As an aviation safety manager or accountable executive, implementing effective mitigations to reduce risks is a cornerstone of a robust Safety Management System (SMS) under 14 CFR Part 5.

The FAA requires organizations—whether Part 121, Part 135, Part 91.147, or certain Part 21 certificate holders—to proactively identify hazards, assess risks, and implement risk controls to ensure safety risks are reduced to an acceptable level.

This comprehensive guide provides a step-by-step process to develop and implement mitigations in a form and manner acceptable to the FAA, complete with practical examples and tips to foster compliance and enhance safety.

This resource is designed to help you navigate the Safety Risk Management (SRM) process, align with FAA expectations, and build a stronger safety culture, regardless of your organization’s size or operational complexity.

Understanding Mitigations in FAA Part 5 SMS

Under 14 CFR Part 5, mitigations are specific actions or controls designed to reduce the likelihood or severity of identified safety risks to an acceptable level (§ 5.51–5.55). These mitigations are developed through the Safety Risk Management (SRM) process, which is one of the four core SMS pillars, alongside Safety Policy, Safety Assurance, and Safety Promotion. The FAA expects mitigations to be practical, measurable, and integrated into your operations, with ongoing monitoring to ensure effectiveness.

Why Mitigations Matter

• Regulatory Compliance: Meets FAA requirements for proactive risk management.

• Safety Enhancement: Reduces the potential for incidents or accidents.

• Operational Efficiency: Optimizes resources by targeting high-priority risks.

• Safety Culture: Demonstrates commitment to safety, encouraging employee trust and engagement.

Related Articles on Mitigations in Aviation SMS

• What Is Risk Mitigation in Aviation SMS
• The 5 Risk Mitigation Strategies in Aviation SMS Programs
• Risk Mitigation Best Practices in Aviation Safety Management

Step-by-Step Guide to Implementing Mitigations

The following steps outline a comprehensive process for implementing mitigations to reduce risks to an acceptable level, aligned with FAA SRM requirements. Each step includes actionable guidance and examples to illustrate application in real-world aviation operations.

Step 1: Identify Hazards

Objective: Recognize potential sources of harm within your operations.

How to Do It:

• Collect data from multiple sources: employee hazard reports, incident/accident reviews, audits, flight data monitoring, and voluntary programs like ASAP or FOQA.

• Engage cross-functional teams (e.g., pilots, maintenance technicians, dispatchers) to ensure comprehensive hazard identification.

• Use tools like brainstorming sessions, checklists, or process flow diagrams to map operational risks.

Example:

At XYZ Air Tours, a Part 91.147 operator, a pilot reported frequent distractions during pre-flight checks due to passenger inquiries. The safety team also identified through maintenance logs that improper tire inspections led to a near-miss incident. These hazards—distractions and inspection oversights—were documented for further analysis.

Step 2: Assess Risks

Objective: Evaluate the likelihood and severity of each hazard to determine risk levels.

How to Do It:

• Use a risk assessment tool, such as a 5x5 risk matrix, to categorize risks based on likelihood (e.g., rare to frequent) and severity (e.g., negligible to catastrophic).

• Assign a risk level (e.g., low, medium, high) to prioritize mitigation efforts.

• Involve subject matter experts to ensure accurate assessments, considering operational context and historical data.

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

Example:

Risk Assessment for Pre-Flight Distractions

• Hazard: Passenger inquiries during pre-flight checks.

• Likelihood: Frequent (4/5, due to daily occurrences).

• Severity: Moderate (3/5, potential for missed checklist items).

• Risk Level: High (4x3=12 on a 25-point scale).

Risk Assessment for Tire Inspections

• Hazard: Improper tire inspections.

• Likelihood: Occasional (3/5, based on audit findings).

• Severity: Severe (4/5, risk of tire failure during landing).

• Risk Level: High (3x4=12).

Both risks were prioritized for mitigation due to their high risk levels.

Tip: Reference FAA’s AC 120-92B for risk matrix templates and SRM process guidance.

Step 3: Develop FAA SMS Mitigation Strategies

Objective: Design controls to reduce risk to an acceptable level.

How to Do It:

• Brainstorm potential aviation risk control examples, prioritizing those that eliminate the hazard or reduce its likelihood/severity.

• Consider the hierarchy of controls: elimination, substitution, engineering controls, administrative controls, and personal protective equipment (PPE).

• Ensure mitigations are specific, measurable, and feasible within your operational constraints.

• Document each mitigation, including its purpose and expected outcome.

Example:

Mitigations for Pre-Flight Distractions

• Control 1: Implement a “sterile cockpit” policy during pre-flight checks, prohibiting non-essential communication.

