Aviation safety and operations questions, answered

Under 14 CFR 5.3, a safety management system is the formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of safety risk controls. It includes systematic procedures, practices, and policies for the management of safety risk.

Source: 14 CFR 5.3

Section 5.1 applies Part 5 to any person that holds or applies for a Part 119 certificate to conduct Part 121 or Part 135 operations, to any person that holds or applies for a letter of authorization under section 91.147, and to certain holders of Part 21 type and production certificates.

Source: 14 CFR 5.1

May 28, 2027. Part 135 operators and section 91.147 air tour operators authorized before May 28, 2024 must develop and implement an SMS that meets 14 CFR Part 5, and submit a declaration of compliance to the FAA, no later than that date (section 5.9(a)).

Source: 14 CFR 5.9

Section 5.9(b) requires anyone who applies for Part 135 or section 91.147 authorization on or after May 28, 2024, or whose application was pending on that date, to develop and implement an SMS that meets Part 5. The section sets no separate date, so applicants confirm the timing with their responsible FAA office.

Source: 14 CFR 5.9

The final rule, Safety Management Systems (89 FR 33068), was published on April 26, 2024 and took effect on May 28, 2024. It extended Part 5, which until then applied to Part 121 air carriers, to Part 135 operators, section 91.147 air tour operators, and certain Part 21 certificate holders.

Source: Safety Management Systems final rule, 89 FR 33068

Part 121 air carriers already had an SMS. Section 5.7(a) required each carrier with an SMS acceptable to the FAA on or before May 28, 2024 to revise it to meet the amended Part 5 no later than May 28, 2025.

Source: 14 CFR 5.7

Section 5.5(a) names safety policy (Subpart B), safety risk management (Subpart C), safety assurance (Subpart D), and safety promotion (Subpart E). Subpart F, on SMS documentation and recordkeeping, supports the four components; it is not a fifth one.

Source: 14 CFR 5.5

Section 5.21 requires safety objectives, a commitment to fulfill them, a clear statement about providing the resources the SMS needs, an employee safety reporting policy, a policy that defines unacceptable behavior and conditions for disciplinary action, an emergency response plan, and a code of ethics that makes safety the organization's highest priority. The accountable executive signs the policy, and it is documented and communicated throughout the organization.

Source: 14 CFR 5.21

The person an operator identifies under section 5.25(a) as the final authority over the operations conducted under its certificate or letter of authorization, who controls the financial and human resources those operations require and retains ultimate responsibility for their safety performance. The accountable executive ensures the SMS is implemented and performing, signs the safety policy, and regularly reviews safety performance.

Source: 14 CFR 5.25

Yes. Section 5.9(e) excepts a set of sections, such as those on employee reporting, disciplinary policy, and internal safety communication, for an organization whose single pilot is the sole individual performing all functions related to the safe operation of the aircraft. That organization still needs an SMS, and a single-pilot operator with other employees must meet every applicable section.

Source: 14 CFR 5.9

No. Section 5.5(a) requires an SMS appropriate to the size, scope, and complexity of the organization, which changes how a small operator meets each requirement but does not remove any of them. The only size-based exception is the single-pilot exception in section 5.9(e).

Sources: 14 CFR 5.5; 14 CFR 5.9

FAA Advisory Circular 120-92D lists the organization's name and certificate number, its physical address, and a statement that it has developed and implemented an SMS that meets Part 5. The accountable executive or another senior member of management signs it, and it goes to the certificate management office or responsible Flight Standards office.

Source: FAA AC 120-92D

No. The FAA does not review or approve an SMS in advance. The operator implements its SMS and submits the declaration of compliance, and the FAA validates the SMS during routine surveillance.

Source: FAA AC 120-92D

Section 5.97 sets four periods: safety risk management outputs for as long as the control remains relevant to the operation, safety assurance outputs for at least 5 years, SMS training records for as long as the individual is employed, and safety communications and hazard notifications to interfacing persons for at least 24 consecutive calendar months.

Source: 14 CFR 5.97

No. In the preamble to the 2024 rule, the FAA states that it does not endorse any specific product or third-party provider and does not pre-approve any service to meet the requirements. It adds that smaller or less complex organizations may use standard word processing software, spreadsheets, email, notebooks, and whiteboards.

Source: Final rule preamble, 89 FR 33068

New requirements include a code of ethics that makes safety the highest priority (section 5.21(a)(7)), interfaces in the system analysis (section 5.53(b)(5)), notification of hazards to interfacing persons (section 5.57), confidential reporting without concern of reprisal (section 5.71(a)(7)), and investigation of hazard notifications received from external sources (section 5.71(a)(8)).

Sources: Final rule, 89 FR 33068; 14 CFR Part 5

Advisory Circular 120-92D, Safety Management Systems for Aviation Service Providers, is the FAA's guidance on SMS under Part 5. It is dated May 21, 2024, took effect on May 28, 2024, and cancels AC 120-92B.

Source: FAA Advisory Circular 120-92D

ASAP is an FAA program whose focus is to encourage voluntary reporting of safety issues and events that come to the attention of employees of certain certificate holders.

