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3.5.11.5.3 Once acceptable risk controls are developed and implemented using their SRM processes, Flyslow Aviation establishes a new objective to reduce the issuance of uncalibrated tools and adds a requirement to track calibrated tool control under § 5.73(a)(3) to ensure the developed risk controls are functioning as designed. The process owner regularly reviews the data acquired through their safety assurance monitoring processes and evaluates the effectiveness of the changes to the calibrated tool program.
3.5.11.5.4 After a defined period of monitoring the tool tracking process, Flyslow Aviation determines the risk controls are working as designed as there have been no further instances of uncalibrated tools being issued to technicians.
They close out the special audit and monitoring of this risk control for their calibrated tool program.
3.6 Subpart E, Safety Promotion.
3.6.1 Competencies and Training.
3.6.1.1 References. Section 5.91.
3.6.1.2 Part 5 Requirement.
§ 5.91, Competencies and training.
Any person required to have an SMS under this part must provide training to each individual identified in § 5.23 of this part to ensure the individuals attain and maintain the competencies necessary to perform their duties relevant to the operation and performance of the SMS.
3.6.1.3 Discussion. Aviation organizations are required to provide initial safety training for employees so they can perform their SMS-related duties. Training should be specific to employee roles and responsibilities with regard to their duties associated with the maintenance of the SMS. Training can take any form or manner the aviation organization determines is acceptable when considering the size and complexity of their operations. An example of this could be all aviation-related employees must be trained on hazard reporting processes and procedures while process owners would require additional training in the SRM and safety assurance processes.
3.6.1.3.1 Recurrent training may also be necessary to reinforce skills to meet the requirement for an employee to maintain competencies. For example, an employee who is a process owner will probably need recurrent SMS training (such as safety risk analysis, system evaluation, system assessment, and data mining, auditing, and inspections) where a baggage handler would only need a refresher on how to use the confidential hazard reporting program. Intervals for recurrent training are determined by the organization based on historical and operational requirements. These intervals must be of sufficient frequency to ensure employees maintain the competencies required.
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3.6.1.3.2 Competency is an observable, measurable set of skills, knowledge, abilities, behaviors, and other characteristics that individuals exhibit as they successfully perform work functions. Competencies are typically required at different levels of proficiency depending on the work roles or occupational function. Aviation organizations should establish competencies for all employees commensurate with their duties relevant to the operation and performance of the SMS. Competence can be assessed at the completion of training by written, oral, or demonstration tests and then measured periodically during the performance of that individual’s work by way of periodic evaluations or supervisor/management observations. As a part of safety assurance, organizations should periodically review the training program(s) to ensure those programs meet the objectives set out in the safety policy.
3.6.1.3.3 It is the responsibility of all aviation organizations to determine their training needs based on operational requirements. Management personnel specifically designated by the accountable executive to ensure the SMS is fully implemented may need to be trained first and may also need specialized training to fulfill their responsibilities. Determining the organization’s training needs starts with a careful review of the safety policy, processes, and objectives. Everyone working within the scope of the SMS should receive training commensurate with their position in the organization.
3.6.1.4 Implementation Strategies. The following examples demonstrate ways aviation organizations might choose to implement this requirement based on where the aviation organization may fall on the spectrum of size or complexity. The following are examples only and are not the only ways the requirements could be met.
3.6.1.4.1 Aviation organizations may choose to either train their employees in house or contract the training to outside vendors. Whichever option is taken, the training must be specific to the SMS and aviation activities conducted.
Training can be in person or virtual based on organizational needs. Training should be modular so only the material pertinent to the position within the organization is presented. For example, a maintenance technician might only need to be trained on hazard reporting while a process owner would need to understand the organization’s SRM processes and procedures. A small or low-complexity organization with only a few employees would likely complete online training to meet this requirement. Aviation organizations on the higher end of the size or complexity spectrum could have a training department that develops and conducts the training.