• Control 2: Train ground staff to manage passenger inquiries, redirecting them away from pilots during checks.

• Expected Outcome: Reduce distractions by 80%, lowering the likelihood to “rare” (1/5).

Mitigations for Tire Inspections

• Control 1: Update maintenance checklists to include mandatory tire pressure and tread depth checks.

• Control 2: Provide recurrent training for mechanics on tire inspection protocols.

• Expected Outcome: Reduce inspection errors, lowering likelihood to “rare” (1/5) and severity to “minor” (2/5).

Step 4: Implement Mitigations

Objective: Integrate controls into operational processes.

How to Do It:

• Update relevant procedures, manuals, or checklists to reflect new controls.

• Communicate changes to affected personnel through training, briefings, or safety bulletins.

• Allocate resources (e.g., budget, personnel, tools) to support implementation.

• Assign responsibilities to ensure accountability (e.g., safety manager oversees training, operations manager updates procedures).

Example:

Implementation Plan for Pre-Flight Distractions

• Action: Revise the operations manual to include the sterile cockpit policy, effective Month 1.

• Training: Conduct mandatory training for pilots and ground staff by Month 2, covering the policy and passenger management protocols.

• Resources: $5,000 for training materials and staff time.

• Responsibility: Safety Manager oversees training; Operations Manager updates manuals.

Implementation Plan for Tire Inspections

• Action: Update maintenance checklists in the maintenance tracking system by Month 1.

• Training: Schedule tire inspection training for mechanics by Month 3.

• Resources: $3,000 for training and $2,000 for checklist software updates.

• Responsibility: Maintenance Supervisor ensures checklist updates; Training Coordinator manages training.

Tip: Use existing systems (e.g., maintenance software, training platforms) to streamline implementation and reduce costs.

Step 5: Monitor and Evaluate Effectiveness

Objective: Verify that mitigations reduce risks as intended and identify new hazards.

How to Do It:

• Establish Safety Assurance (SA) processes to monitor mitigation performance, such as audits, inspections, or safety performance indicators (SPIs).

• Collect feedback from employees to assess control effectiveness and usability.

• Reassess risks periodically to confirm they remain at an acceptable level (e.g., low risk on the risk matrix).

• Document findings and adjust mitigations if needed, using the SRM process to address deficiencies.

Example:

Monitoring for Pre-Flight Distractions

• Method: Conduct monthly audits of pre-flight check compliance, tracking distraction-related errors.

• SPI: Percentage of distraction-free pre-flight checks (target: 95%).

• Outcome: After three months, audits showed a 90% reduction in distractions, with risk reduced to “low” (1x3=3).

• Adjustment: Increased ground staff training frequency to address minor non-compliance.

Monitoring for Tire Inspections

• Method: Review maintenance logs quarterly for tire inspection compliance.

• SPI: Number of tire-related maintenance discrepancies (target: 0 per quarter).

• Outcome: Zero discrepancies after six months, with risk reduced to “low” (1x2=2).

• Adjustment: None required; controls deemed effective.

Step 6: Document and Report

Objective: Maintain records of the SRM process for FAA audits and continuous improvement.

How to Do It:

• Document each SRM step: hazard identification, risk assessment, mitigations, implementation, and monitoring results.

• Use SMS Pro software tool or database to centralize records for easy access and reporting.

• Share findings with the accountable executive and SMS team during regular safety meetings.

• Submit reports to the FAA as required, especially during SMS audits or certification processes.

Example:

SRM Documentation for XYZ Air Tours

• Hazard Report: Pilot distraction during pre-flight checks (ID: HAZ-2025-001).

• Risk Assessment: High risk (4x3=12).

• Mitigations: Sterile cockpit policy, ground staff training.

• Implementation: Policy effective Month 1, training completed Month 2.

• Monitoring: 90% distraction reduction, risk reduced to low (3).

• Storage: Recorded in XYZ SMS software, accessible to the SMS team.

• Reporting: Presented at quarterly safety meeting, submitted to FAA CMO during annual audit.

Tip: Align documentation with FAA’s SMS Voluntary Program Guide for consistency and audit readiness.

Structuring Your Mitigation Process for FAA Compliance

To ensure your mitigation process is acceptable to the FAA, integrate it into your SMS documentation, such as the SMS Implementation Plan or SRM manual. Below is a suggested structure:

1. Introduction:

   • Explain the purpose of the SRM process and its role in Part 5 compliance.

2. Hazard Identification:

   • Describe data sources, tools, and team roles for identifying hazards.