Source: FAA Aviation Safety Action Program

EASA defines flight data monitoring as the proactive and non-punitive use of digital flight data from routine operations to improve aviation safety. ICAO calls the practice flight data analysis, and the FAA calls it flight operational quality assurance (FOQA).

Source: EASA, Annex I to Regulation (EU) No 965/2012

No. FAA Advisory Circular 120-82 states that no aircraft operator is required to have a FOQA program, and AC 120-92D notes that Part 5 does not require one. Helicopter air ambulances must carry a flight data monitoring system under 14 CFR 135.607, which is an equipment rule rather than a FOQA program.

Sources: FAA AC 120-82; FAA AC 120-92D; 14 CFR 135.607

ORO.AOC.130 requires a flight data monitoring programme, integrated in the operator's management system, for aeroplanes with a maximum certificated take-off mass of more than 27 000 kg. SPA.HOFO.145 requires one for commercial offshore helicopter operations with a helicopter equipped with a flight data recorder.

Source: EASA ORO.AOC.130 and SPA.HOFO.145

Annex 6, Part I requires the operator of an aeroplane with a maximum certificated take-off mass over 27 000 kg to establish and maintain a flight data analysis programme as part of its SMS. Since Amendment 49, aeroplanes over 15 000 kg with more than 19 passenger seats and a certificate of airworthiness first issued on or after 1 January 2027 must be equipped to support a programme, and their operators run one. ICAO recommends a programme for all aeroplanes over 15 000 kg.

Source: ICAO Annex 6, Amendment 49

No. Amendment 49 to Annex 6, applicable from 28 November 2024, lowered the recommendation to aeroplanes over 15 000 kg, and the standard for aeroplanes over 27 000 kg remains. Material that cites a 20 000 kg recommendation predates that change.

Source: ICAO Annex 6, Amendment 49

Under 14 CFR 13.401(e), except for criminal or deliberate acts, the FAA will not use an operator's FOQA data, or aggregate FOQA data, in an enforcement action against that operator or its employees when the data comes from a FOQA program the FAA has approved.

Source: 14 CFR 13.401

EASA's acceptable means of compliance describe three techniques: exceedance detection, which searches for deviations from aircraft flight manual limits and standard operating procedures; all-flights measurement, which defines what normal practice is; and statistics, series of data collected to support the analysis.

Source: EASA AMC1 ORO.AOC.130

In EASA guidance, only the gatekeeper is permitted to connect identifying data with an event, and the procedure that prevents disclosure of crew identity is written down and signed. ORO.AOC.130 requires the programme to be non-punitive and to protect the sources of the data.

Source: EASA ORO.AOC.130 and its guidance material

Yes, for aeroplanes with a maximum certificated take-off mass over 27 000 kg. The UK rule is ORO.AOC.130 in the retained Regulation (EU) No 965/2012, with the same threshold as EASA, and the CAA's CAP 739 is its good-practice guidance on running a programme.

Source: UK CAA CAP 739, Flight Data Monitoring

For some operators. Transport Canada Advisory Circular 700-068, dated 15 September 2026, states that the ICAO standard has been adopted for Subpart 705 operators conducting international scheduled operations.

Source: Transport Canada AC 700-068

Part 117 covers flightcrew members in Part 121 passenger operations. Section 117.23 limits flight time to 100 hours in any 672 consecutive hours and 1,000 hours in any 365 consecutive calendar days, and Table A in section 117.11 limits flight time in an unaugmented operation to 8 or 9 hours.

Sources: 14 CFR 117.23; 14 CFR 117.11

For an unaugmented crew, Table B in section 117.13 sets a maximum flight duty period of 9 to 14 hours, depending on the scheduled start time and the number of flight segments.

Source: 14 CFR 117.13

Before a flight duty period, a flightcrew member must have at least 10 consecutive hours of rest that provide at least 8 uninterrupted hours of sleep opportunity. Each flightcrew member must also have at least 30 consecutive hours free from all duty within the past 168 consecutive hours (section 117.25).

Source: 14 CFR 117.25

Section 117.23 limits a flightcrew member to 60 flight duty period hours in any 168 consecutive hours and 190 flight duty period hours in any 672 consecutive hours.

Source: 14 CFR 117.23

Not without an approved fatigue risk management system. Section 117.7(a) states that no certificate holder may exceed any provision of Part 117 unless approved by the FAA under a fatigue risk management system (FRMS).

Source: 14 CFR 117.7

ICAO defines an FRMS as a data-driven means of continuously monitoring and managing fatigue-related safety risks, based upon scientific principles and knowledge as well as operational experience, that aims to ensure relevant personnel are performing at adequate levels of alertness.

Source: ICAO fatigue management

Under ORO.FTL.210, duty is limited to 60 hours in any 7 consecutive days, 110 hours in any 14 consecutive days, and 190 hours in any 28 consecutive days. Flight time is limited to 100 hours in any 28 consecutive days, 900 hours in any calendar year, and 1,000 hours in any 12 consecutive calendar months.