3.6.1.5 Considerations for Small and Single-Individual Organizations. The knowledge and experience gained by a single individual developing the organization’s SMS is likely sufficient to meet training requirements for the organization. In a small organization, consider whether the safety manager or
3-61 the individual assigned the associated duties (if there is one in a small organization) has received SMS training.
3.6.2 S afety Communication .
3.6.2.1 References. Section 5.93.
3.6.2.2 Part 5 Requirement.
§ 5.93, Safety communication.
Any person required to have an SMS under this part must develop and maintain means for communicating safety information that, at a minimum:
(a) Ensures that employees are aware of the SMS policies, processes, and tools that are relevant to their responsibilities.
(b) Conveys hazard information relevant to the employee’s responsibilities.
(c) Explains why safety actions have been taken.
(d) Explains why safety procedures are introduced or changed.
3.6.2.3 Discussion.
3.6.2.4 Effective communication involves adjusting the content and manner in which the information is delivered to match the employee’s role in the organization.
The accountable executive must ensure communication mechanisms are available and are effectively used. The delivery system should be appropriate to the size and complexity of the organization.
3.6.2.4.1 Safety policy and information could be provided as text, visual media
(e.g., posters or short videos), orally, or through examples. Communication should be consistent and in a format that employees at each level can relate to and be delivered using whichever media the organization utilizes. For example, hazard communications regarding birds for flightcrew members (regarding new bird strike avoidance techniques) may be in a “Notices” section of the Flight Operations Manual (FOM) and may be reinforced by recurrent training. Hazard communications made to line maintenance technicians (regarding birds roosting and nesting in flight controls, auxiliary power unit (APU) intakes, and engine cowlings) may be conveyed by posters and changes to daily inspection procedures. Hazard communications regarding birds made to ground service personnel may be in the form of posters, videos, and demonstrations (cleaning and removing bird droppings from windshields).
3.6.2.5 Implementation Strategies. The following examples demonstrate ways aviation organizations might choose to implement this requirement based on where the aviation organization may fall on the spectrum of size or complexity. The following are examples only and are not the only ways the requirements could be met.
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3.6.2.5.1 In smaller or lower complexity aviation organizations, communicating safety considerations to employees may be simple and direct. For example, the accountable executive could conduct regular all-hands/employee meetings, such as “hangar talk sessions.” Additionally, communication could include regular and periodic briefings to the employees, posting the status of safety issues on bulletin boards, emails to employees, and face-to-face meetings with division management teams. Aviation organizations with only a few employees could utilize a required reading list consisting of material from industry or other sources. The selected material would be applicable to the operations conducted. Documentation of what was reviewed would meet the requirements of § 5.97(d). Aviation organizations on the higher end of the spectrum of size or complexity may utilize communication methods that are more structured. Safety information may be distributed throughout the organization by printed or electronic means or a combination of both.
Communication and feedback may be formalized in order to provide information to individual employees as well as organization-wide information for cross-boundary issues and/or common hazards. A tracking system may be used to ensure that the appropriate safety messages are delivered to the appropriate personnel. Information technology approaches, such as email broadcasts or intranet websites, may be considered to facilitate directing the flow of safety information and recording its accomplishment for evaluation and auditing purposes.
3.6.2.6 Single-Individual Organizations.
3.6.2.6.1 Single-pilot operations and single-individual organizations pose unique situations when implementing an SMS. As a result of these factors, the following regulatory sections are excepted from the implementation requirements for organizations with a single pilot who is the sole individual performing all necessary functions in the conduct and execution related to, or in direct support of, the safe operation of aircraft:
Section 5.93: Any person required to have an SMS under this part must develop and maintain means for communicating safety information that, at a minimum:
(a) Ensures that employees are aware of the SMS policies, processes, and tools that are relevant to their responsibilities.
(b) Conveys hazard information relevant to the employee’s responsibilities.
(c) Explains why safety actions have been taken.
(d) Explains why safety procedures are introduced or changed.
