Stop Rebuilding What Already Exists
When organizations begin developing a Part 5 Safety Management System (SMS), there is often a belief that everything must be built internally from the ground up. This typically includes manual development, software alignment, and even integration planning for tools like flight data monitoring.
With upcoming SMS requirements affecting Part 135 operators, 14 CFR § 91.147 operators, and certain Part 21 certificate holders, many teams still follow this traditional path. It usually starts with expensive training courses, a review of Advisory Circular AC 120-92D, and a “gap analysis” exercise that results in a newly written SMS Manual.
On paper, it may look complete, but in practice, it often leads to a mismatch between documentation and operational systems.
The Problem with a “Build-It-Yourself” SMS
A common outcome of this approach is what is often referred to as a piecemeal SMS. This occurs when:
- The SMS Manual is developed separately from operational software
- Safety processes are not fully aligned with FAA expectations
- Design validation requirements are not fully addressed
- SMS tools are not integrated into daily operations
The issue becomes clear during FAA review when operators encounter SMS Data Collection Tools (DCTs). These evaluate seven essential safety attributes and often reveal gaps that were not identified during internal development.
At that stage, operators may realize that while they technically meet Part 5 requirements, their SMS is not fully aligned with FAA design validation expectations.
Why Aviation Doesn’t Build Everything From Scratch
In aviation operations, most organizations do not create critical systems entirely on their own.
For example:
- General Operations Manuals are typically adapted from proven frameworks
- Maintenance manuals follow established industry standards
- Training programs are based on validated regulatory structures
The same logic applies to aircraft themselves. Operators do not assemble aircraft from individual components without certification. Instead, they select a certified aircraft designed by professionals and then configure it for their specific operational needs.
SMS design follows the same principle; structured systems already exist and can be adapted rather than rebuilt.
From Development to Configuration: A Shift in SMS Thinking
Modern SMS solutions are now designed and refined by experienced providers over time. These systems are not static templates; they are configurable frameworks tailored to an operator’s:
- Size and operational scope
- Mission profiles and operational environments
- Equipment and fleet composition
- Organizational structure and processes
Rather than starting from zero, operators work within a structured system that is then customized with:
- Identified hazards
- Baseline safety controls
- Taxonomies of human factors and organizational risks
- Unique operational safety profiles
This allows the SMS to reflect the real-world risk environment of the organization without requiring full system development from scratch.
Learning to Operate SMS Instead of Building It
A key shift in approach is moving from SMS development to SMS operation.
With a professionally designed and harmonized SMS, managers are trained to:
- Configure system components correctly
- Operate safety risk management processes
- Apply safety assurance activities consistently
- Use integrated tools and reporting systems effectively
This significantly reduces development time and avoids the workload and stress associated with building an SMS internally. It also improves readiness for FAA SMS design validation and design demonstration phases.
Why Provider Experience Matters
The effectiveness of a configured SMS depends heavily on the capability of the provider.
A qualified SMS provider should have:
- Real-world experience in flight operations and maintenance
- Deep knowledge of Part 5 compliance requirements
- Familiarity with FAA SMS design validation and demonstration DCTs
- A proven track record of successful FAA SMS acceptance outcomes
Without this experience, even well-designed systems may fail to align properly with regulatory expectations.
Conclusion: A More Efficient Path to SMS Implementation
As the FAA Part 5 compliance deadline of May 28, 2027, approaches, operators must carefully evaluate their SMS implementation strategy.
Instead of placing the burden on internal teams to build complex systems from scratch, a more effective approach is to:
- Use professionally developed SMS tools and frameworks
- Train teams to operate and configure SMS rather than design it from the ground up
- Work with experienced SMS providers throughout the FAA acceptance, validation, and demonstration phases
- Ensure alignment with operational safety programs, such as flight operations quality assurance
Ultimately, decisions made during SMS development have a direct impact on safety culture, regulatory readiness, and long-term operational performance.
A professionally developed and properly configured SMS is not just a compliance solution; it is a practical path to FAA acceptance, improved safety performance, and stronger organizational engagement across the entire aviation safety management system.
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COMPANY NAME : Omni Air Group
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