Objectives

Purpose: Establish management commitment and organizational approach to safety management.

Components:

  • 1.1 - Management Commitment
    • Written safety policy signed by accountable executive
    • Clear statement of commitment to SMS and continuous improvement
    • Resources allocated to support SMS
    • Safety as core organizational value
  • 1.2 - Safety Accountability & Responsibilities
    • Accountable Executive identified
    • Safety roles and responsibilities documented
    • Safety Action Group established
    • Authority and accountability clearly defined
  • 1.3 - Appointment of Key Safety Personnel
    • Safety Manager designated
    • Qualifications and authority documented
    • Direct access to Accountable Executive
  • 1.4 - Emergency Response Plan (ERP)
    • Comprehensive ERP developed
    • Contact lists maintained
    • Procedures tested periodically
    • Coordination with external agencies
  • 1.5 - SMS Documentation
    • SMS Manual developed
    • Policies and procedures documented
    • Records management system established

Pillar 2: Safety Risk Management

Safety Risk Management (SRM)

Purpose: Identify hazards and manage safety risks to acceptable levels.

Components:

  • 2.1 - System Description & Analysis
    • Operational processes documented
    • Interfaces and dependencies identified
    • System boundaries defined
  • 2.2 - Hazard Identification
    • Multiple hazard identification methods
    • Proactive hazard reporting encouraged
    • Safety data sources identified
    • Continuous hazard identification process
  • 2.3 - Safety Risk Assessment
    • Risk assessment methodology defined
    • Risk matrix developed (probability vs. severity)
    • Risk tolerability criteria established
    • Risk assessment performed for identified hazards
  • 2.4 - Safety Risk Mitigation
    • Risk control strategies developed
    • Mitigation effectiveness evaluated
    • Residual risk assessed
    • Risk acceptance decisions documented

Pillar 3: Safety Assurance

Safety Assurance (SA)

Purpose: Evaluate the continued effectiveness of implemented risk controls and support identification of new hazards.

Components:

  • 3.1 - Safety Performance Monitoring & Measurement
    • Safety Performance Indicators (SPIs) established
    • Safety Performance Targets (SPTs) set
    • Data collection systems implemented
    • Continuous monitoring of safety performance
  • 3.2 - Management of Change
    • Change management process documented
    • Safety impact assessments for changes
    • Approval process for operational changes
  • 3.3 - Continuous Improvement
    • Internal evaluations and audits
    • External audits
    • Corrective action tracking
    • Lessons learned documented and shared

Pillar 4: Safety Promotion

Safety Promotion

Purpose: Create a positive safety culture through training, communication, and employee engagement.

Components:

  • 4.1 - Training & Education
    • SMS training program developed
    • Initial SMS training for all employees
    • Recurrent SMS training
    • Role-specific SMS training
    • Training records maintained
  • 4.2 - Safety Communication
    • Safety communication plan developed
    • Multiple communication channels established
    • Regular safety bulletins/newsletters
    • Safety meeting structure
    • Feedback mechanisms

SMS Implementation Process

Phased Implementation Approach

SMS implementation is typically accomplished in four phases over 1-3 years, depending on organizational size and complexity.

Phase Focus Duration Key Deliverables
Phase 1 Planning & Policy 2-4 months Gap analysis, SMS Manual, Safety Policy, organizational structure
Phase 2 Reactive Processes 4-6 months Reporting system, investigation processes, corrective actions
Phase 3 Proactive/Predictive 6-12 months SRM processes, SPIs/SPTs, data analysis capabilities
Phase 4 Continuous Improvement Ongoing Mature SMS, continuous monitoring, culture of safety

Detailed Implementation Timeline

Months 1-2: Planning & Gap Analysis

  • Secure management commitment and resources
  • Appoint Accountable Executive and Safety Manager
  • Conduct gap analysis (current state vs. SMS requirements)
  • Develop implementation plan with timeline and milestones
  • Establish Safety Action Group (SAG)
  • Begin SMS awareness training for management

Months 3-4: Safety Policy & Documentation

  • Draft and approve Safety Policy
  • Document safety roles and responsibilities
  • Begin development of SMS Manual
  • Establish SMS records management system
  • Review and update Emergency Response Plan
  • Conduct SMS awareness training for all employees

Months 5-8: Safety Risk Management Foundation

  • Document operational processes and interfaces
  • Establish hazard identification methods
  • Develop risk assessment methodology and risk matrix
  • Implement safety reporting system
  • Train personnel on hazard identification and reporting
  • Begin initial hazard identification exercises