3.6.2.6.2 Single-individual organizations are not required to have a safety communication process or procedure; however, they should consider the methods they will utilize when sharing information with other aviation service
3-63 providers they interface with. Methods used can be as simple or as complex as the organization chooses, but they should be consistent. Maintaining a “Journey Log” or “Unusual Occurrences” log may be useful for regular review and reinforcement of safety concerns identified when performing the aviation service. This will facilitate entering the occurrences into the safety assurance component (§ 5.71) for tracking and resolution.
3.7 Subpart F, SMS Documentation and Recordkeeping.
3.7.1 SMS Documentation.
3.7.1.1 References. Sections 5.95 and 145.215.
3.7.1.2 Part 5 Requirement.
§ 5.95, SMS documentation.
Any person required to have an SMS under this part must develop and maintain the following SMS documentation:
(a) Safety policy.
(b) SMS processes and procedures.
3.7.1.3 Discussion.
3.7.1.3.1 Part 5 does not require aviation organizations to develop and maintain an SMS manual. All that part 5 requires an aviation organization to do is document their SMS safety policy and SMS processes and procedures. How this is accomplished is up to the aviation organization. Larger organizations are likely to have an SMS manual whereas smaller organizations might use a compliance statement or spreadsheet listing the part 5 requirements and how the organization meets the requirements. SMS documentation may be maintained either as hard copies or electronically. It may be contained in a General Operations Manual (GOM) or Repair Station Manual (RSM) or any other combination of documentation and manuals that is appropriate for the organization. However, the documentation is maintained, the organization should ensure it remains up to date.
3.7.1.3.2 The aviation organization should also implement a distribution system (if needed) to ensure documents dealing with SMS processes and procedures are promptly updated whenever there is a change.
3.7.1.4 Implementation Strategies. The following examples demonstrate ways aviation organizations might choose to implement SMS documentation based on where the aviation organization may fall on the spectrum of size or complexity. The following are examples only and are not the only ways the requirements could be met.
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3.7.1.4.1 In a small or lower complexity aviation organization, the owner/manager (accountable executive) or designee may be responsible for maintaining and distributing current versions of guidance documents. Documentation may consist of a set of typewritten documents, spreadsheets, and forms that are kept in file cabinets or binders. They may also use WBAT or other third-party providers. Managers of medium-complexity organizations need the same type of information to make decisions; however, the volume is typically larger than that of a low-complexity organization and smaller than that of a high-complexity organization. Aviation organizations on the higher end of the size or complexity spectrum may institute documentation and recordkeeping processes using WBAT, other third-party providers, unique software applications, or development of new database tools to support risk reporting and analysis. These organizations should examine existing tools and infrastructure, as it is likely that these can be leveraged (modified) to meet SMS requirements.
3.7.1.5 Considerations for Small and Single-Individual Organizations. While single-pilot organizations are not required to maintain a manual system per § 135.21, they are still required to document their SMS safety policy and SMS processes and procedures. How this is accomplished is up to the aviation organization.
3.7.2 S MS Records.
3.7.2.1 References. Section 5.97.
3.7.2.2 Part 5 Requirement.
§ 5.97, SMS records.
Any person required to have an SMS under this part must:
(a) Maintain records of outputs of safety risk management processes as described in subpart C of this part. Such records must be retained for as long as the control remains relevant to the operation.
(b) Maintain records of outputs of safety assurance processes as described in subpart D of this part.
Such records must be retained for a minimum of 5 years.
(c) Maintain a record of all training provided under § 5.91 for each individual. Such records must be retained for as long as the individual is employed by the person.
(d) Retain records of all communications provided under § 5.93 or § 5.57 for a minimum of 24 consecutive calendar months.
3.7.2.3 Discussion. Organizations are required to retain documents associated with the outputs of SRM processes for as long as the risk control remains relevant to the operation. For SRM processes that do not result in any risk controls being implemented or where risks are acceptable, aviation organizations are not required to retain these documents. While part 5 does not require an organization to retain a system analysis when no risk control is developed, aviation organizations may find it useful to retain this analysis for future use.
