For aviation safety managers and accountable executives, ensuring compliance with the FAA’s Safety Management System (SMS) requirements under 14 CFR Part 5 is a cornerstone of operational safety. A critical step in this process is submitting a Declaration of Compliance (DOC) to the FAA, which confirms that your organization’s SMS, including its Safety Risk Management (SRM) processes, meets regulatory standards.

This article provides a deep dive into the role of SRM in SMS compliance and a detailed list of required content for the DOC. Whether you’re managing a Part 135 operation, a Part 91.147 air tour operation, or a Part 21 certificate holder, this guide will help you craft a compliant DOC while strengthening your SRM practices.

Understanding Safety Risk Management in Aviation SMS

Safety Risk Management (SRM) is one of the four pillars of an SMS under 14 CFR Part 5, alongside Safety Policy, Safety Assurance, and Safety Promotion. SRM is a systematic process to identify hazards, assess risks, and implement controls to maintain an acceptable level of safety (ALoS). It’s a proactive approach that enables aviation organizations to address potential safety issues before they lead to incidents or accidents.

In the context of SMS compliance, SRM ensures that your organization:

• Identifies hazards through data analysis, employee reporting, and operational reviews.

• Assesses the likelihood and severity of risks associated with those hazards.

• Implements mitigations to reduce risks to an acceptable level.

• Documents and monitors the effectiveness of risk controls.

A robust SRM process is not only a regulatory requirement but also a foundation for a strong safety culture, making it a key focus when preparing your DOC for FAA submission.

Why the Declaration of Compliance Matters

The Declaration of Compliance (DOC) is a formal statement submitted to the FAA to affirm that your SMS, including SRM processes, complies with 14 CFR Part 5. Signed by the accountable executive, the DOC serves as a legal commitment to safety and is a prerequisite for regulatory acceptance of your SMS.

For aviation safety managers, the DOC is a critical deliverable that demonstrates:

• Full implementation of an SMS across all required components.

• Adherence to SRM processes to proactively manage safety risks.

• Accountability at the executive level for safety performance.

Once submitted, the FAA’s Certificate Management Office (CMO) updates your organization’s status to reflect SMS compliance, followed by routine surveillance to validate your SRM and overall SMS performance.

Detailed List of Required Content for the Declaration of Compliance

The DOC must include specific content to demonstrate that your SMS, including SRM, meets Part 5 standards. Below is a detailed list of required elements, informed by FAA guidance such as Notice 8900.700 and Advisory Circular (AC) 120-92D, tailored to emphasize SRM integration.

1. Statement of Compliance

• A clear affirmation that your organization has developed and implemented an SMS that fully complies with 14 CFR Part 5.

• Example: “We, [Organization Name], certify that our Safety Management System, including Safety Risk Management processes, meets all requirements of 14 CFR Part 5.”

2. Organization Identification

• Your organization’s full legal name, certificate type (e.g., Part 135, Part 91.147, Part 21), and certificate number.

• Contact information for the accountable executive and SMS point of contact.

• Example: “[Organization Name], a Part 135 certificate holder (Certificate No. XXXX), located at [Address].”

3. SMS Implementation Overview

• A summary confirming that all four SMS components—Safety Policy, SRM, Safety Assurance, and Safety Promotion—are fully implemented.

• Specific mention of SRM processes, including hazard identification, risk assessment, and mitigation strategies.

• Example: “Our SMS includes documented SRM processes to identify hazards through employee reporting and data analysis, assess risks using a 5x5 risk matrix, and implement controls to maintain an acceptable level of safety.”

4. Safety Risk Management Details

• A description of your SRM processes to demonstrate compliance with Part 5 requirements (§§ 5.51–5.55).

• Key elements to include:

  • Hazard Identification: Methods for identifying hazards (e.g., safety reporting systems, flight data analysis, operational audits).

  • Risk Assessment: Tools or methodologies used to assess risk (e.g., risk matrix, likelihood-severity scoring).

  • Risk Mitigation: Examples of controls implemented to mitigate risks (e.g., revised procedures, additional training, equipment upgrades).