Months 9-12: Safety Assurance Development

  • Identify and define Safety Performance Indicators
  • Establish Safety Performance Targets
  • Implement data collection and analysis systems
  • Develop change management process
  • Establish internal audit procedures
  • Begin regular SAG meetings with data review

Months 13-18: Safety Promotion & Integration

  • Implement comprehensive SMS training program
  • Develop safety communication strategy
  • Launch safety newsletters/bulletins
  • Establish regular safety meetings at all levels
  • Integrate SMS into daily operations
  • Conduct first internal SMS audit

Months 19-24: Maturation & Refinement

  • Refine processes based on lessons learned
  • Demonstrate continuous improvement
  • Achieve full SMS implementation
  • Assemble the evidence for the declaration of compliance due 28 May 2027 (§ 5.9)
  • Transition to ongoing SMS maintenance mode

Critical Success Factors

Keys to Successful SMS Implementation

  • Management Commitment: Visible, active support from top management
  • Adequate Resources: Budget, personnel, and time allocated
  • Communication: Clear, frequent communication about SMS progress
  • Employee Engagement: Involve employees at all levels
  • Training: Comprehensive training for all personnel
  • Non-Punitive Culture: Focus on learning, not blame
  • Data-Driven: Make decisions based on actual safety data
  • Continuous Improvement: Treat SMS as ongoing process, not project
  • Integration: Embed SMS into existing operations, don't bolt on
  • Patience: Cultural change takes time; don't rush

Common Implementation Challenges

Challenges & Solutions

  • Challenge: "We're already safe, why do we need SMS?"
    Solution: Emphasize proactive vs. reactive safety, continuous improvement, and business benefits
  • Challenge: Lack of management buy-in
    Solution: Present business case with ROI data, regulatory trends, customer expectations
  • Challenge: Fear of punitive action for reporting
    Solution: Establish clear non-punitive policy, demonstrate with actions, protect reporters
  • Challenge: "Just another paperwork burden"
    Solution: Streamline processes, integrate with existing systems, demonstrate value
  • Challenge: Limited resources and budget
    Solution: Start small, scale SMS to organization size, demonstrate quick wins
  • Challenge: Data overload without analysis
    Solution: Focus on key metrics, use automated tools, train analysts

SMS Documentation Requirements

SMS Manual

The SMS Manual is the primary documentation of your Safety Management System. It describes your organization's approach to managing safety.

SMS Manual Structure (Recommended)

  • Chapter 1: Introduction
    • Purpose and scope of SMS
    • Regulatory requirements
    • SMS applicability
    • Manual organization and updates
  • Chapter 2: Safety Policy (Pillar 1)
    • Safety Policy statement
    • Safety objectives
    • Management commitment
    • Organizational structure
    • Roles and responsibilities
    • SMS documentation and records
  • Chapter 3: Safety Risk Management (Pillar 2)
    • System description and analysis
    • Hazard identification methods
    • Safety risk assessment process
    • Risk matrix and tolerability criteria
    • Safety risk mitigation procedures
  • Chapter 4: Safety Assurance (Pillar 3)
    • Safety performance monitoring
    • Safety Performance Indicators (SPIs)
    • Management of change process
    • Continuous improvement processes
    • Internal audits and evaluations
  • Chapter 5: Safety Promotion (Pillar 4)
    • SMS training program
    • Safety communication strategy
    • Employee engagement initiatives
  • Appendices
    • Forms and templates
    • Definitions and acronyms
    • Regulatory references

Required Records

Record Type Contents Retention
Safety Policy Current safety policy, previous versions Part of the documented SMS (§ 5.95); keep superseded versions with the change record
Hazard Reports All submitted hazard/safety reports SRM output: as long as the control remains relevant (§ 5.97(a)); Jetfolio keeps 5 years
Risk Assessments Completed risk assessments, mitigation plans SRM output: as long as the control remains relevant (§ 5.97(a)); Jetfolio keeps 5 years after the control retires
SAG Minutes Safety Action Group meeting minutes Safety assurance output: minimum 5 years (§ 5.97(b))
Safety Data SPI data, analysis results, trends Safety assurance output: minimum 5 years (§ 5.97(b))
Audit Reports Internal and external SMS audit reports Safety assurance output: minimum 5 years (§ 5.97(b))
Training Records SMS training completion records Duration of employment (§ 5.97(c))
Change Management Change requests and safety assessments SRM output: as long as the control remains relevant (§ 5.97(a)); safety communications 24 months (§ 5.97(d))

SMS Tools & Templates

Safety Risk Matrix

A risk matrix is a fundamental tool for assessing safety risks. It combines the probability of an occurrence with the severity of potential consequences.

