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How to Document the Risk Matrix Process for FAA Compliance

Posted by Christopher Howell on Aug 13, 2025 6:00:00 AM Find me on:

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For new aviation safety managers, creating aviation safety management system (SMS) documentation that meets Federal Aviation Administration (FAA) compliance standards can feel overwhelming. The risk matrix process is a cornerstone of aviation safety risk management, helping organizations identify, assess, and mitigate risks effectively.

Proper documentation ensures compliance, enhances safety, and streamlines audits. This guide outlines actionable steps to document the risk matrix process, tailored for FAA requirements, to help safety managers build a robust SMS.

Why Documenting the Risk Matrix Process Matters

The FAA mandates that aviation organizations, including airlines, airports, and maintenance facilities, implement an SMS under 14 CFR Part 5. A key component is the risk matrix, which categorizes risks based on severity and likelihood. Documenting this process demonstrates compliance, ensures consistency, and provides a clear framework for safety decision-making. For new safety managers, well-documented processes reduce confusion, improve training, and support continuous improvement.

This evergreen guide is designed to help you create clear, FAA-compliant documentation for your risk matrix process, even if you’re starting from scratch. Let’s dive into the steps.

Step 1: Understand FAA Requirements for Risk Management

Before documenting the risk matrix process, familiarize yourself with FAA SMS requirements. The FAA’s Advisory Circular 120-92B provides guidance on SMS implementation, emphasizing risk management. Key points include:

  • Risk Identification: Identify hazards in operations, such as runway incursions or equipment failures.

  • Risk Assessment: Evaluate risks using a standardized tool like a risk matrix.

  • Risk Mitigation: Develop controls to reduce risks to an acceptable level.

  • Documentation: Maintain records of risk assessments and mitigations for FAA audits.

Review FAA’s SMS Voluntary Program and Order 8040.4C for additional context. Understanding these requirements ensures your documentation aligns with regulatory expectations.

Step 2: Define the Risk Matrix Framework

A risk matrix is a visual tool that plots risks based on their severity (e.g., minor, major, catastrophic) and likelihood (e.g., improbable, occasional, frequent). To document this framework:

2.1 Establish Severity Categories

Define severity levels based on potential consequences, such as injury, equipment damage, or operational disruption. A common FAA-aligned scale includes:

  • Negligible: No significant impact (e.g., minor delays).

  • Minor: Limited impact (e.g., small injuries, slight damage).

  • Major: Significant impact (e.g., serious injuries, major damage).

  • Catastrophic: Severe consequences (e.g., fatalities, total loss).

2.2 Define Likelihood Categories

Assign likelihood levels based on how often a hazard might occur. A typical scale includes:

  • Improbable: Rare, unlikely in the system’s lifetime.

  • Remote: Unlikely but possible.

  • Occasional: Likely to occur several times.

  • Frequent: Expected to occur regularly.

2.3 Create the Matrix

Combine severity and likelihood into a grid. For example, a 5x5 matrix plots severity (rows) against likelihood (columns). Assign risk levels (e.g., low, medium, high) to each cell, with clear thresholds for action. For instance, “Catastrophic + Frequent = High Risk” requires immediate mitigation.

Document these definitions in a clear table or diagram. Include examples relevant to aviation, such as a “runway incursion” classified as “Major + Occasional = Medium Risk.”

Related Articles on Aviation SMS Risk Matrix

Step 3: Develop a Standardized Risk Assessment Process

Document a repeatable process for using the risk matrix. This ensures consistency across your organization. Include the following components:

3.1 Hazard Identification

Describe how hazards are identified, such as through safety reports, audits, or incident reviews. For example, a pilot’s report of a near-miss could trigger a risk assessment.

3.2 Risk Analysis

Explain how the risk matrix is applied. For each hazard:

  • Determine its severity and likelihood using the defined categories.

  • Plot the risk on the matrix to assign a risk level (low, medium, high).

  • Document the rationale for the assessment, including data sources (e.g., incident history).

3.3 Risk Evaluation

Define criteria for acceptable vs. unacceptable risks. For example, “High” risks may require immediate action, while “Low” risks may be monitored. Reference FAA guidance to align with acceptable levels of safety (ALoS).

3.4 Mitigation Strategies

Outline how mitigations are developed. For instance, a high-risk hazard like “bird strikes during takeoff” might lead to new wildlife control measures. Document:

  • Proposed controls (e.g., training, equipment upgrades).

  • Responsible parties (e.g., safety officer, operations manager).

  • Timelines for implementation.

3.5 Residual Risk Assessment

After mitigations, reassess the risk to determine its residual level. Document whether the risk is now acceptable or requires further action.

Step 4: Create a Documentation Template

To streamline documentation, develop a standardized template for risk assessments. This ensures all necessary information is captured and simplifies FAA audits. A sample template might include:

  • Hazard Description: Brief description of the hazard (e.g., “Taxiway congestion during peak hours”).

