As an aviation safety manager or accountable executive, developing a Safety Management System (SMS) that complies with 14 CFR Part 5 is critical for ensuring safety and meeting Federal Aviation Administration (FAA) requirements.

A well-crafted SMS Implementation Plan is your roadmap to achieving this, outlining how your organization will establish, integrate, and maintain an SMS to proactively manage safety risks. This guide provides a step-by-step approach to writing a comprehensive Part 5 SMS Implementation Plan acceptable to your local FAA Certificate Management Office (CMO), complete with practical examples and tips for success.

Whether you’re a Part 135 operator, Part 91.147 air tour operator, or Part 21 certificate holder, this evergreen resource will help you navigate the process with confidence, ensuring compliance and fostering a robust safety culture.

What is a Part 5 SMS Implementation Plan?

A Part 5 SMS Implementation Plan is a formal document required by the FAA under 14 CFR Part 5 that details how your organization will develop and integrate a Safety Management System. The SMS is a structured, proactive approach to identifying hazards, managing risks, and ensuring continuous safety improvement. The plan must outline your organization’s timeline, processes, and resources to meet FAA standards, tailored to your operational scope and complexity.

The FAA requires the plan to be submitted in a form and manner acceptable to the Administrator during the certification process or within specified timelines (e.g., no later than November 28, 2024, for certain Part 21 certificate holders with licensing agreements) [Ref: 14 CFR § 5.19]. The CMO evaluates the plan to ensure it aligns with the four SMS components: Safety Policy, Safety Risk Management (SRM), Safety Assurance (SA), and Safety Promotion.

Why It Matters

• Regulatory Compliance: Meets FAA mandates for Part 121, Part 135, Part 91.147, and certain Part 21 operators.

• Proactive Safety: Identifies and mitigates risks before they lead to incidents or accidents.

• Organizational Efficiency: Enhances decision-making and resource allocation through structured processes.

• Safety Culture: Fosters a collaborative environment where safety is a shared responsibility.

Key Components of an SMS Implementation Plan

To create an FAA-acceptable SMS Implementation Plan, your document must address the following elements, as outlined in 14 CFR Part 5 and FAA guidance (e.g., Advisory Circular AC 120-92B, Order 8120.24). Below, we break down each component with actionable steps and examples.

1. FAA SMS Organizational System Description

Requirement: Develop and maintain a description of your aviation-related processes, procedures, and activities (§ 5.17).

How to Write It:

• Provide an overview of your organization’s operations, including size, scope, and complexity.

• Detail the aviation-related Part 5 SMS processes (e.g., flight operations, maintenance, training) and how they interact.

• Identify key personnel, including the accountable executive, safety manager, and SMS team.

Example:

Organizational System Description
ABC Charter Airlines, a Part 135 operator, conducts on-demand passenger and cargo flights across the U.S. using a fleet of 10 turboprop aircraft. Our operations include flight planning, crew training, aircraft maintenance, and customer service. The SMS will integrate with existing processes, such as our maintenance tracking system and crew scheduling software. The accountable executive, CEO Jane Doe, oversees the SMS, supported by Safety Manager John Smith and a cross-functional SMS team comprising representatives from operations, maintenance, and training.

2. Safety Policy

Requirement: Establish a safety policy that defines management commitment, objectives, and accountability (§ 5.21–5.25).

How to Write It:

• Articulate your organization’s commitment to safety as a core value.

• Define clear, measurable safety objectives (e.g., reduce maintenance-related incidents by 10% within 12 months).

• Designate the accountable executive and outline their responsibilities, including SMS oversight and resource allocation.

• Include a code of ethics and a confidential employee reporting system to encourage hazard reporting without fear of reprisal.

Example:

Safety Policy
At ABC Charter Airlines, safety is our top priority. We are committed to achieving the highest safety standards through proactive risk management and continuous improvement. Our safety objectives include maintaining a 100% compliance rate with FAA regulations and reducing operational hazards by 15% annually. The accountable executive, Jane Doe, is responsible for SMS implementation, resource allocation, and regular safety performance reviews. Employees are encouraged to report hazards via our confidential reporting system, accessible through our internal portal, with a guarantee of non-reprisal as outlined in our code of ethics.

Tip: Reference FAA’s AC 120-92B for guidance on crafting a safety policy that aligns with ICAO Annex 19 standards.

3. Safety Risk Management (SRM)

Requirement: Develop processes to identify hazards, assess risks, and implement controls (§ 5.51–5.55).

How to Write It:

• Describe how your organization will identify hazards (e.g., employee reports, audits, incident reviews).

• Outline the risk assessment process, including tools like risk matrices or fault tree analysis.

• Explain how risk controls will be developed, implemented, and monitored.

Example:

Safety Risk Management Process
ABC Charter Airlines will use a five-step SRM process:

1. Hazard Identification: Collect data from employee reports, flight data monitoring, and maintenance logs.

2. Risk Assessment: Evaluate hazards using a 5x5 risk matrix (severity vs. likelihood) to prioritize risks.

3. Risk Control Development: Design mitigations, such as additional training or equipment upgrades.

4. Implementation: Integrate controls into operational procedures (e.g., update checklists).

5. Monitoring: Track control effectiveness through quarterly audits.
   For example, a recent hazard report identified icing risks during winter operations. The SRM team assessed a “high” risk level and implemented mandatory de-icing training and updated pre-flight procedures.

