Developing a Part 5 SMS – There’s a Better Way

Developing a Part 5 SMS?  Don’t re-invent the wheel!

Today, with SMS mandates on the horizon for part 135 operators, 14 CFR § 91.147 operators, and certain part 21 certificate holders, many people still think their SMS needs to be developed internally, including integration with tools such as flight data monitoring. So they spend 3 days attending an expensive class, study the 148-page Advisory Circular AC 120-92D, perform a ‘gap analysis’, and come home with an SMS Manual that can be ‘paired with any software’ – perhaps, but not without significantly more work. The real surprise comes when FAA shows up with their SMS data collection tools (DCTs) and operators discover that while they may comply with Part 5, they are far from conforming with the SMS design validation DCTs that FAA uses to check for seven essential safety attributes. The operator has created what we refer to as a ‘piecemeal SMS’; one that is not harmonized with their software, and is a long way from satisfying FAA design validation requirements.

Learn more about the Piecemeal SMS

Welcome to 2025, where operators and their 119 managers can learn to configure and operate a well-designed SMS, rather than trying to develop one. If you are a 135 operator, ask yourself: Where did our General Operations Manual, General Maintenance Manual, or Pilot Training Program originate? Did you perform a ‘gap analysis’ and develop these documents internally? My bet is that you obtained another operator’s manuals (with permission of course!) and then edited them for the type of equipment and operations you planned to conduct. The same is true for your aircraft. You didn’t piece together your aircraft from disparate parts in the hangar. Instead, you selected a suitable aircraft – designed and certificated by professionals – and then modified and configured it to meet the size, scope, performance requirements, operating environment, and needed capabilities of your unique operation.

These same principles can be applied to today’s safety management systems. SMS service providers have been developing and refining their systems and processes over the years, and now offer professionally developed safety management systems that can be configured to the size and scope of the operations you conduct. Arguments regarding ‘off-the-shelf’ or ‘cookie-cutter’ SMS systems being inappropriate or unacceptable are no longer valid. This is because the SMS provider works closely with each operator to configure and align the operator’s SMS not only for size and scope of operations, but for types of operations, operational processes, operating environment, equipment, mission profiles, etc. The operator then further configures the system with identified hazards, baseline controls, and taxonomies of unwanted events, human factors, and organizational factors that make up the operator’s unique safety risk profile.

Learn to Configure and Operate Your SMS – Not Develop One

By selecting a professionally developed, harmonized SMS with detailed written guidance and SMS training, managers learn how to configure and operate the SMS rather than how to develop one. This saves the operator many hundreds of hours of development time. It also helps prevent manager burnout and ensures success during SMS design validation, based on feedback from regulators and clients who have previously obtained FAA acceptance.

Caution: This will only work with the right SMS provider. The provider should have real-world commercial experience in both flight operations and maintenance. The provider should be experienced with Part 5 conformance and well-versed with FAA’s SMS design validation DCTs and SMS design demonstration DCTs. The provider should also have a proven track record of working with clients who have achieved SMS active conformance status with FAA; in other words, full FAA acceptance of their part 5 SMS.

Learn more about how to choose an SMS provider

Conclusion

The FAA Part 5 compliance date of May 28, 2027 requires operators to start planning their SMS implementation strategy now. Senior managers – Don’t let part 5 SMS development burn out your management team! It is extremely stressful to attempt development of a new and complex project, particularly one you’ve never done before, while continuing to run daily operations. Instead:

Provide professionally-developed tools – don’t ask busy managers to build them!
Provide SMS training – NOT on how to develop an SMS; rather, on how to configure and operate one.
Choose the right SMS provider – One that will support and assist you throughout FAA’s SMS acceptance process, including SMS design validation and design demonstration phases.

Decisions as to how you develop and implement your Part 5 SMS are critical to your organization’s safety culture and continuous improvement over time, including integration with programs such as flight operations quality assurance (FOQA). A professionally developed SMS with harmonized SMS training is more than just Part 5-compliant; it’s a fast track to FAA acceptance and encourages buy-in from employees and managers. It’s the right choice!