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How to Manage Risk Acceptance in Your Aviation SMS Manual

Written by Jamie Adams | Dec 30, 2025 11:00:00 AM

Manage Risk Acceptance in Aviation SMS Manuals

Managing risk acceptance is a critical component of an aviation Safety Management System (SMS) manual, as outlined in TOC 6.1–6.5. It ensures that residual risks, after mitigation, are formally evaluated and accepted by appropriate authorities, supporting Management of Change (MOC) and compliance with International Civil Aviation Organization (ICAO), Federal Aviation Administration (FAA), and European Union Aviation Safety Agency (EASA) standards.

For safety managers, consultants, and accountable executives, a structured risk acceptance process reduces compliance risks by 15%, as evidenced by client audits. This guide provides a step-by-step approach to managing risk acceptance authority, leveraging tools to ensure effectiveness for operators from small flight schools to global airlines.

Step 1: Understand Risk Acceptance and Its Role in SMS

Risk acceptance involves formally acknowledging and approving residual risks that remain after mitigation efforts. According to ICAO Doc 9859, this process ensures risks are reduced to an acceptable level, as defined by the organization’s safety policy. SKYbrary’s SMS framework emphasizes that risk acceptance is integral to Safety Risk Management (SRM) and MOC, requiring clear documentation and accountability.

Review What is a Risk in Aviation Safety Management Systems to understand the distinction between hazards, risks, and acceptable levels of safety (ALoS). For example, a small fixed-base operator (FBO) might accept the residual risk of minor fueling errors after implementing training, while an airport could accept low-likelihood runway risks post-mitigation. This step aligns new safety managers or experienced professionals with FAA Part 5 or EASA Part-ORA requirements.

Key actions:

  • Study ICAO Annex 19 and FAA Part 5 for risk acceptance requirements.
  • Define ALoS criteria based on organizational risk tolerance.
  • Identify scenarios requiring formal risk acceptance, such as MOC or new operations.

Step 2: Develop a Risk Acceptance Framework

A risk acceptance framework outlines the process for evaluating and approving residual risks, including roles, criteria, and documentation. FAA Advisory Circular 120-92B mandates that the accountable executive or designated authority approve high-level risks, while lower risks may be delegated to safety managers. Use tools like the Risk Matrix to categorize risks by severity and likelihood, guiding risk acceptance decisions.

For instance, a Part 135 operator might use a risk matrix to accept low-severity fatigue risks after scheduling adjustments, while a maintenance, repair, and overhaul (MRO) organization could approve equipment risks post-maintenance upgrades. A client airline reduced compliance risks by 15% by standardizing its framework, as noted in The 5 Risk Mitigation Strategies in Aviation SMS. Ensure the framework is scalable for small operators or complex utilities.

Key actions:

  • Define criteria for risk acceptance based on severity and likelihood.
  • Assign approval roles, such as accountable executive for high risks.
  • Document the framework in the SMS manual (TOC 6.2).

Step 3: Integrate Risk Acceptance into MOC Processes

Management of Change (MOC) requires risk acceptance to evaluate the safety implications of operational changes, such as new equipment or procedures. ICAO and FAA standards mandate formal MOC risk assessments, with acceptance decisions documented. Use tools like SMS Pro's Manage Change module to streamline MOC risk acceptance, ensuring traceability and compliance.

For example, a commercial operator introducing a new aircraft type might accept residual training risks after implementing a pilot program, while a small FBO could approve risks from a new fueling system post-evaluation. A client airport saved 100 hours annually by automating MOC documentation using SMS Pro, as detailed in Understanding Management of Change in Aviation SMS. Ensure MOC decisions are reviewed by the safety manager and approved by the accountable executive.

Key actions:

  • Incorporate risk acceptance into MOC procedures.
  • Document MOC risk acceptance decisions with rationale and approvals.
  • Verify MOC compliance through regular audits.

Step 4: Document and Communicate Risk Acceptance Decisions

Clear documentation of risk acceptance decisions ensures traceability and accountability, as required by ICAO and FAA standards. Record the risk, mitigation measures, residual risk level, and approval details in the SMS manual. Use tools like SMS Pro's Aviation Safety Database to store and manage these records, facilitating audits and reviews.

Communicate decisions to relevant stakeholders, such as department heads or frontline staff, through safety newsletters, read and sign Message Board or safety meetings. For instance, a helicopter operator might inform pilots of accepted risks related to high-altitude operations, while an MRO could notify technicians about equipment risks. A client utility company improved engagement by 20% through transparent communication, as noted in A Key to Transparency in Aviation SMS.

Key actions:

  • Document risk acceptance decisions with clear rationale and approvals.
  • Store records in a centralized database for audit readiness.
  • Communicate decisions to stakeholders via appropriate channels.

Step 5: Monitor and Review Risk Acceptance Processes

Continuous monitoring ensures the risk acceptance process remains effective and compliant. Use key performance indicators (KPIs), such as the number of accepted risks reviewed or MOC approvals completed, to track performance. Regular audits, supported by SMS Pro's Auditing System, verify process alignment with FAA, EASA, or ICAO standards, as recommended in How to Conduct Internal SMS Audits.

A client airline reduced compliance risks by 15% by auditing its risk acceptance process annually, highlighting the value of evaluation. Update the process based on audit findings, new risks, or regulatory changes, ensuring it evolves with operational needs. This step is critical for consultants supporting complex operations like airports or commercial operators.

Key actions:

  • Establish KPIs to monitor risk acceptance effectiveness.
  • Conduct annual audits to evaluate the process.
  • Revise the process based on data, feedback, or regulatory updates.

Common Pitfalls to Avoid

Managing risk acceptance can be challenging, especially for organizations with complex changes or limited resources. Avoid these common mistakes:

  • Overlooking Residual Risks: Ensure all mitigated risks are formally evaluated.
  • Inadequate Documentation: Record all acceptance decisions with clear rationale.
  • Lack of Oversight: Involve the accountable executive in high-risk approvals.

By addressing these challenges, organizations can create a robust risk acceptance process, as evidenced by clients who achieved zero audit findings through systematic documentation and review.

Conclusion and Call to Action

Managing risk acceptance is essential for ensuring safe operations and regulatory compliance in an SMS. By understanding its role, developing a framework, integrating MOC, documenting decisions, and monitoring effectiveness, safety professionals can strengthen their safety program. Tools like SMS Pro’s Risk Matrix and Auditing System simplify the process, supporting operators of all sizes.

Ready to manage risk acceptance? Download free templates from Audit Resources or explore SMS Pro’s solutions at asms-pro.com to streamline your SMS manual development. Start enhancing your safety program today.