3. Risk Assessment:

   • Detail the risk matrix and criteria for determining acceptable risk levels.

4. Mitigation Development:

   • Outline the process for designing and prioritizing controls, including the hierarchy of controls.

5. Implementation Plan:

   • Specify actions, timelines, resources, and responsibilities for each mitigation.

6. Monitoring and Evaluation:

   • Define SA methods, SPIs, and reassessment schedules.

7. Documentation and Reporting:

   • Describe record-keeping procedures and reporting protocols.

Formatting Tips:

• Use tables to summarize risk assessments or implementation plans.

• Include flowcharts to visualize the SRM process.

• Ensure clarity and professionalism for FAA review (e.g., PDF format, 12-point font).

Tips for FAA-Acceptable Mitigations

1. Engage Your CMO:

   • Consult your local FAA Certificate Management Office early to clarify SRM expectations. Request feedback on your risk matrix or mitigation strategies.

2. Tailor to Your Operation:

   • Scale mitigations to your organization’s size and complexity. Small Part 135 operators should prioritize simple, cost-effective controls.

3. Leverage Existing Programs:

   • Integrate data from ASAP, FOQA, or maintenance tracking systems to inform hazard identification and monitoring.

4. Involve Employees:

   • Encourage hazard reporting through a confidential, non-punitive system to ensure comprehensive risk identification.

5. Use Measurable Metrics:

   • Define clear SPIs to track mitigation effectiveness, such as incident rates or compliance percentages.

6. Reference FAA Guidance:

   • Align with AC 120-92B, AC 21-58 (for Part 21 operators), and Order 8120.24 for SRM best practices.

Common Pitfalls to Avoid

• Overly Complex Mitigations: Avoid controls that are impractical or resource-intensive for your operation.

• Inadequate Monitoring: Failing to track mitigation effectiveness can lead to undetected risks.

• Poor Documentation: Incomplete or disorganized records may result in FAA audit findings.

• Ignoring Employee Input: Excluding frontline staff from hazard identification can miss critical risks.

• Static Processes: Failing to reassess risks periodically can allow new hazards to emerge unnoticed.

Example SRM Process for Mitigations

Below is a simplified example of the SRM process applied to a fictional Part 135 operator, XYZ Air Tours, to illustrate the steps and outcomes.

SRM Process: Mitigating Pre-Flight Distractions

1. Hazard Identification

• Source: Pilot hazard report via SMS Pro portal.

• Hazard: Passenger inquiries disrupting pre-flight checks.

• Team: Safety Manager, Operations Manager, Pilot Representative.

2. Risk Assessment

• Tool: 5x5 risk matrix (likelihood x severity).

• Score: Likelihood (4/5), Severity (3/5), Risk Level: High (12/25).

• Acceptable Level: Low risk (<5).

3. Mitigation Development

• Controls:

  • Sterile cockpit policy during pre-flight checks.

  • Train ground staff to handle passenger inquiries.

• Outcome: Reduce likelihood to “rare” (1/5).

4. Implementation

• Actions: Update operations manual, conduct training.

• Timeline: Policy effective Month 1, training by Month 2.

• Resources: $5,000 budget, Safety Manager oversees.

5. Monitoring

• Method: Monthly audits of pre-flight compliance.

• SPI: 95% distraction-free checks.

• Result: 90% reduction, risk reduced to low (1x3=3).

6. Documentation

• Record: Stored in SMS Pro software (ID: HAZ-2025-001).

• Report: Shared at safety meeting, submitted to FAA CMO.

Additional Resources

• FAA SMS Website: Access tools and FAQs at www.faa.gov.

• Advisory Circulars: Review AC 120-92B (SMS for Aviation Service Providers) and AC 21-58 (Part 21 SMS).

• ICAO Annex 19: Understand global SMS standards for alignment.

• SMS Program Office: Contact 9-NATL-SMS-ProgramOffice@faa.gov for support.

• Voluntary Programs: Leverage ASAP and FOQA data for SRM inputs.

Conclusion

Implementing mitigations to reduce risks to an acceptable level is a critical responsibility for aviation safety managers and accountable executives under FAA Part 5.

By following this step-by-step guide

1. identifying hazards,
2. assessing risks,
3. developing and implementing controls,
4. monitoring effectiveness, and
5. documenting outcomes, you can ensure compliance and enhance safety across your operations.

Use the examples provided to tailor your SRM process, engage with your FAA CMO, and foster a proactive safety culture.

Start strengthening your SMS today by applying these proven mitigation strategies. For additional support, explore the FAA resources above or contact our team for expert guidance or SMS Pro software tools to implement effective mitigation measures.