3-65 Part 5 requires documentation of risk assessments and risk controls and any supporting data used in the SRM process be retained for as long as the risk control remains appropriate for the operations. These outputs serve as evidence of the organization reviewing the system and finding the associated hazards and residual risks acceptable. Outputs of the safety assurance processes must be retained for a minimum of 5 years. Section 5.23 requires the members of management and the accountable executive to review the outputs of the SRM and safety assurance processes to ensure the effectiveness of safety risk controls and that the SMS is functioning as designed.
Documentation showing the process owners and accountable executive have reviewed these documents should also be retained. Training records must show when the individual initially received training to attain the competencies necessary for their position. Proof of recurrent training completion must also be retained as documentation of maintaining the competencies required for their position. Superseded recurrent training records must be retained in accordance with the aviation organization’s record retention processes and procedures for as long as the employee is employed by the aviation organization. Records of safety communications and hazard information sharing must be retained for a minimum of 24 consecutive calendar months.
Attendance rosters from meetings or training events also provide documentation of employees that have received the safety communications.
3.7.2.3.1 Aviation organizations are required to retain the outputs of their SRM processes. Section 5.97(a) requires maintaining these records for as long as the associated risk control remains applicable to the current operational activities. While not a regulatory requirement, it is a good policy to retain all SRM documentation so work previously conducted can be reviewed by future SRM workgroups. This has the potential of reducing duplicative work or undoing existing risk controls.
3.7.2.3.2 Aviation organizations are also required to maintain records of their safety assurance outputs and retain them for a minimum of 5 years. As with an SMS, the process used for safety assurance outputs needs to be appropriate for the aviation organization. A good practice would be to develop a method of documenting who in the organization has reviewed the data. Other sections of this part require a review of this data to ensure risk controls are working properly and organizational objectives are being met; this would be an appropriate way to meet this requirement.
3.7.2.3.3 Training records need to be retained for each individual in the organization with duties and responsibilities under the SMS. These records must be maintained as long as the individual is employed by the organization. There is no provision for purging SMS training records. SMS training records are in addition to any other required training records from other parts. It is key to ensure the process developed for record retention is appropriate for the size and complexity of the aviation organization.
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3.7.2.3.4 Records of all safety communications are required to be retained for a minimum of 24 consecutive calendar months. The process developed for record retention should be appropriate for the aviation organization. As an example, digital photographs of safety-related posters or signs in a maintenance hangar could be retained as a record of the communication.
Read-and-initial files would also provide a record. Hangar talks and flight crew alerts are also types of communications that would be retained. These communications can be retained electronically or in paper format. The method utilized should be appropriate to the size and complexity of the aviation organization.
3.7.2.4 Implementation Strategies. The following examples demonstrate ways aviation organizations might choose to implement this requirement based on where the aviation organization may fall on the spectrum of size or complexity. The following are examples only and are not the only ways the requirements could be met.
3.7.2.4.1 In smaller or lower complexity aviation organizations, the owner/manager (accountable executive) or designee may be responsible for maintaining auditable records. Documentation may consist of handwritten records, spreadsheets, and completed forms that are kept in file cabinets or binders.
Aviation organizations on the higher end of the spectrum of size or complexity may identify an individual or small staff to coordinate document maintenance and retention. This staff may use a combination of paper and electronic media or a combination of both to administer the process. Some records may be retained by department heads in accordance with a procedure delegating this responsibility. Some aviation organizations may have a dedicated records staff or department whose duties include document distribution and records retention. Due to the size and complexity of the organization, the use of technology is probably more pronounced.
3.7.2.5 Single-Individual Organizations. Single-pilot operations and single-individual organizations pose unique situations when implementing an SMS. As a result of these factors, the following regulatory section is excepted from the implementation requirements for organizations with a single pilot who is the sole individual performing all necessary functions in the conduct and execution related to, or in direct support of, the safe operation of aircraft.
Section 5.97: Any person required to have an SMS under this part must:
(d) Retain records of all communications provided under § 5.93 or § 5.57 for a minimum of 24 consecutive calendar months.
3.7.2.5.1 Single-individual organizations are not required to have a safety communication process or procedure; therefore, there is not a requirement to retain records of communications.
