Below is a sample SMS Implementation Plan for Part 135 operators using SMS Pro. Amend this plan to suit your needs. Do not simply copy and paste this entire document, as there are placeholders in the text to put your company details.
To submit an aviation Safety Management System (SMS) implementation plan for regulatory compliance, particularly for Part 135 operators under the FAA’s 14 CFR Part 5, you must meet specific requirements outlined in the regulation and associated guidance, such as Advisory Circular (AC) 120-92D and FAA Order 8900.1. These requirements ensure the SMS aligns with FAA standards and international frameworks like ICAO Annex 19. Below is a concise breakdown of the key requirements for submitting an SMS implementation plan, focusing on Part 135 operators, with the deadline for full compliance being May 28, 2027
This SMS Implementation Plan outlines how [Operator Name], a Part 135 operator, will develop, implement, and maintain a Safety Management System (SMS) compliant with 14 CFR Part 5 by May 28, 2027. The plan leverages SMS Pro (asms-pro.com) as the primary SMS database to manage regulatory requirements, streamline processes, and foster a proactive safety culture. The plan is scalable to our operation’s size (e.g., 8 aircraft, 30 employees) and addresses the four SMS pillars: Safety Policy, Safety Risk Management (SRM), Safety Assurance (SA), and Safety Promotion.
The purpose of this plan is to:
Meet FAA Part 5 requirements for SMS implementation.
Provide a roadmap with timelines, milestones, and responsibilities.
Utilize SMS Pro’s modules to ensure efficient compliance and safety management.
Submit a compliant plan to the FAA Certificate Management Office (CMO) for design validation.
This plan applies to all [Operator Name] operations under Part 135, including flight operations, maintenance, ground handling, and administrative functions. Note: Single-pilot operations, if applicable, will use simplified processes per 14 CFR § 5.3(c).
14 CFR Part 5: Safety Management Systems
FAA Advisory Circular (AC) 120-92D: Safety Management Systems for Aviation Service Providers
ICAO Annex 19 and Document 9859: Safety Management Manual
FAA Order 8900.1: Flight Standards Information Management System
Certificate Type: Part 135 (On-Demand and Commuter Operations)
Fleet: 8 aircraft (e.g., Cessna Citation, King Air)
Employees: 30 (12 pilots, 8 maintenance technicians, 5 dispatchers, 5 administrative)
Key Personnel:
Accountable Executive: [Name], CEO
Safety Manager: [Name], Director of Safety
Operations Manager: [Name]
Maintenance Manager: [Name]
Operational Scope: Charter flights, cargo transport, and medical evacuations across [Region/State].
The SMS will be implemented in four phases over 24 months (June 2025–June 2027), aligning with FAA deadlines and leveraging SMS Pro’s modules for efficiency. The plan includes a gap analysis, quick wins, and continuous improvement processes.
Objective: Assess current safety processes and develop the SMS framework.
Activities:
Conduct a gap analysis using SMS Pro’s Gap Analysis Module to compare existing safety processes against 14 CFR Part 5 requirements. Identify deficiencies in Safety Policy, SRM, SA, and Safety Promotion.
Define SMS goals (e.g., reduce incidents by 20%, achieve 100% employee reporting participation).
Secure top management commitment via a signed Safety Policy.
Identify key stakeholders (e.g., pilots, maintenance, dispatchers) for SMS development.
Configure SMS Pro’s Implementation Plan Manager Module to track tasks, timelines, and responsibilities.
Quick Wins:
Establish a confidential reporting system using SMS Pro’s Safety Reporting System (with mobile app) and Issue Manager module to encourage hazard reporting and manage submitted safety reports' investigations.
Draft an initial Safety Policy using SMS Pro’s Policies and Procedures Module.
Deliverables:
Gap analysis report (September 2025).
Draft Safety Policy signed by the Accountable Executive.
SMS Pro setup with user accounts for key personnel.
Responsible: Safety Manager, Accountable Executive.