Sample 5x5 Risk Matrix

Probability 5 - Frequent 5M 10M 15H 20H 25H
4 - Occasional 4L 8M 12M 16H 20H
3 - Remote 3L 6L 9M 12M 15H
2 - Improbable 2L 4L 6L 8M 10M
1 - Extremely Improbable 1L 2L 3L 4L 5M
1
Minor		 2
Moderate		 3
Major		 4
Hazardous		 5
Catastrophic
Severity

Risk Levels: L = Low (acceptable), M = Medium (review/mitigate), H = High (unacceptable without mitigation)

Sample Safety Performance Indicators

Example SPIs for Part 135 Operations

  • Lagging Indicators (outcome measures):
    • Accident/incident rate per 100,000 flight hours
    • Runway incursions per 10,000 operations
    • Airspace violations per year
    • Maintenance-related delays per month
  • Leading Indicators (predictive measures):
    • Number of safety reports submitted per month
    • Percentage of hazards identified proactively vs. reactively
    • Training completion rates
    • Percentage of flights with SOP deviations
    • Fatigue risk scores trending
    • Percentage of risk mitigations completed on time

Key SMS Forms & Templates

Essential Forms to Develop

  • Safety Report Form: For employees to report hazards, incidents, concerns
  • Risk Assessment Form: Template for conducting safety risk assessments
  • Change Request Form: For proposing operational or procedural changes
  • SAG Meeting Minutes Template: Standardized format for Safety Action Group meetings
  • Internal Audit Checklist: For conducting SMS compliance audits
  • Corrective Action Tracking: Template for tracking actions to closure
  • SPI Dashboard: Visual display of key safety metrics

Sustaining & Improving SMS

Ongoing SMS Activities

SMS is not a one-time project but an ongoing process requiring continuous attention and resources.

Activity Frequency Participants
Safety Action Group Meetings Monthly minimum Safety Manager, key managers, Accountable Executive (quarterly)
Safety Data Review Monthly Safety Manager, data analysts
Safety Report Processing Within 30 days of receipt Safety Manager, relevant subject matter experts
Internal SMS Audit Annual minimum Internal audit team or external auditors
SMS Training (initial) At hire All new employees
SMS Training (recurrent) Annual All employees
Safety Communication Ongoing (monthly bulletins minimum) Safety Manager, communications team
Management Review Quarterly minimum Senior management, Accountable Executive

Measuring SMS Effectiveness

SMS Maturity Indicators

How to know if your SMS is maturing and effective:

  • Reporting Culture: Increase in voluntary safety reports (not just compliance)
  • Proactive Identification: More hazards identified before incidents occur
  • Data Quality: Comprehensive, accurate safety data collection
  • Timely Actions: Corrective actions completed on schedule
  • Management Engagement: Active management participation in SMS activities
  • Employee Engagement: Employees see value in and support SMS
  • Learning Organization: Lessons learned are documented and applied
  • Continuous Improvement: Regular refinement of SMS processes
  • Safety Performance: Positive trends in safety metrics

Common SMS Pitfalls to Avoid

SMS Mistakes & How to Avoid Them

  • Pitfall: SMS as compliance checkbox
    Avoidance: Focus on genuine safety improvement, not just meeting minimums
  • Pitfall: Safety Manager works in isolation
    Avoidance: Integrate SMS across all departments, engage everyone
  • Pitfall: Data collection without analysis
    Avoidance: Establish regular data review cadence, take action on findings
  • Pitfall: Punishing reporters
    Avoidance: Protect reporters, investigate systems not people
  • Pitfall: Allowing SMS to become stagnant
    Avoidance: Continuous improvement mindset, regular reviews and updates
  • Pitfall: Over-complexity
    Avoidance: Keep processes simple and scalable to your operation size

SMS Training & Education

FAA SMS Training Programs

FAA Safety Team (FAASTeam) Courses

  • Introduction to SMS: Free online course covering SMS basics and regulatory requirements
  • SMS Hazard Identification: Techniques for identifying operational hazards
  • SMS Risk Assessment: How to assess and mitigate safety risks
  • Safety Culture: Building a positive safety culture in your organization
  • SMS for Executives: Management-level overview of SMS responsibilities

Access: Available through FAASafety.gov - Free registration required

Industry Training Programs

NBAA Professional Development

  • SMS Foundations Course: 2-day comprehensive SMS training
  • SMS Internal Auditor Training: Learn to conduct effective SMS audits
  • Advanced SMS Topics: Deep dives into specific SMS components
  • SMS Workshops: Annual NBAA convention SMS sessions

