How Much SMS Does Your Flight Department Need?

A safety management system scales to the operation using it. For a small flight department, the core functions can fit inside the routines the team already runs.

Part 5 and other industry frameworks let operators scale a safety management system to fit their operation. What they require in return is evidence that it works.

Safety management systems (SMS) will no doubt be a common topic at this year’s NBAA-BACE, with Part 135 operators facing a May 28, 2027, deadline to have an SMS meeting 14 CFR Part 5 in place. Beyond this much-discussed regulation, IS-BAO and ARGUS audits both look for a functioning SMS, and the FAA encourages every general aviation organization to adopt one voluntarily. For a flight department that does not yet have an SMS in place, how much of that applies and at what scale?

On one hand, the frameworks answer that question themselves. Part 5 requires an SMS to be “appropriate to the size, scope, and complexity” of the organization, language NBAA pressed the FAA to keep during rulemaking, and it exempts a one-person operation, where a single pilot performs every function, from several requirements outright. IBAC describes IS-BAO as scalable down to a single aircraft flying domestically, and AC 120-92D states that there is no one-size-fits-all method. On the other hand, that flexibility leaves room for interpretation. What counts as appropriate can look different to federal oversight than to an industry audit team, and different again to the organizations and individuals taking part in an SMS program.

In 2014, a Part 91 flight department with one Gulfstream IV and three employees had a manual with a safety management section, a flight risk assessment process and IS-BAO Stage 2 registration earned two years earlier. On paper, it was exactly the kind of scaled SMS a small operator is encouraged to build. I’ll circle back to this below, because what happened next is the clearest argument I know for how an SMS should be scaled.

The Evidence Test

Consider this standard: The form of each SMS function can shrink to fit the operation, and the evidence that it works has to be there at any size. AC 120-92D points the same way: Scalability lets an organization adjust how it meets each section of Part 5, and it does not allow any section to be set aside. ARGUS’s Platinum rating reflects the same idea: It requires a mature SMS that is actively used, and its on-site auditors look at how a team actually identifies hazards and mitigates operational risk. InFO 24014 puts it plainly: “A successful SMS implementation will require more than writing a manual.” A manual describes the system. What happens on the ramp and in the cockpit shows whether it works, and that is where the evidence lives.

Four Functions at Any Size

Part 5, which more closely aligns U.S. requirements with ICAO Annex 19, organizes an SMS into four components:

Safety policy is a written commitment to safety, signed by the person known as the accountable executive, meaning whoever holds final authority over the operation and controls its money and people. In a business aviation organization, that may be a corporate officer or the aviation manager, and the policy can fit on a single page. One sign it is working: Pilots and technicians can explain how to report a hazard without looking it up.

Safety risk management means identifying hazards before something changes, such as a new aircraft type, destination or procedure, and deciding whether the remaining risk is acceptable. A flight risk assessment tool applies the same thinking one trip at a time. The evidence is a record of each decision, including the ones that changed the plan.

Safety assurance confirms that those controls work. Part 5 calls for a confidential reporting system, and in a small department that can be a non-punitive report form, a standing agenda item at the monthly pilot meeting and a log of what came in and what was done about it.

Safety promotion covers training and communication, and Part 5 specifically calls for explaining why safety procedures are introduced or changed.

Part 5 as a Blueprint

Part 5 applies to Part 121 and 135 certificate holders, air tour operators under § 91.147 and certain manufacturers, which leaves Part 91 corporate flying outside its reach. Even so, InFO 24014 encourages every general aviation organization, Part 91 flight departments included, to develop and implement a voluntary SMS that meets Part 5. Even without legal weight, Part 5 remains a detailed, publicly available description of what each function should include.

Some Part 91 aircraft also fly charter under a management company’s Part 135 certificate. Because Part 5 applies to the certificate holder, those charter legs will fall under the management company’s SMS by May 28, 2027, while the owner’s own Part 91 trips may not. Where that applies, I recommend that the owner’s department and the management company agree on how hazards and reports move between them. A hazard found on a Part 91 leg is just as real on the next charter.