SMS Pro Modules: Gap Analysis, Implementation Plan Manager, Issue Manager, Policies and Procedures, Safety Reporting System with mobile app.
Objective: Develop SMS processes and documentation for all four pillars.
Activities:
Safety Policy:
Finalize the Safety Policy, including non-punitive reporting and safety objectives, using SMS Pro’s Policies and Procedures Module.
Create an organizational chart for SMS roles via SMS Pro’s Org Chart module.
Document employee SMS duties and responsibilities by role using SMS Pro's Duties and Requirements Module.
Safety Risk Management (SRM):
Develop hazard identification and risk assessment processes using SMS Pro’s Hazard Register Module and Issue Manager Module.
Document system descriptions (e.g., flight operations, maintenance) using SMS Pro’s Proactive Hazard Analysis Tool (PHAT) templates.
Train safety team on SRM using SMS Pro’s SMS Induction Manager Module, based on users' role or position within the SMS, including all employees, safety manager and department heads.
Safety Assurance (SA):
Establish audit and performance monitoring processes using SMS Pro’s Audit Manager Module, PHAT and KPI Manager Module.
Implement corrective action workflows using SMS Pro’s Issue Manager and Corrective Action Module.
Safety Promotion:
Develop SMS training curricula for all employees using SMS Pro’s SMS Induction Manager Module templates.
Create safety communication plans (e.g., newsletters, briefings) via SMS Pro’s Safety Communications Modules, (Message Board, Newsletters, Meeting Manager).
Deliverables:
SMS Manual (draft) in SMS Pro’s Version Controlled Documentation Module (March 2026).
SRM and SA processes documented.
Initial training completed for 50% of employees.
Responsible: Safety Manager, Department Heads.
SMS Pro Modules: Policies and Procedures, Duties and Requirements, Hazard Register, Issue Manager, Proactive Hazard Analysis Tool (PHAT), Audit Manager, KPI Manager, Corrective Action, Training Manager, Newsletters, Message Board, Meeting Manager, Documentation.
Objective: Roll out SMS processes and test effectiveness.
Activities:
Implement SRM processes (e.g., hazard reporting, risk assessments) across all departments using SMS Pro’s Issue Manager Module and Proactive Hazard Analysis Tool Module.
Conduct initial audits using SMS Pro’s Audit Manager Module to assess compliance with Part 5 checklist template.
Monitor KPIs (e.g., hazard report rate, audit findings closed) via SMS Pro’s Goals & Objectives Module.
Deliver SMS training to all employees using SMS Pro’s SMS Induction Manager Module.
Communicate safety updates via SMS Pro’s Safety Communications Modules.
Test the Emergency Response Plan (ERP) using SMS Pro’s Emergency Response Plan Module.
Submit the SMS Implementation Plan to the FAA CMO for design validation (October 2026).
Quick Wins:
Launch a safety newsletter using SMS Pro’s Safety Communications Modules.
Recognize employees for hazard reporting to build a safety culture.
Deliverables:
FAA-submitted SMS Implementation Plan (October 2026).
100% employee training completion (December 2026).
Initial audit report and corrective actions logged in SMS Pro.
Responsible: Safety Manager, Accountable Executive, FAA Liaison.
SMS Pro Modules: Issue Manager, Proactive Hazard Analysis Tool, Audit Manager, KPI Manager, SMS Induction Manager, Safety Communications modules, Emergency Response Planning.
Objective: Achieve full SMS compliance and establish continuous improvement.
Activities:
Conduct regular audits and performance reviews using SMS Pro’s Audit Manager Module, Proactive Hazard Analysis Tool and KPI Manager Module.
Update SMS processes based on audit findings and operational changes via SMS Pro’s Version Controlled Documentation Module.
Submit a Declaration of Compliance to the FAA CMO by May 28, 2027, using SMS Pro’s Gap Analysis Module to verify Part 5 adherence and all gaps have been filled.