More info: NBAA Professional Development

IATA SMS Training

  • SMS Foundation Course: 3-day comprehensive training
  • SMS Manager Course: Advanced training for SMS managers
  • SMS Auditor Course: How to audit SMS programs
  • Safety Culture Training: Building and assessing safety culture

More info: IATA Training & Development

University SMS Programs

Academic SMS Education

  • University of Southern California (USC): SMS Certificate Program - 10-week online program covering all SMS components
  • Embry-Riddle Aeronautical University: SMS courses as part of aviation safety programs
  • Cranfield University (UK): MSc in Air Safety Management with SMS focus
  • National Safety Council (NSC): Aviation SMS training programs

SMS Training Best Practices

Creating an Effective SMS Training Program

  • Tailor to Audience: Different training for executives, managers, frontline employees
  • Initial + Recurrent: Comprehensive initial training, annual recurrent to reinforce
  • Practical Examples: Use real scenarios from your operation
  • Interactive Methods: Avoid death-by-PowerPoint; use case studies, discussions, exercises
  • Measure Effectiveness: Test comprehension, track behavior change
  • Just-in-Time Training: Provide training when roles change or new processes introduced
  • Document Everything: Maintain training records per 14 CFR requirements

Industry Best Practices & Guidelines

SMS Maturity

NBAA SMS Maturity Model

A five-level maturity ladder is a common way to assess where an SMS stands:

  • Level 1 - Informal: Ad-hoc safety activities, minimal documentation
  • Level 2 - Developing: Basic SMS components in place, reactive approach
  • Level 3 - Defined: Documented SMS processes, proactive hazard identification
  • Level 4 - Managed: Data-driven decision making, continuous improvement
  • Level 5 - Optimizing: Mature SMS, predictive capabilities, industry leader

Use this model to: Benchmark your SMS, identify improvement areas, set maturity goals

Flight Safety Foundation SMS Framework

FSF SMS Best Practices

  • BARS (Basic Aviation Risk Standard): SMS audit program with standardized protocols
  • SMS Implementation Guide: Step-by-step guidance for aviation service providers
  • Safety Culture Assessment Tools: Surveys and methods to measure safety culture
  • Practical SMS Examples: Case studies from successful SMS implementations

Access: Flight Safety Foundation website

Industry Working Groups

Collaborative Safety Initiatives

  • CAST (Commercial Aviation Safety Team): FAA-industry partnership for safety improvement
    • Develops SMS best practices and tools
    • Publishes safety enhancements and lessons learned
  • GAJSC (General Aviation Joint Steering Committee): GA-specific safety initiatives
    • SMS guidance for smaller operators
    • Scalable SMS approaches
  • NBAA SMS Working Group: Business aviation SMS collaboration
    • Monthly calls and webinars
    • Share best practices and lessons learned
    • Free to NBAA members

SMS in Jetfolio

The Safety Management System tool in this toolbox is the operator's SMS of record. It carries the four components of Part 5 — hazard and incident reporting, the risk register and safety risk assessments, investigations and corrective actions, safety performance indicators and targets, management reviews, safety promotion, and the § 5.97 retention schedule — and the Part 135 Declaration workspace assembles the evidence for the 28 May 2027 declaration of compliance.

Open the Safety Management System

Technology is a tool, not the system

Software records and organizes; it does not supply management commitment, a reporting culture, trained people or working processes. Build those first and use the tool to keep them honest.

Common SMS Deficiencies

Common Deficiencies Identified in SMS Audits

Learn from Others' Mistakes

FAA and industry audits have identified these common SMS deficiencies:

  • Inadequate Management Commitment: Safety policy signed but no follow-through with resources or actions
  • Reactive-Only Approach: SMS only responds to incidents, no proactive hazard identification
  • Poor Data Analysis: Collecting data but not analyzing or acting on it
  • Insufficient Training: Employees don't understand SMS or their role in it
  • Punitive Culture: Reporters face discipline, leading to under-reporting
  • Lack of Continuous Improvement: SMS becomes static, not evolving
  • Disconnected from Operations: SMS seen as separate "safety department" activity
  • Incomplete Documentation: Processes exist but not documented in SMS Manual

Action: Use this list as a self-assessment tool during implementation and ongoing operations

Related Resources

Additional resources to support your SMS implementation:

Part 135 Compliance Checklist FAA Advisory Circulars Crew Scheduling Guide Fatigue Risk Management Record-Keeping Guide All reference pages

FAA Resources

ICAO Resources

Industry Organizations