4. Safety Assurance (SA)

Requirement: Establish processes to evaluate risk control effectiveness and identify new hazards (§ 5.71–5.75).

How to Write It:

• Detail methods for monitoring safety performance (e.g., audits, safety performance indicators).

• Describe how you’ll assess SMS effectiveness and correct deficiencies.

• Include a schedule for regular safety performance reviews by the accountable executive.

Example:

Safety Assurance Plan
ABC Charter Airlines will conduct monthly internal audits to evaluate SMS performance, focusing on compliance with risk controls and safety objectives. Key performance indicators include incident rates, hazard report submissions, and training completion rates. The accountable executive will review SA findings quarterly to identify new hazards or ineffective controls. For instance, if an audit reveals low hazard reporting, we will launch a safety promotion campaign to encourage participation. Deficiencies will be addressed using the SRM process to develop corrective actions within 30 days.

Tip: Align SA processes with existing quality assurance programs to streamline implementation.

5. Safety Promotion

Requirement: Foster a safety culture through training, communication, and employee engagement (§ 5.91–5.93).

How to Write It:

• Outline initial and recurrent SMS training for all employees, tailored to their roles.

• Describe communication channels (e.g., safety newsletters, briefings) to share safety information.

• Highlight initiatives to build a “just culture” where employees feel safe to report issues.

Example:

Safety Promotion Strategy
ABC Charter Airlines will provide SMS training during onboarding and annually thereafter, with role-specific modules for pilots, mechanics, and dispatchers. Monthly safety newsletters will share hazard reports, lessons learned, and safety tips. To promote a just culture, we will recognize employees who submit actionable hazard reports during quarterly safety meetings. For example, a mechanic’s report on a tool calibration issue led to a company-wide equipment audit, earning public recognition.

6. Implementation Timeline

Requirement: Provide a phased timeline for SMS development and integration (§ 5.19).

How to Write It:

• Break implementation into phases (e.g., planning, development, integration, full operation).

• Specify milestones and deadlines, typically spanning 12–36 months based on FAA guidance.

• Ensure the timeline is realistic and accounts for your organization’s size and resources.

Example:

Implementation Timeline

• Month 1–3: Form SMS team, draft safety policy, and develop organizational system description.

• Month 4–6: Design SRM and SA processes, begin employee training.

• Month 7–12: Pilot SRM and SA processes, refine based on feedback.

• Month 13–18: Fully integrate SMS into operations, conduct initial audits.

• Month 19–36: Achieve full SMS operation, maintain continuous improvement.
  This 36-month timeline aligns with FAA expectations for a Part 135 operator of our size and complexity.

Tip: Reference FAA Order 8120.24 for timeline expectations, especially for Part 21 organizations.

7. Resources and Responsibilities

Requirement: Identify resources (personnel, budget, tools) and assign responsibilities.

How to Write It:

• List personnel involved in SMS implementation, including their roles and qualifications.

• Estimate budget needs for training, software, or consultants.

• Specify tools, such as SMS software or risk assessment templates.

Example:

Resources and Responsibilities

• SMS Team: Safety Manager John Smith (lead, 10 years’ experience), Operations Manager, Maintenance Supervisor, and Training Coordinator.

• Budget: $50,000 for Year 1, covering training ($20,000), SMS Pro software ($15,000), and consulting ($15,000).

• Tools: Adopt XYZ SMS software for hazard tracking and reporting.
  The Safety Manager oversees SRM and SA processes, while the Training Coordinator develops safety promotion materials.

8. Gap Analysis and Existing Programs

Requirement: Incorporate existing safety programs and address gaps to meet Part 5 requirements.

How to Write It:

• Conduct a gap analysis to compare current safety practices with Part 5 standards.

• Describe how existing programs (e.g., ASAP, FOQA) will be integrated into the SMS.

• Outline steps to address identified gaps, such as new processes or training.

Example:

Gap Analysis Summary
A gap analysis revealed that ABC Charter Airlines has a robust ASAP program but lacks formalized SRM processes. We will integrate ASAP data into the SMS hazard identification process and develop a risk assessment matrix to address this gap. Additional training on SRM will be provided to the SMS team by Month 6. Our existing safety committee will be repurposed as the SMS team to streamline resources.

Tip: Use FAA’s SMS Voluntary Program Guide (available via the SMS Program Office) for gap analysis templates.

Structuring Your SMS Implementation Plan

To ensure your plan is clear and acceptable to the FAA, follow this structure:

1. Cover Page:

   • Title: “Safety Management System Implementation Plan”

   • Organization name, certificate type (e.g., Part 135), and submission date.

   • Contact information for the accountable executive and safety manager.

2. Table of Contents:

   • List sections with page numbers for easy navigation.

3. Executive Summary:

   • Briefly summarize the plan’s purpose, scope, and timeline (1–2 paragraphs).