Maintain records (e.g., hazard reports, audits, training) in SMS Pro’s modules, including Regulatory Document Review Module for at least five years.
Enhance safety promotion through recurring training and communications using SMS Pro’s SMS Induction Manager Module and Safety Communications Modules, (Message Board, Newsletters, Meeting Manager).
Participate in regional safety groups to share data, tracked via SMS Pro’s Issue Manager Module's sharing features.
Deliverables:
Declaration of Compliance submitted to FAA (May 2027).
Updated SMS Manual reflecting operational feedback.
Annual safety performance report with KPIs.
Responsible: Safety Manager, Accountable Executive.
SMS Pro Modules: Audit Manager, KPI Manager, Gap Analysis Tool, Documentation, Regulatory Document Manager, SMS Induction Manager, Safety Communications tools, Issue Manager's safety data sharing.
A preliminary gap analysis conducted in June 2025 using SMS Pro’s Gap Analysis Module identified the following:
Strengths: Existing hazard reporting process, basic safety training program.
Gaps:
Lack of formalized SRM processes (e.g., risk assessment matrix).
Limited SA processes (e.g., no regular audits or KPIs).
Incomplete Safety Policy (e.g., missing non-punitive reporting clause).
Insufficient SMS training for non-flight personnel.
Action Plan: Address gaps in Phases 2–3 by developing processes and training using SMS Pro modules.
Accountable Executive: Approves Safety Policy, allocates resources, reviews safety performance.
Safety Manager: Oversees SMS development, manages SMS Pro database, coordinates training and audits.
Department Heads: Implement SRM and SA processes, ensure employee participation.
Employees: Report hazards via SMS Pro’s mobile app and Safety Reporting modules, complete training.
FAA Liaison: Coordinates with FAA CMO for plan submission and validation.
SMS Pro Software: Primary database for managing SMS processes (asms-pro.com).
Personnel: Safety Manager (full-time), support from Operations and Maintenance Managers.
Training: SMS Pro’s SMS Induction Manager Module, supplemented by FAA SMS Voluntary Program resources.
Budget: Estimated $50,000 for SMS Pro subscription, training, and audits (2025–2027).
|
Phase |
Duration |
Key Milestones |
Completion Date |
|---|---|---|---|
|
1: Planning |
Jun–Sep 2025 |
Gap analysis, Safety Policy draft, SMS Pro setup |
Sep 30, 2025 |
|
2: Development |
Oct 2025–Mar 2026 |
SMS Manual draft, SRM/SA processes, 50% training |
Mar 31, 2026 |
|
3: Implementation |
Apr–Dec 2026 |
Plan submission to FAA, 100% training, initial audits |
Dec 31, 2026 |
|
4: Full Compliance |
Jan–May 2027 |
Declaration of Compliance, updated SMS Manual |
May 28, 2027 |
Conduct quarterly reviews of SMS performance using SMS Pro’s Proactive Hazard Analysis Tool and KPI Manager Module.
Update SMS processes based on audit findings, hazard reports, and regulatory changes via SMS Pro’s Version Controlled Documentation Module and Policies and Procedures Module.
Engage employees through regular safety communications and recognition programs using SMS Pro’s Safety Communications Modules.
Initial Submission: Submit this SMS Implementation Plan to the FAA CMO by October 2026 for design validation, using SMS Pro’s Gap Analysis Module to ensure all Part 5 elements are addressed.
Declaration of Compliance: Submit by May 28, 2027, confirming full SMS implementation, supported by SMS Pro’s Regulatory Document Review Module for documentation.
This SMS Implementation Plan provides a structured, scalable approach to achieving 14 CFR Part 5 compliance by May 28, 2027. By leveraging SMS Pro’s comprehensive modules, [Operator Name] will streamline SMS development, enhance safety performance, and foster a proactive safety culture. Regular updates to this plan will reflect operational feedback and FAA guidance to ensure continuous improvement.
Signed:
[Name], Accountable Executive
[Date]
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