For new aviation safety managers, documenting a safety management system (SMS) is a critical yet daunting task, especially when it comes to the risk matrix. The risk matrix is a cornerstone of aviation safety risk management, categorizing risks by severity and likelihood to guide decision-making.

To meet Federal Aviation Administration (FAA) compliance requirements under 14 CFR Part 5, safety managers must document specific actions for each risk level (e.g., low, medium, high) to ensure hazards are mitigated effectively.

This evergreen guide provides a step-by-step approach to documenting these actions, helping new safety managers create clear, FAA-compliant SMS documentation that enhances safety and streamlines audits.

Why Documenting Actions for Each Risk Level Matters

The FAA mandates that aviation organizations—airlines, airports, and maintenance facilities—implement an SMS that includes robust risk management processes, as outlined in Advisory Circular 120-92B. The risk matrix helps prioritize hazards, but without documented actions for each risk level, organizations risk regulatory non-compliance, inconsistent safety practices, and unaddressed hazards.

Clear documentation demonstrates to FAA auditors that your SMS is proactive, traceable, and aligned with the acceptable level of safety (ALoS).

This guide outlines best practices for documenting specific actions for each risk level, tailored to FAA requirements. Whether you’re new to SMS or refining your processes, these steps will help you build a compliant and effective risk management framework.

Step 1: Understand FAA Risk Management Requirements

Before documenting actions, familiarize yourself with FAA SMS requirements. The FAA’s Order 8040.4C and SMS Voluntary Program emphasize:

• Hazard Identification: Recognizing potential safety issues, such as runway incursions or equipment failures.

• Risk Assessment: Using a risk matrix to evaluate severity and likelihood.

• Risk Control: Implementing actions to mitigate risks to an acceptable level.

• Documentation: Maintaining detailed records of risk assessments and actions for audits.

The risk matrix typically categorizes risks into levels (e.g., low, medium, high) based on severity (negligible, minor, major, catastrophic) and likelihood (improbable, remote, occasional, frequent). Actions must be tailored to each level to ensure compliance and safety.

Related Articles on Aviation SMS Risk Matrix

• What Is a Risk Matrix and Risk Assessment in Aviation SMS
• How to Define Severity and Likelihood Criteria on Your Risk Matrix
• How to Create Your Risk Matrix for Risk Assessments in Aviation SMS

Step 2: Define Risk Levels and Criteria

To document specific actions, first establish clear risk levels within your risk matrix. A standard 5x5 matrix combines severity and likelihood to assign risk levels. For example:

• Low Risk: Minimal impact and unlikely to occur (e.g., Negligible + Improbable).

• Medium Risk: Moderate impact or occasional occurrence (e.g., Major + Occasional).

• High Risk: Severe impact or frequent occurrence (e.g., Catastrophic + Frequent).

2.1 Document Severity and Likelihood Scales

Clearly define severity and likelihood categories in your SMS manual. For instance:

• Severity: Negligible (minor delays), Minor (small injuries), Major (serious injuries), Catastrophic (fatalities).

• Likelihood: Improbable (rare), Remote (unlikely), Occasional (several times), Frequent (regularly).

2.2 Set Action Thresholds

Specify which risk levels require action. For example:

• Low: Monitor periodically, no immediate action required.

• Medium: Implement mitigations within a defined timeframe.

• High: Take immediate action to reduce risk.

Document these criteria to ensure consistency and FAA compliance.

Step 3: Develop Specific Actions for Each Risk Level

For each risk level, define tailored actions that address the hazard’s severity and likelihood. These actions should be specific, measurable, achievable, relevant, and time-bound (SMART).

3.1 Actions for Low Risk

Low-risk hazards typically have minimal impact and low likelihood. Actions focus on monitoring rather than intensive intervention. Examples include:

• Action: Conduct quarterly reviews of the hazard to ensure it remains low risk.

• Example Hazard: Minor delays due to occasional gate congestion.

• Documented Action: “Monitor gate congestion during quarterly safety audits. Record findings in SMS database. Responsible: Operations supervisor. Frequency: Every 3 months.”

3.2 Actions for Medium Risk

Medium-risk hazards require proactive mitigations to reduce severity or likelihood. Actions should be practical and targeted. Examples include:

• Action: Implement training, procedural changes, or equipment upgrades.

• Example Hazard: Taxiway congestion during peak hours (Major + Occasional = Medium).

• Documented Action: “Introduce taxiway flow management training for ground crews and deploy additional staff during peak hours. Complete training by Q2 2025. Responsible: Training coordinator. Measure: Reduce congestion incidents by 15% within 6 months.”

3.3 Actions for High Risk

High-risk hazards demand immediate and comprehensive action to prevent severe consequences. Examples include:

• Action: Halt operations, redesign processes, or invest in significant safety enhancements.

• Example Hazard: Bird strikes during takeoff (Catastrophic + Occasional = High).

• Documented Action: “Install bird deterrent systems at runway ends, train ground crews on wildlife management, and adjust flight schedules to avoid peak bird activity. Complete by Q1 2025. Responsible: Wildlife management team. Measure: Reduce bird strike incidents by 25% within 12 months.”

Document each action’s rationale, linking it to the risk matrix assessment, to demonstrate FAA compliance.

