Part 135 SMS readiness checklist

Scope and dates

Confirm that Part 5 applies to you and which date is yours. The guide to Part 135 SMS requirements explains the rule in more detail.

• Part 5 applies to you: you hold or are applying for a Part 119 certificate to conduct Part 135 operations, or a letter of authorization under § 91.147. § 5.1(b), (c)
• Your date is set: if you were authorized before May 28, 2024, the SMS must be implemented and the declaration of compliance submitted no later than May 28, 2027. § 5.9(a)
• If you applied on or after May 28, 2024, or your application was pending on that date, you have confirmed with your FAA office when your SMS must be in place. § 5.9(b)
• You know whether the single-pilot exception applies. It covers only an organization whose single pilot is the sole individual performing all functions related to the safe operation of the aircraft. A single-pilot operator with other employees meets every applicable section. § 5.9(e)

Checks marked § 5.9(e) do not apply to an organization whose single pilot is the sole individual performing all functions related to the safe operation of the aircraft.

Safety policy

The safety policy is the documented commitment the rest of the SMS depends on. It must include at least the following.

• Safety objectives, written as measurable goals or desirable outcomes related to safety. §§ 5.3, 5.21(a)(1)
• Your commitment to fulfill those objectives. § 5.21(a)(2)
• A clear statement that the resources needed to implement the SMS will be provided. § 5.21(a)(3)
• A safety reporting policy that defines how employees report safety hazards or issues. § 5.21(a)(4) § 5.9(e)
• A policy that defines unacceptable behavior and the conditions for disciplinary action. § 5.21(a)(5) § 5.9(e)
• An emergency response plan for the safe transition from normal to emergency operations, as set out in § 5.27. § 5.21(a)(6)
• A code of ethics that applies to all employees, including management and officers, and makes clear that safety is the organization's highest priority. § 5.21(a)(7)
• The policy is signed by the accountable executive. § 5.21(b)
• The policy is documented and communicated throughout the organization. § 5.21(c) § 5.9(e)
• The accountable executive reviews the policy regularly to keep it relevant and appropriate. § 5.21(d)

Accountability and safety management personnel

Part 5 asks you to name who is accountable for safety, who may accept risk, and who runs the SMS on the accountable executive's behalf.

• The safety policy defines the safety accountability of the accountable executive. § 5.23(a)(1)
• It defines the accountability of all managers for SMS processes in their area: hazard identification and risk assessment, the effectiveness of risk controls, safety promotion, and advising the accountable executive on SMS performance. § 5.23(a)(2) § 5.9(e)
• It defines the accountability of employees for the organization's safety performance. § 5.23(a)(3) § 5.9(e)
• The levels of management with authority to make safety risk acceptance decisions are identified. § 5.23(b) § 5.9(e)
• An accountable executive is identified who has final authority over operations, controls the financial and human resources they require, and retains ultimate responsibility for their safety performance. § 5.25(a)
• The accountable executive ensures the SMS is implemented and performing across all pertinent areas, develops and signs the safety policy, reviews it regularly, and regularly reviews safety performance, directing action where it falls short. § 5.25(b)(1), (2), (4), (5)
• The accountable executive communicates the safety policy throughout the organization. § 5.25(b)(3) § 5.9(e)
• The accountable executive has designated enough managers to coordinate the SMS, facilitate hazard identification and risk analysis, monitor risk controls, ensure safety promotion, and report regularly on SMS performance. § 5.25(c) § 5.9(e)

Emergency response planning

Where emergency response procedures are necessary, the accountable executive approves an emergency response plan as part of the safety policy. It addresses at least the following.

• Delegation of emergency authority throughout the organization. § 5.27(a) § 5.9(e)
• Assignment of employee responsibilities during the emergency. § 5.27(b) § 5.9(e)
• Coordination with the emergency response plans of the other organizations you interface with while providing your services. § 5.27(c)
• The plan is approved by the accountable executive as part of the safety policy. § 5.27

Safety risk management

Safety risk management describes the system, identifies hazards, and analyzes, assesses, and controls risk.