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3.7.2.6 SMS Documentation and Recordkeeping Example. In an effort to raise awareness of the calibrated tool issue and employee reporting, Flyslow Aviation’s management included discussions on these areas as a monthly topic during employee meetings (§§ 5.23(2)(iii) and 5.93). In addition, management also posted signs and posters in the breakroom and work areas.
Rosters of meeting attendees were retained as well as a copy of the agenda topics (§ 5.97(d)).
Note 1: In this example, § 5.91 would not be required as the training requirement addresses SMS processes and procedures. Calibrated tool usage, which is the subject of the training, is covered by other regulations and not the SMS.
Note 2: Flyslow Aviation has control of the calibrated tool program and the associated hazards. If the hazard was under the control of an interfacing organization, then Flyslow Aviation would communicate the hazard under § 5.57.
4-1 CHAPTER 4. IMPLEMENTATION: BUILDING A SAFETY MANAGEMENT
SYSTEM (SMS)
4.1 Process Overview.
4.1.1 Title 14 CFR Part 5 Regulatory Requirements. Title 14 CFR part 119 certificate holders (CH) authorized to operate under 14 CFR part 121 must show compliance with all revised part 5 requirements by May 28, 2025 (part 5, § 5.7(a)).
4.1.1.1 Existing part 119 aviation organizations authorized to operate under 14 CFR part 135 or aviation organizations conducting air tours under a 14 CFR part 91, § 91.147 Letter of Authorization (LOA) with an existing SMS need to review their existing SMS programs for compliance with part 5 (§ 5.9(a)).
Areas found not in compliance, that need to be added, or that have been changed should be identified and addressed. Once the aviation organizations have implemented and developed an SMS meeting the requirements of part 5, they must submit a declaration of compliance stating the SMS meets the requirements of part 5 prior to May 28, 2027.
4.1.1.2 New applicants for a part 119 certificate authorizing them to operate under part 121 or 135 or air tour operators requiring a § 91.147 LOA must demonstrate they meet the applicable regulatory requirements of part 5 prior to issuance of a certificate or LOA (§§ 5.7(b) and 5.9(b), as applicable). New applicants must meet part 5 requirements as a part of the certification process as defined in the Air Operator and Air Agency Certification and Application Process in FAA Order 8900.1, Volume 2.
4.1.2 Aviation Organizations Voluntarily Implementing an SMS. Aviation organizations that seek FAA acknowledgement of their voluntary SMS should develop and implement an SMS that meets part 5. They should submit a declaration of compliance once this has been accomplished. The FAA will validate SMS implementation as a part of routine surveillance activities. For information pertaining to a voluntary SMS, refer to Order 8900.1, Volume 17, Safety Management System.
4.2 Building an SMS. The first step in developing an SMS is mapping out and analyzing the aviation organization by developing an organizational description. The initial mapping and analysis start by describing and documenting the organizational structure and looking at the internal interfaces and external interfaces with other aviation organizations.
4.2.1 Organizational Description.
4.2.1.1 The organizational description should detail each of the aviation organization’s activities by function as well as the management personnel responsible for the organization’s departments (e.g., flight operations, training, ground operations, cabin safety, dispatch, and maintenance). The organizational description may also include, for example, a discussion of external interfaces, such as using contractors for fueling and deicing operations, maintenance functions, etc. It is also common for representatives
4-2 of various employee groups to be discussed and described during the organizational description process. Existing aviation organizations could review their LOAs, operations specifications (OpSpecs), or ratings and limitations to determine if their organization is properly described.
4.2.1.2 As a part of the organizational description, aviation organizations should describe and document key positions for risk acceptance. Managers and process owners should also be identified in this analysis. Process owners sometimes occupy positions that may not be considered management but are in a position to accept risk or change processes or procedures in their area. An example of this could be a battery shop technician or lead dispatcher.