Related Aviation SMS Risk Matrix Articles

• How to Define Your Risk Matrix in Aviation SMS
• Guide to Define Risk Matrix Probability and Severity in Aviation Safety
• Safety Chart: How to Monitor Aviation Risk Management Priorities Using Heat Maps

Step 4: Create a Standardized Documentation Template

To ensure consistency and audit readiness, develop a template for documenting actions for each risk level. A sample template might include:

• Hazard Description: Brief summary of the hazard (e.g., “Bird strikes during takeoff”).

• Risk Level: Low, Medium, or High, based on risk matrix.

• Initial Assessment: Severity, likelihood, and risk rating.

• Specific Actions: Detailed mitigation or monitoring steps.

• Responsible Party: Who will implement and monitor the action.

• Timeline: Deadline for completion.

• Metrics: Measurable outcomes to evaluate success.

• Residual Risk: Post-mitigation risk level.

• Approval: Sign-off by safety manager or accountable executive.

Include this template in your SMS manual, along with examples of completed entries for each risk level. For instance:

• Low Risk Example: “Monitor gate congestion quarterly to ensure no escalation. No immediate action required.”

• Medium Risk Example: “Train ground crews on taxiway procedures to reduce congestion incidents.”

• High Risk Example: “Install bird deterrents and adjust schedules to mitigate bird strikes.”

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Step 5: Integrate Actions with SMS Processes

Document how actions for each risk level integrate with other SMS components, such as:

• Safety Reporting: Link actions to hazards reported by employees.

• Safety Assurance: Use metrics to monitor action effectiveness (e.g., incident rate reductions).

• Safety Promotion: Train staff on actions and their role in safety.

For example, document how a high-risk action like “installing bird deterrents” is tracked via safety performance indicators (SPIs). Delayed milestones trigger corrective action plans. This demonstrates to the FAA that your SMS is cohesive and proactive.

Step 6: Ensure Traceability and Audit Readiness

FAA audits require traceable records of risk management actions. To meet this requirement:

• Centralize Records: Store documentation in a digital SMS platform or secure database.

• Use Version Control: Track changes to actions or risk assessments.

• Retain Records: Keep records for at least 5 years, per FAA guidelines.

Document your record-keeping procedures, including who maintains records and how they are accessed during audits. This ensures compliance with FAA’s SMS Voluntary Program.

Step 7: Train Staff on Documented Actions

Effective actions require staff understanding and implementation. Develop a training program that covers:

• Risk Matrix Overview: How risk levels are determined.

• Action Implementation: Specific steps for low, medium, and high-risk actions.

• Documentation Standards: How to complete the action template.

Include practical exercises, such as documenting actions for a hypothetical hazard like “fuel spills during refueling.” Document the training program, including schedules, materials, and attendance records, to demonstrate FAA compliance.

Related Aviation SMS Training Articles

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Step 8: Monitor and Evaluate Action Effectiveness

Actions must be monitored to ensure they achieve the intended outcomes. Document a monitoring process that includes:

• Safety Performance Indicators (SPIs): Track metrics like incident rates or compliance with action timelines.

• Regular Reviews: Conduct quarterly or annual reviews of actions to assess effectiveness.

• Corrective Measures: If an action fails to reduce risk, document additional mitigations and reassess.

For example, if bird strike incidents do not decrease after installing deterrents, document a new action: “Conduct a wildlife behavior study to refine deterrent placement.” This shows continuous improvement, a key FAA expectation.

Step 9: Leverage Technology for Efficiency

SMS software can streamline documentation and monitoring of risk level actions. Tools like SMS Pro or ABC offer:

• Automated risk matrix calculations.

• Digital templates for action documentation.

• Dashboards for tracking SPIs and action progress.

Document how your organization uses technology to support action documentation, highlighting efficiency and compliance benefits.

Related Aviation SMS Database Articles

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• How Long to Switch to New Aviation SMS Database?

Step 10: Prepare for FAA Audits

FAA audits assess SMS compliance, including documentation of risk level actions. To prepare:

• Organize Records: Ensure action documentation is complete, signed, and accessible.

• Demonstrate Consistency: Show that actions are consistently applied across risk levels.

• Highlight Effectiveness: Provide data (e.g., reduced incident rates) to prove action success.

Document an audit preparation checklist in your SMS manual, including steps to verify action records. This helps new safety managers navigate inspections confidently.

Common Pitfalls to Avoid

New safety managers may encounter challenges when documenting actions. Avoid these mistakes:

• Generic Actions: Tailor actions to specific risk levels rather than using vague solutions.

• Incomplete Documentation: Include all required details (e.g., metrics, timelines) in the template.

• Lack of Monitoring: Regularly evaluate actions to ensure ongoing effectiveness.

• Insufficient Training: Ensure staff are trained to implement and document actions.

Conclusion

Documenting specific actions for each risk level is a critical task for aviation safety managers. By

• defining clear risk levels,
• developing SMART actions,
• using standardized templates, and
• integrating with SMS processes, you can create FAA-compliant documentation that enhances safety and simplifies audits.

For new safety managers, the key is to follow a structured approach, leverage technology, and prioritize training and monitoring.

This process may seem complex, but with these best practices, it becomes manageable. Effective documentation of risk level actions not only ensures FAA compliance but also fosters a proactive safety culture. Start implementing these steps today to build a stronger, safer aviation operation.

Aviation SMS software reduces documentation nightmares and decreases the time auditors spend at your organization. What is your time worth? SMS Pro provides tools to facilitate SMS regulatory compliance.

Additional Resources

• FAA SMS Guidance

• Advisory Circular 120-92B

• Order 8040.4C