  • Assessment Date: When the risk was evaluated.

  • Risk Matrix Rating: Initial severity, likelihood, and risk level.

  • Mitigation Plan: Actions taken, responsible parties, and timelines.

  • Residual Risk: Post-mitigation risk level.

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

Include this template in your SMS manual, along with instructions for its use. Provide examples of completed assessments to guide new safety managers.

Related Aviation SMS Manual Articles

Step 5: Integrate with SMS Processes

The risk matrix process doesn’t operate in isolation—it’s part of the broader SMS. Document how it integrates with other SMS components, such as:

  • Safety Reporting: Link hazard identification to employee reporting systems.

  • Safety Assurance: Use risk assessments to monitor mitigation effectiveness.

  • Safety Promotion: Train staff on the risk matrix process and its role in safety culture.

For example, document how risk assessment outcomes feed into safety performance indicators (SPIs) or corrective action plans. This shows the FAA that your SMS is cohesive and proactive.

Step 6: Ensure Traceability and Accessibility

FAA auditors require traceable records. To meet this requirement:

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

  • Version Control: Track changes to the risk matrix process or assessments.

  • Accessibility: Ensure authorized personnel (e.g., safety officers, auditors) can access records easily.

Document your record-keeping procedures, including retention periods (FAA typically requires at least 5 years). Specify who is responsible for maintaining these records. SMS database software drastically reduces errors and speeds up future audit activities.

Related Aviation SMS Database Articles

Step 7: Train Staff on the Process

Effective documentation is useless if staff don’t understand it. Develop a training program to educate employees on the risk matrix process. Include:

  • Overview of the Risk Matrix: Explain severity, likelihood, and risk levels.

  • Practical Exercises: Use real-world scenarios (e.g., “Assess a fuel spill risk”).

  • Documentation Requirements: Train staff on completing the risk assessment template.

Document the training program, including schedules, materials, and attendance records. This demonstrates to the FAA that your organization prioritizes safety competency.

Step 8: Conduct Regular Reviews and Updates

The risk matrix process must evolve with your operations and regulatory changes. Document a review schedule (e.g., annually or after significant incidents). During reviews:

  • Evaluate the effectiveness of the risk matrix (e.g., Are risks accurately categorized?).

  • Update severity/likelihood definitions if needed.

  • Incorporate lessons learned from incidents or audits.

Document all changes and communicate them to staff. This ensures your process remains FAA-compliant and relevant.

Step 9: Prepare for FAA Audits

FAA audits assess SMS compliance, including risk management documentation. To prepare:

  • Organize Records: Ensure risk assessments are complete, signed, and accessible.

  • Demonstrate Consistency: Show that the risk matrix is applied uniformly across operations.

  • Highlight Integration: Provide examples of how risk assessments inform safety decisions.

Document an audit preparation checklist in your SMS manual. This helps new safety managers navigate FAA inspections confidently.

Related Aviation SMS Audit Articles

Step 10: Leverage Technology for Efficiency

Modern SMS software can simplify risk matrix documentation. Tools like SMS Pro's Aviation Safety Management Software or ABC offer features like:

  • Automated risk matrix calculations.

  • Digital templates for assessments.

  • Real-time reporting for audits.

Document how your organization uses technology to support the risk matrix process. This shows the FAA that you’re leveraging best practices.

Related Articles on Aviation Safety Software Benefits

Common Pitfalls to Avoid

New safety managers often face challenges when documenting the risk matrix process. Avoid these mistakes:

  • Vague Definitions: Ensure severity and likelihood categories are specific and FAA-aligned.

  • Incomplete Records: Always document the full risk assessment cycle, from identification to mitigation.

  • Lack of Training: Staff must understand the process to use it effectively.

  • Static Processes: Regularly update documentation to reflect operational changes.

Conclusion

Documenting the risk matrix process for FAA compliance is a critical task for aviation safety managers. By following these steps—

  • understanding FAA requirements,
  • defining the risk matrix,
  • standardizing assessments, and
  • integrating with SMS—you can create clear, actionable documentation that enhances safety and simplifies audits.

For new safety managers, the key is to start with a structured approach, leverage templates and technology, and prioritize training and reviews.

This process may seem daunting, but with the right framework, it becomes manageable. Your documented risk matrix process will not only ensure FAA compliance but also foster a proactive safety culture in your organization. Start today, and build a foundation for long-term safety success.

SMS Pro's customizable risk matrix and documentation management reduces the labor associated with managing regulatory compliant SMS. Need some help? Let us be your SMS Partner.

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Additional Resources

  • FAA SMS Guidance

  • Advisory Circular 120-92B

  • Order 8040.4C

Topics: Aviation SMS Implementation, 2-Safety Risk Management, FAA Compliance

Site content provided by Northwest Data Solutions is meant for informational purposes only. Opinions presented here are not provided by any civil aviation authority or standards body.

 

 

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