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.
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.
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.
Requirement: Develop and maintain a description of your aviation-related processes, procedures, and activities (§ 5.17).
How to Write It:
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.
Requirement: Establish a safety policy that defines management commitment, objectives, and accountability (§ 5.21–5.25).
How to Write It:
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.
Requirement: Develop processes to identify hazards, assess risks, and implement controls (§ 5.51–5.55).
How to Write It:
Example:
Safety Risk Management Process
ABC Charter Airlines will use a five-step SRM process:
- Hazard Identification: Collect data from employee reports, flight data monitoring, and maintenance logs.
- Risk Assessment: Evaluate hazards using a 5x5 risk matrix (severity vs. likelihood) to prioritize risks.
- Risk Control Development: Design mitigations, such as additional training or equipment upgrades.
- Implementation: Integrate controls into operational procedures (e.g., update checklists).
- 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.
Requirement: Establish processes to evaluate risk control effectiveness and identify new hazards (§ 5.71–5.75).
How to Write It:
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.
Requirement: Foster a safety culture through training, communication, and employee engagement (§ 5.91–5.93).
How to Write It:
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.
Requirement: Provide a phased timeline for SMS development and integration (§ 5.19).
How to Write It:
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.
Requirement: Identify resources (personnel, budget, tools) and assign responsibilities.
How to Write It:
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.
Requirement: Incorporate existing safety programs and address gaps to meet Part 5 requirements.
How to Write It:
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.
To ensure your plan is clear and acceptable to the FAA, follow this structure:
Formatting Tips:
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, 2025Executive 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
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
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!
Consider SMS Pro for SMS tools to reduce the SMS documentation burden.
Last updated in June 2026.