  • Monitoring: How SRM outcomes are monitored and reviewed (e.g., through Safety Assurance processes).

• Example: “Our SRM process identifies hazards via a confidential employee reporting system, assesses risks using a likelihood-severity matrix, and mitigates risks through targeted training and procedural updates, with effectiveness monitored through quarterly safety reviews.”

5. Accountable Executive’s Commitment

• A statement from the accountable executive affirming their responsibility for SMS implementation and performance.

• Confirmation that the executive has reviewed SRM processes and safety performance data.

• Example: “As the accountable executive, I, [Name], confirm that I oversee our SMS, regularly review SRM outcomes, and ensure resources are allocated to address identified risks.”

6. Signature and Date

• The accountable executive’s signature (or that of another senior management member with equivalent authority).

• The date of submission to the FAA.

• Example: “Signed: [Name], Accountable Executive, [Date].”

7. Compliance with Regulatory Deadlines

• A statement confirming that the SMS was implemented by the required deadline for your organization type.

• Example: “Our SMS was fully implemented by May 28, 2027, in accordance with the FAA’s SMS Final Rule for Part 135 operators.”

8. Supporting Documentation Reference (Optional)

• A note indicating that supporting documentation (e.g., SMS manual, SRM records, training logs) is available for FAA review.

• Example: “Supporting documentation, including our SMS manual and SRM records, is maintained at [Location] and available upon request per §§ 5.9(d) and 5.95.”

Related Aviation SMS Manual Articles

• How to Create Your Aviation SMS Manual
• Tips Writing SMS Manuals With Aviation Safety Database Solutions
• 3 Best Practices for Your Aviation SMS Manual

Steps to Prepare and Submit the Declaration of Compliance

To ensure your DOC is accurate and complete, follow these steps:

1. Strengthen SRM Processes: Ensure your SRM processes are robust, documented, and operational. Conduct a gap analysis against Part 5 requirements to identify and address deficiencies. SMS Pro integrates this gap analysis model to facilitate regulatory compliance management.

2. Compile Required Content: Use the list above to draft your DOC, ensuring all elements are addressed with specific references to SRM.

3. Engage the Accountable Executive: Review the DOC with the accountable executive, ensuring they understand their role in SRM and SMS oversight.

4. Validate Compliance: Conduct an internal audit to confirm that SRM and other SMS components are fully implemented and effective.

5. Submit to the FAA: Submit the DOC to your local FAA Certificate Management Office (CMO) in a form and manner acceptable to the FAA (e.g., via email or FAA portal) by your compliance deadline.

Best Practices for SRM and DOC Preparation

• Integrate SRM Across Operations: Ensure SRM is embedded in all operational areas, from flight operations to maintenance, to create a holistic safety approach.

• Use Data-Driven Tools: Leverage flight data monitoring, safety reporting systems, and risk assessment tools to enhance SRM effectiveness. You can be using SMS Pro tools within two days to save time and money on this process.

• Document Everything: Maintain detailed records of hazard identification, risk assessments, and mitigation actions to support your DOC and FAA audits. SMS Pro organizes and secures your safety data.

• Train Your Team: Provide SRM training to employees to ensure they understand their role in identifying and reporting hazards.

• Seek FAA Guidance: Refer to FAA resources like AC 120-92D and Notice 8900.700 for detailed SRM and DOC requirements.

Conclusion: Elevate Safety Through SRM and Compliance

A well-prepared Declaration of Compliance not only ensures FAA SMS compliance but also reinforces your organization’s commitment to safety through effective Safety Risk Management. By including the required content outlined above, aviation safety managers and accountable executives can confidently affirm their SMS meets 14 CFR Part 5 standards.

Take proactive steps today—strengthen your SRM processes, compile a thorough DOC, and submit it to the FAA to achieve compliance and enhance safety. For additional support, contact the FAA SMS Program Office at 9-NATL-SMS-ProgramOffice@faa.gov or visit www.faa.gov for more resources.