In today’s aviation environment, a Safety Management System (SMS) isn’t just a good idea – it’s a requirement for Part 135 operators, 91.147 air tour operators and aircraft manufacturers. The FAA’s Part 5 SMS regulation provides a structured framework for operators of all sizes to manage safety risks systematically and effectively. Part 91, 141, 142 and 145 organizations can also use this framework to develop an SMS, even without a regulatory mandate.
This guide is designed specifically for small operators who want to launch, implement and enhance their SMS under Part 5 requirements. Whether you’re just beginning your journey or looking to adapt an existing system, this guide will take you through the essentials of safety policy, safety risk management, safety assurance and safety promotion.
Explore interactive, scenario-based videos that bring the SMS elements to life, and help you confidently navigate your SMS implementation. Real-world examples from Blue Skies Charter – a small operator like you – will make the concepts clear and practical. Start strong, stay compliant and prioritize the safety of your operations every step of the way.
- Who Needs to Implement a Part 5 Compliant SMS?
- Compliance Deadlines for FAA Part 5 SMS
- FAA Part 5 Requirements
- SMS Implementation Videos
- FAA SMS Guidance and Resources
- Conclusion
Who Needs to Implement a Part 5 Compliant SMS?
The updated FAA Part 5 SMS rule applies to the following categories of operators in the United States:
- Part 121 Operators: All operators conducting domestic, flag and supplemental operations under Part 121 are required to comply with Part 5 SMS regulations.
- Part 135 Operators: Operators conducting commuter and on-demand operations under Part 135, must develop and implement an SMS.
- Air Tour Operators Holding a Letter of Authorization (LOA) under § 91.147: Air tour operators holding LOAs under § 91.147 must also implement an SMS. This includes helicopter tours and fixed-wing air tours, now required to align with SMS best practices to ensure safety.
- Manufacturers (Certain Production Certificate Holders and Type Certificate Holders): Certain manufacturers (aircraft, aircraft engine, or propeller) holding production certificates and type certificates are required to implement an SMS.
- Any organization wishing to improve its safety culture and performance: Even though Part 5 may not include your type of organization yet, an SMS will yield important and lasting benefits for your organization.
Compliance Deadlines for FAA Part 5 SMS
- Part 121 Operators: Must revise or implement an SMS to meet Part 5 requirements by May 28, 2025.
- Part 135 Operators, Air Tour Operators holding an LOA under § 91.147: Must develop and implement an SMS by May 28, 2027, and submit a declaration of compliance to the FAA by that date.
- Manufacturers:
- Submit an implementation plan for FAA approval by Nov. 28, 2024.
- Fully implement the SMS by May 28, 2027.
- Safety Management System Voluntary Program (SMSVP) (already FAA-accepted): Must revise the SMS to meet Part 5 requirements by May 28, 2025
FAA Notice 8900.700 Interim Guidance Related to Amendments to FAA Part 5 SMS (PDF)
FAA Part 5 Requirements
FAA Part 5 outlines specific regulations and guidance for operators seeking to implement SMS. The key components are:
- Safety Policy: Establish safety objectives and document a commitment to safety, including:
- Provision of necessary resources for SMS implementation
- A safety reporting policy for employees
- A policy defining unacceptable behavior
- An emergency response plan
- A code of ethics
- Safety Risk Management: Develop processes to:
- Determine when to apply safety risk management
- Analyze systems and identify hazards
- Assess and control safety risks
- Evaluate the acceptability of risks with proposed controls.
- Safety Assurance: Continuously monitor and evaluate safety performance through:
- Data acquisition to monitor operations
- Audits and evaluations of processes and systems
- Investigations of incidents, accidents and non-compliance reports
- A confidential employee reporting system
- Safety Promotion: Build a strong safety culture by:
- Providing training to ensure personnel are competent in SMS roles
- Effectively communicating safety information throughout the organization
SMS Implementation Videos
Safety Policy & Safety Promotion
This video provides an overview of implementing a Part 5-compliant SMS, with a focus on safety policy development and safety promotion strategies. This video covers essential components like leadership commitment, gap analysis, safety objectives, emergency response planning and employee training.
Safety Assurance
Coming August 2025! This video covers the SMS component safety assurance, that evaluates the continued effectiveness of implemented risk control strategies and supports the identification of new hazards.
Safety Risk Management
Coming September 2025! This video covers the SMS component safety risk management, which determines the need for, and adequacy of, new or revised risk controls based on the assessment of acceptable risk.
FAA SMS Guidance and Resources
The FAA provides several documents and tools to assist operators with SMS implementation under Part 5:
- FAA Advisory Circular 120-92D: Safety Management Systems for Aviation Service Providers Offers guidance on developing an SMS for both commercial and non-commercial operators, explaining essential components and practical steps for implementation.
- FAA SMS Website: Programs & Initiatives
Provides an overview of SMS requirements, guidance, and access to FAA-approved training and resources. - FAA Order 8000.369C: Safety Management System
Outlines the FAA’s SMS framework and details how the FAA integrates SMS into its safety oversight responsibilities. - FAA Order 8900.1, Volume 17: Safety Management System
- Chapter 1 – General, Section 1: Safety Management System
- Chapter 2 – Voluntary Program, Section 1: SMSVP Implementation, Validation, and Continued Operational Safety
- Chapter 2 – Voluntary Program, Section 2: Safety Management System Voluntary Program Standard
- Chapter 3 – Corporate Enterprise Safety Management System Voluntary Program, Section 1: Implementation, Validation, and Continued Operational Safety
- FAA SMS Implementation GAP Analysis Tool for Sole Individual Organizations
- FAA SMS Implementation GAP Analysis Tool For All Organizations Except Sole Individual
- FAA Order 8900.700: Interim Guidance Based on the Amendments to Title 14 of the Code of Federal Regulations Part 5
- FAA SMS Policy and Requirements Foundational Resources
- FAA Final Rule: Safety Management Systems
On April 26, 2024, the FAA published updated SMS requirements for all Part 135 certificate holders, Part 91.147 air tour operators and certain Part 21 certificate holders.
Conclusion
The updated FAA Part 5 SMS regulations expand the requirement for implementing an SMS to more organizations, including Part 91.147 air tour operators and Part 135 operators. The FAA offers numerous resources to guide operators through the SMS implementation process, ensuring compliance with national and international standards. While these guides focus on organizations regulated by Part 5, they can help any operator, from a single pilot operating a single corporate aircraft to a large charter operator with numerous crews and aircraft, develop, implement and maintain a Part 5 compliant SMS.
International Business Aviation Council Ltd.