4.2.2 D eveloping a Plan of Action. To develop a plan of action for SMS development and implementation, aviation organizations need to understand their current state of compliance with the requirements of part 5. This should include programs already adopted that may meet the requirements of part 5. One way to accomplish this is by conducting a gap analysis and documenting the results in a compliance statement. A gap analysis involves analyzing and assessing the aviation organization’s existing programs, systems, processes, and activities with respect to part 5. If a process in the aviation organization satisfies part 5, the analysis should document how that process meets the requirements. This may be accomplished by referencing the process or procedure in the manual system (if required) where the requirement is discussed. Aviation organizations may use any technique to identify what needs to be accomplished to implement an SMS.
Many organizations have developed spreadsheets with the part 5 requirements in one column with the next column being used to describe how the organization meets the requirement or what the organization needs to develop to “fill the gap.” For detailed information on developing and completing a compliance statement, see Appendix D, Guidance for Developing a Compliance Statement.
4.2.3 Organizational Processes. Many aviation organizations may find that they have most of the elements of part 5 in their current operational processes. While these processes may not entirely fulfill the requirements (e.g., they may be limited in scope (do not cover the entire organization) and interoperability (do not interface sufficiently to form a “system”)), credit should be taken for those areas already meeting part 5 requirements.
Areas that are deficient should be addressed and processes developed. Existing processes may be internally developed or from third-party contractors’ products or services. The goal here is to ensure that all part 5 requirements are met.
4.2.4 Regulatory and Voluntary Programs. A list of regulatory and voluntary programs that may be appropriate for inclusion in the SMS to satisfy the requirements can be found in Chapter 5, Integrating Existing Safety Programs Into the Safety Management System (SMS).
5-1 CHAPTER 5. INTEGRATING EXISTING SAFETY PROGRAMS INTO THE SAFETY
MANAGEMENT SYSTEM (SMS)
5.1 Purpose of This Chapter. This chapter explains how existing safety programs may be integrated into the SMS safety assurance processes. The FAA encourages the continued use of existing safety programs as an input into the safety assurance processes to ensure the safety performance of aviation organizations. Expanding current safety programs across the entire aviation organization is one way to provide a comprehensive systems approach to safety assurance. These programs would be accepted as one means of meeting some of the provisions of 14 CFR part 5, § 5.71, but they may not fully meet the requirements. Other means may be required.
Note: I t is not the intent or purpose of an SMS to override any existing regulatory standards or alter approval and acceptance processes that already apply to the aviation organization.
5.2 Discussion of Individual Programs. The following are FAA or FAA-sanctioned programs that could be integrated into an SMS. This is not intended to be an all-inclusive listing, and other programs may also satisfy SMS requirements.
5.2.1 C ontinuing Analysis and Surveillance System (CASS).
5.2.1.1 Program. A CASS is required by 14 CFR part 121, § 121.373 and part 135, § 135.431. A CASS is a quality assurance system that monitors and analyzes the performance and effectiveness of the air carrier’s Continuous Airworthiness Maintenance Program (CAMP).
5.2.1.2 I ntegration. A CASS overlaps some part 5 required SMS safety assurance functions (§ 5.71). A CASS could be a standalone system or a subsystem within an SMS. A CASS may be maintained separately; however, it would probably be beneficial to integrate a CASS within the SMS. However accomplished, it is imperative to understand that a CASS should supply information to the SMS. The SMS may even support a CASS through the use of Safety Risk Management (SRM) and safety assurance processes applied to CASS needs. An SMS may evaluate the CASS to ensure that all critical CASS elements are being performed and controlled and all outcomes are acceptable in accordance with FAA Order 8900.1 and AC 120-79, Developing and Implementing an Air Carrier Continuing Analysis and Surveillance System.
5.2.2 Aviation Safety Action Program (ASAP).
5.2.2.1 Program. The ASAP is meant to encourage voluntary reporting of safety issues and events that come to the attention of a participating aviation organization’s employees. ASAPs include processes for intake of data from employees, analysis of the data, and development of corrective actions within a confidential environment. ASAP is accepted by the FAA but is not a required program. ASAP development, implementation, acceptance, and operation are detailed in AC 120-66, Aviation Safety Action Program. An