Sept. 22, 2025

Safety management systems (SMS) are based on a simple premise: to demonstrate a practical commitment to safety excellence.

However, the creation and implementation of an SMS that meets all the FAA’s requirements can benefit from a few, actionable tips offered by those who’ve been through the process.

That’s the idea behind NBAA’s FAA Part 5 SMS for Small Operators: A Practical Guide, which includes, among other resources, a series of scenario-based videos offering practical guidance developed by the NBAA Safety Committee’s SMS Working Group also created.

The newly released second video in the series focuses on the safety-assurance aspect of an SMS: assessing the ongoing effectiveness of implemented risk control strategies and facilitating the identification of new hazards. View the video.

It’s what the FAA calls safety performance monitoring and measurement, which includes data collection and assessment, or the “auditing” side of an SMS.

The FAA’s Part 5 SMS requirement applies to Part 135 operators, Part 91.147 air tour operators that have a letter of authorization, and aircraft manufacturers. These organizations have until May 28, 2027, to implement their SMS and submit a declaration of compliance statement.

NBAA Safety Committee SMS Working Group Lead Amanda Ferraro, CEO of Aviation Safety Solutions, mentioned an additional provision in the new requirement – “If a Part 145 repair station has European Aviation Safety Administration approval, Europe is mandating those repair stations have a Part 5 SMS in place by Dec. 31, 2025.” Ferraro estimates that about 1,200 repair stations will be affected.

“We have many operators who believe they can simply copy a manual and their SMS will be good to go,” Ferraro said. “But compliance with the new mandates will require people to roll up their sleeves and implement a system that’s able to demonstrate its usage and effectiveness to the FAA, specifically, to the principal operations inspector and the principal maintenance inspector assigned to the certificate.

“Every time the FAA inspectors reach out, currently for those operators that have achieved FAA Part 5 compliance, they’re asking for evidence from the SMS,” Ferraro said. “So far this year, in my role as director of safety on a Part 135 certificate, we’ve had four compliance record-keeping requests – a clear sign that our system is being put to use and is performing as designed.”

Ferraro added there are several items operators need to pay attention to after watching the video. “First, the FAA has established eight categories of data that operators must track under CFR 5.71,” she said. “Operators are also required to audit both their SMS and their operations. Within the safety assurance framework, the FAA is shifting SMS toward a predictive data model. This is where simply copying a manual falls apart — because it’s not just about collecting data. It’s about analyzing that data, drawing insights, and ensuring it’s readily available when requested.”

Certificate holders are encouraged to take the SMS mandate seriously. The FAA’s vision is to raise the safety bar, and these new regulations are the result of a commitment to reduce the number of preventable accidents.