4. Main Sections:

   • Organizational System Description

   • Safety Policy

   • Safety Risk Management

   • Safety Assurance

   • Safety Promotion

   • Implementation Timeline

   • Resources and Responsibilities

   • Gap Analysis and Existing Programs

5. Appendices:

   • Include supporting documents, such as risk assessment templates, training syllabi, or organizational charts.

Formatting Tips:

• Use clear headings and subheadings.

• Include tables or charts for timelines and resource breakdowns.

• Ensure the document is professional, error-free, and easy to read (e.g., 12-point font, PDF format).

Tips for FAA Submission Success

1. Engage with Your CMO Early:

   • Contact your local FAA Certificate Management Office before submission to discuss expectations and clarify requirements. Request a pre-certification briefing from the Certification and Evaluation Program Office (CEPO).

2. Align with FAA Guidance:

   • Reference key documents, such as AC 120-92B, AC 21-58 (for Part 21 organizations), and Order 8120.24. These are available on the FAA website (www.faa.gov).

3. Leverage Existing Resources:

   • Integrate voluntary programs like ASAP or FOQA to demonstrate compliance and reduce implementation costs.

4. Involve All Stakeholders:

   • Include representatives from operations, maintenance, and training in the SMS team to ensure buy-in and comprehensive hazard identification.

5. Test and Refine:

   • Pilot SRM and SA processes before full implementation to identify and address weaknesses.

6. Document Everything:

   • Maintain records of gap analyses, training sessions, and SRM outcomes to demonstrate compliance during FAA audits.

Common Pitfalls to Avoid

• Lack of Specificity: Vague descriptions of processes or timelines may lead to FAA rejection. Provide concrete examples and measurable objectives.

• Ignoring Scalability: Ensure the plan is tailored to your organization’s size and complexity. Small operators should avoid overly complex processes.

• Neglecting Safety Culture: A weak safety promotion strategy can undermine employee engagement and SMS effectiveness.

• Missing Deadlines: Adhere to FAA submission timelines (e.g., 36 months from plan approval for full implementation) to avoid penalties.

Example SMS Implementation Plan Outline

Below is a simplified outline of an SMS Implementation Plan for a fictional Part 135 operator, ABC Charter Airlines, to illustrate the structure and content.

Safety Management System Implementation Plan
ABC Charter Airlines (Part 135)
Submission Date: June 1, 2025

Executive Summary
ABC Charter Airlines is committed to implementing a Part 5-compliant SMS to enhance safety across our on-demand charter operations. This plan outlines a 36-month timeline to develop and integrate SMS processes, leveraging existing safety programs like ASAP and aligning with FAA guidance (AC 120-92B).

1. Organizational System Description

• Overview of operations: 10 turboprop aircraft, 50 employees.

• Key processes: Flight operations, maintenance, crew training.

• SMS team: Safety Manager John Smith, Operations Manager, Maintenance Supervisor.

2. Safety Policy

• Commitment: Safety as the top priority, led by CEO Jane Doe.

• Objectives: 100% regulatory compliance, 15% hazard reduction annually.

• Confidential reporting system: Accessible via internal portal.

3. Safety Risk Management

• Process: 5-step SRM (hazard ID, risk assessment, control development, implementation, monitoring).

• Example: Icing hazard mitigated through training and procedure updates.

4. Safety Assurance

• Methods: Monthly audits, quarterly executive reviews.

• KPIs: Incident rates, hazard reports, training completion.

5. Safety Promotion

• Training: Annual SMS training for all employees.

• Communication: Monthly newsletters, quarterly safety meetings.

• Just culture: Recognition for hazard reporting.

6. Implementation Timeline

• Months 1–3: Form SMS team, draft policy.

• Months 4–36: Develop, pilot, and fully integrate SMS.

7. Resources and Responsibilities

• Budget: $50,000 for Year 1.

• Tools: SMS Pro software.

• Roles: Safety Manager leads SRM/SA, Training Coordinator handles promotion.

8. Gap Analysis

• Strengths: Robust ASAP program.

• Gaps: Lack of formalized SRM; addressed via training and risk matrix.

Appendices

• Risk assessment matrix

• SMS training syllabus

• Organizational chart

Additional Resources

• FAA SMS Website: Access guidance, 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 international SMS standards for alignment.

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

• Voluntary Programs: Explore ASAP and FOQA for integration ideas.

Conclusion

Writing a comprehensive Part 5 SMS Implementation Plan is a critical step for aviation safety managers and accountable executives to achieve FAA compliance and enhance safety. By addressing the

1. organizational system description,
2. safety policy,
3. SRM,
4. SA,
5. safety promotion,
6. timeline, resources, and
7. gap analysis, you can create a robust plan that meets FAA expectations.

Use the examples and tips provided to tailor your plan to your organization’s needs, engage with your CMO early, and leverage FAA guidance for success.

Start drafting your SMS Implementation Plan today to build a safer, more resilient aviation operation. For further assistance, contact your local FAA CMO or explore the resources listed above.

Call to Action: Need help developing your SMS Implementation Plan? Contact our team for expert consulting or download our free SMS checklist to get started!

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