Source: EASA ORO.FTL.210

For acclimatised crew, Table 2 in ORO.FTL.205 sets 13 hours as the maximum for a duty that starts between 0600 and 1329 with one or two sectors. Other start times, more sectors, and crew who are not acclimatised get lower limits.

Source: EASA ORO.FTL.205

Under ORO.FTL.235, minimum rest at home base is at least as long as the preceding duty period, or 12 hours, whichever is greater. Away from home base it is at least as long as the preceding duty period, or 10 hours, whichever is greater.

Source: EASA ORO.FTL.235

ORO.FTL.110(a) requires operators to publish duty rosters sufficiently in advance for crew members to plan adequate rest, and its acceptable means of compliance say rosters should be published 14 days in advance.

Source: EASA ORO.FTL.110 and AMC1 ORO.FTL.110(a)

Under OTAR Parts 121 and 135, each operator's fatigue management scheme must comply with Appendix F. For aeroplanes, Appendix F limits duty to 55 hours in any 7 consecutive days (which may be increased to 60), 95 hours in any 14 consecutive days, and 190 hours in any 28 consecutive days. Flight time is limited to 100 hours in 28 days and 900 hours in 12 months, and Table A sets a maximum flight duty period of 14 hours.

Source: OTAR Parts 121 and 135, Appendix F

Not directly, because the units differ. The FAA counts flight duty period hours in rolling windows of 168 and 672 consecutive hours, while EASA and the OTARs count duty hours in 7, 14, and 28 consecutive days, so a roster that is legal under one scheme is not automatically legal under another.

Sources: 14 CFR 117.23; EASA ORO.FTL.210

ICAO's fatigue management manual defines a pairing, also called a trip, as the time from when a flight crew member reports for duty until they return home from a sequence of flights and are released from duty. A roster is a list of planned shifts or work periods within a defined period of time, and it is how pairings are assigned to named crew.

Source: ICAO fatigue management

ICAO defines operational control as the exercise of authority over the initiation, continuation, diversion or termination of a flight in the interest of the safety of the aircraft and the regularity and efficiency of the flight. The FAA's definition in 14 CFR 1.1 is the exercise of authority over initiating, conducting or terminating a flight, and EASA's is the responsibility for the initiation, continuation, termination or diversion of a flight in the interest of safety.

Sources: 14 CFR 1.1; EASA, Annex I to Regulation (EU) No 965/2012

In domestic and flag operations, the pilot in command and the aircraft dispatcher are jointly responsible for the preflight planning, delay, and dispatch release of a flight (14 CFR 121.533 and 121.535). In supplemental operations, the pilot in command and the director of operations are jointly responsible (section 121.537).

Sources: 14 CFR 121.533; 14 CFR 121.535; 14 CFR 121.537

Under 14 CFR Part 65, Subpart C, an applicant must be at least 23 years of age, and an approved aircraft dispatcher course provides a minimum of 200 hours of instruction. Once working, a dispatcher in domestic or flag operations may not be scheduled for more than 10 consecutive hours of duty (section 121.465).

Sources: 14 CFR Part 65, Subpart C; 14 CFR 121.465

No. ORO.GEN.110(c) requires the operator to establish and maintain a system for exercising operational control over any flight operated under its certificate, and EASA guidance states that this does not imply a requirement for licensed flight operations officers or flight dispatchers.

Source: EASA ORO.GEN.110 and GM1 ORO.GEN.110(c)

No. The rules define operational control and leave the organization of it to the operator. IATA's audit reference manual describes the OCC as the department assigned responsibility for operational control of ongoing operations, with authority to originate, delay, divert and cancel flights.

Source: IATA Operational Safety Audit

IATA lists the functions typically located in an OCC: management representatives, flight dispatch, flight planning, crew scheduling, maintenance experts, meteorology personnel, air traffic services specialists, and customer service specialists.

Source: IATA Operational Safety Audit

FAA Advisory Circular 120-101 uses airline operational control center (AOCC) and notes that it may include the systems operations control (SOC), airline operational control (AOC), operations control center (OCC), flight control, or dispatch center.

Source: FAA AC 120-101

The ICAO Council adopted Amendment 2 to Annex 19, the annex on safety management, on 23 June 2025. It became effective on 4 November 2025, and its applicability date is 26 November 2026.

Source: ICAO Annex 19 SARPs

The Overseas Territories Aviation Requirements are the aviation requirements for the UK Overseas Territories, published by Air Safety Support International. They describe the means by which aircraft operators, aviation personnel, and service providers can gain approvals, licences, and certificates, and the requirements they need to meet to maintain them.

Source: Overseas Territories Aviation Requirements

ASSI is a not-for-profit, wholly-owned subsidiary company of the UK Civil Aviation Authority. Where a Territory's civil aviation regulator lacks the resources, the Governor can designate ASSI to perform the regulatory tasks. Gibraltar is outside its remit.

Sources: About ASSI; ASSI and the Overseas Territories

OTAR Part 121 covers commercial air transport operations with large aeroplanes, and Part 135 covers commercial air transport operations with helicopters and small aeroplanes. Part 119 covers air operator certification, and Part 125 covers complex general aviation, including corporate operations.

Source: OTAR index