What the Record Shows

Because every framework leaves scaling to the operator, the first record I recommend keeping is the reasoning behind each choice, such as why the hazard log is a spreadsheet, why risk reviews happen at the pilot meeting and why the director of operations also serves as safety manager. That short record lets an auditor judge the design on its merits and lets a new aviation manager inherit the logic with the procedures.

That record describes the design, and the example from the beginning of this article shows why the evidence test asks for more. The NTSB’s report on the 2014 accident at Bedford, Massachusetts, notes that the operator’s 2012 IS-BAO audit observed no flights because none were scheduled. On May 31, 2014, the crew attempted a takeoff with the gust lock engaged, and all seven people aboard died. Recorder data showed that complete flight control checks had been omitted before 98% of the crew’s previous 175 takeoffs, and the NTSB cited habitual noncompliance with checklists as a contributing factor (i.e., evidence of how the aircraft was actually being flown was potentially available to the operator before the accident).

The lesson from Bedford is to aim every review, internal or external, at what the operation actually does, and outside audits offer an independent way to test that evidence. IS-BAO’s progression from Stage 1 to Stage 3 offers a realistic maturity roadmap for any department, while an ARGUS Platinum audit brings the same on-site scrutiny from the charter side. For operators who want to take it a step further, ARGUS Platinum Elite adds continuous monitoring between full audits, with maintenance and operations reviews every six months culminating in a company-wide review every two years. The program is open to operators with at least two consecutive Platinum audits and no significant findings, and its more frequent reviews shorten the time between independent looks at the operation.

Wherever flight data exists, it belongs in that review as well. NBAA strongly encourages voluntary flight data monitoring for any business aviation operator whose aircraft has, or can be fitted with, a flight data recorder, and corporate FOQA programs let a flight department benchmark its data against aggregated, de-identified business aviation data.

Final Thoughts

Getting started does not require a new manual. The FAA posts the Data Collection Tools its inspectors use for Part 5 surveillance on the Dynamic Regulatory System, and InFO 24014 suggests using them for internal evaluation. I recommend starting there and applying the evidence test to every line.

For anyone who wants to learn more, the NBAA Safety Committee is an excellent resource. It serves as a center of expertise on business aviation safety, and its work shapes NBAA’s annual Top Safety Focus Areas. It is also worth exploring the SMS software platforms built for business aviation, which are designed to support tasks such as hazard reporting, risk assessment and record keeping. In the end, a department that can produce the record behind each item has an SMS sized correctly for its operation, whatever that size happens to be.

Hall Lewallen is Director of Courseware at Advanced Aircrew Academy, whose eLearning programs support Part 5, IS-BAO, and ARGUS compliance for aviation organizations across the industry, including Part 91 and Part 135 operators.

More Resources

REGULATIONS AND FAA GUIDANCE
14 CFR Part 5, Safety Management Systems ecfr.gov
AC 120-92D, Safety Management Systems for Aviation Service Providers faa.gov
InFO 24014, Safety Management System for General Aviation Organizations faa.gov
FAA Part 5 Frequently Asked Questions faa.gov
Part 5 Data Collection Tools, Dynamic Regulatory System drs.faa.gov

INDUSTRY STANDARDS AND AUDITS
IS-BAO, International Standard for Business Aircraft Operations ibac.org
ARGUS Platinum Audit argus.aero
ARGUS Platinum Elite Continuous Monitoring argus.aero

NBAA RESOURCES
FAA Part 5 SMS for Small Operators: A Practical Guide nbaa.org
Flight Data Monitoring (FDM) nbaa.org
NBAA Safety Committee nbaa.org

CASE STUDY
NTSB/AAR-15/03, Gulfstream G-IV N121JM, Bedford, Massachusetts ntsb.gov