• Safety risk management is applied to new systems, revisions of existing systems, new operational procedures, and hazards or ineffective controls found through safety assurance. § 5.51
• Each system analysis considers the system's function and purpose, its operating environment, its processes and procedures, the personnel, equipment, and facilities it needs, and its interfaces. § 5.53(a), (b)
• A process identifies hazards within the context of the system analysis. § 5.53(c)
• A process analyzes the safety risk of each identified hazard. § 5.55(a)
• A defined risk assessment process determines what level of safety risk is acceptable. § 5.55(b)
• A process develops the safety risk controls the assessment shows are necessary. § 5.55(c)
• Before a control is implemented, you evaluate whether the risk will be acceptable with that control applied. § 5.55(d)
• When you identify a hazard in the operating environment, you notify any interfacing person who could address it or mitigate the risk. § 5.57

Safety assurance

Safety assurance collects and analyzes data to show that risk controls work and that the SMS meets its objectives. The data collection must include at least the following.

• Monitoring of operational processes. § 5.71(a)(1)
• Monitoring of the operational environment to detect changes. § 5.71(a)(2)
• Audits of operational processes and systems. § 5.71(a)(3)
• Evaluations of the SMS and of operational processes and systems. § 5.71(a)(4)
• Investigations of incidents and accidents. § 5.71(a)(5)
• Investigations of reports of potential non-compliance with regulations or with your own risk controls. § 5.71(a)(6)
• A confidential employee reporting system for hazards, issues, concerns, occurrences, incidents, and proposed improvements, without concern of reprisal. § 5.71(a)(7) § 5.9(e)
• Investigations of hazard notifications received from external sources. § 5.71(a)(8)
• Processes analyze the data from these sources and any other relevant data. § 5.71(b)
• Safety performance is assessed against the safety objectives, including reviews by the accountable executive, to confirm compliance with risk controls, evaluate the SMS, test the effectiveness of controls, and find changes and new hazards. § 5.73(a)
• Ineffective controls and new hazards found in an assessment go back through safety risk management. § 5.73(b)
• Processes correct the safety performance deficiencies those assessments identify. § 5.75

Safety promotion

Training and communication keep the people named in the SMS able to run it.

• Each individual named in § 5.23 is trained to attain and maintain the competencies their SMS duties require. § 5.91
• Safety communication makes employees aware of the SMS policies, processes, and tools relevant to their responsibilities. § 5.93(a) § 5.9(e)
• It conveys hazard information relevant to each employee's responsibilities. § 5.93(b) § 5.9(e)
• It explains why safety actions have been taken. § 5.93(c) § 5.9(e)
• It explains why safety procedures are introduced or changed. § 5.93(d) § 5.9(e)

Documentation and records

Records are what an inspector asks to see. Part 5 sets the documents to maintain and how long to keep each record.

• The safety policy is documented and maintained. § 5.95(a)
• SMS processes and procedures are documented and maintained. § 5.95(b)
• Records of safety risk management outputs are kept for as long as each control remains relevant to the operation. § 5.97(a)
• Records of safety assurance outputs are kept for at least 5 years. § 5.97(b)
• A record of all SMS training is kept for each individual for as long as they are employed. § 5.97(c)
• Records of safety communications and of hazard notifications to interfacing persons are kept for at least 24 consecutive calendar months. § 5.97(d) § 5.9(e)

The declaration of compliance

The declaration follows implementation. The FAA does not approve the SMS in advance; it validates the SMS during routine surveillance.

• The SMS is developed and implemented, not only documented. § 5.9(a)(1)
• The declaration of compliance is submitted to the FAA, in a form and manner acceptable to the Administrator, no later than May 28, 2027. § 5.9(a)(2)
• The declaration gives the organization's name, certificate number, and physical address, states that the organization has developed and implemented an SMS that meets Part 5, and is signed by the accountable executive or another senior member of management. AC 120-92D
• It goes to your certificate management office or responsible Flight Standards office. AC 120-92D, submission
• You can make available to the FAA, on request, the information and data that show your SMS meets Part 5. § 5.9(d)
• The SMS is maintained for as long as you hold the authorization. §§ 5.5(b), 5.9(c)