Advisory 

Circular

Subject: Introduction to Safety Date: 6/22/06 AC No: 120-92 

Management Systems for Air Operators Initiated by: AFS-800 

1. PURPOSE. 

a. This advisory circular (AC): 

(1) Introduces the concept of a safety management system (SMS) to aviation service 

providers (for example, airlines, air taxi operators, corporate flight departments, and pilot 

schools). 

(2) Provides guidance for SMS development by aviation service providers. 

b. This AC is not mandatory and does not constitute a regulation. Development and 

implementation of an SMS is voluntary. While the Federal Aviation Administration (FAA) 

encourages each aviation service provider to develop and implement an SMS, these systems in 

no way substitute for regulatory compliance of other certificate requirements, where applicable. 

2. APPLICABILITY. This AC applies to both certificated and non-certificated air operators 

that desire to develop and implement an SMS. An SMS is not currently required for U.S. 

certificate holders. However, the FAA views the requirements in Appendix 1 to this AC to be a 

minimum standard for an SMS developed by an aviation service provider. 

3. RECOMMENDED READING MATERIAL. The following ACs may be of value to users 

of this AC if they desire to integrate any of the following programs with an SMS: 

a. AC 120-59A, Air Carrier Internal Evaluation Programs. 

b. AC 120-66, Aviation Safety Analysis Programs (ASAP). 

c. AC 120-79, Developing and Implementing a Continuing Analysis and Surveillance 

System. 

d. AC 120-82, Flight Operational Quality Assurance. 

4. BACKGROUND. The modern aviation system is characterized by increasingly diverse and 

complex networks of business and governmental organizations. The rapidly changing aviation 

operational environment requires these organizations to adapt continuously to maintain their 
AC 120-92 6/22/06 

viability and relevance. The aviation system is also becoming increasingly global. Few business 

entities’ markets, supplier networks, and operations are confined entirely within the boundaries 

of a single country. These characteristics of complexity, diversity, and change add to the 

importance of sound management of functions that are essential to safe operations. While safety 

efforts in the aviation system have been highly successful to date, the rapid increase in the 

volume and variety of aviation operations push the limitations of current safety strategies and 

practices. Along with this trend is the problem of decreasing resources to be applied by both 

business and government organizations. These processes have forced a fresh look at the safety 

strategies of the future. The best approach to problems of increased aviation activity and 

decreased resources is to bring safety efforts into the normal management framework of aviation 

operations. Just as businesses and government organizations must manage these factors 

effectively to accomplish their missions or to maintain business viability, they must likewise 

provide sound management of safety. This innovation in aviation system safety is best termed 

“Safety Management Systems” a term indicating that safety efforts are most effective when 

made part of business and government management of operations and oversight. 

a. Safety Benefits of an SMS. An SMS is essentially a quality management approach to 

controlling risk. It also provides the organizational framework to support a sound safety culture. 

For general aviation operators, an SMS can form the core of the company’s safety efforts. For 

certificated operators such as airlines, air taxi operators, and aviation training organizations, the 

SMS can also serve as an efficient means of interfacing with FAA certificate oversight offices. 

The SMS provides the company’s management with a detailed roadmap for monitoring safetyrelated processes. 

b. Business Benefits of an SMS. Development and implementation of an SMS can give the 

aviation service provider’s management a structured set of tools to meet their legal 

responsibilities but they can also provide significant business benefits. The SMS incorporates 

internal evaluation and quality assurance concepts that can result in more structured management 

and continuous improvement of operational processes. The SMS outlined in this AC is designed 

to allow integration of safety efforts into the operator’s business model and to integrate other 

systems such as quality, occupational safety, and environmental control systems that operators 

might already have in place or might be considering. Operators in other countries and in other 

industries who have integrated SMSs into their business models report that the added emphasis 

on process management and continuous improvement benefits them financially as well. 

5. SMS PRINCIPLES. 

a. Safety Management. Modern management and safety oversight practices are moving 

increasingly toward a systems approach that concentrates more on control of processes rather 

than efforts targeted toward extensive inspection and remedial actions on end products. One way 

of breaking down SMS concepts is to discuss briefly the three words that make it up: safety, 

management, and systems. Then we’ll touch on another essential aspect of safety management; 

safety culture. 

(1) Safety: Requirements Based on Risk Management. The objective of an SMS is to 

provide a structured management system to control risk in operations. Effective safety 

management must be based on characteristics of an operator’s processes that affect safety. 

Page 2 Par 4 
6/22/06 AC 120-92 

Safety is defined in dictionaries in terms of absence of potential harm, an obviously impractical 

goal. However, risk, being described in terms of severity of consequences (how much harm) and 

likelihood (how likely we are of suffering harm) is a more tangible object of management. We

can identify and analyze the factors that make us more or less likely to be involved in accidents 

of incidents as well as the relative severity of the outcomes. From here, we can use this 

knowledge to set system requirements and take steps to insure that they are met. Effective safety 

management is, therefore, risk management. 

(2) Management: Safety Assurance Using Quality Management Techniques. In a 

recent set of working papers and guidance documents, the International Civil Aviation 

Organization (ICAO) emphasized that safety is a managerial process, shared by both the state 

(government regulators such as the FAA) and those who conduct aviation operations or produce 

products or services that support those operations.1

 This is compatible with the goals set forth 

for the FAA and industry in the Federal Aviation Act of 1958. The safety management process 

described in this AC starts with design and implementation of organizational processes and 

procedures to control risk in aviation operations. Once these controls are in place, quality 

management techniques can be used to provide a structured process for ensuring that they 

achieve their intended objectives and, where they fall short, to improve them. Safety 

management can, therefore, be thought of as quality management of safety related operational 

and support processes to achieve safety goals. 

(3) Systems: Focusing on a Systems Approach. Systems can be described in terms of 

integrated networks of people and other resources performing activities that accomplish some

mission or goal in a prescribed environment. Management of the system’s activities involves 

planning, organizing, directing, and controlling these assets toward the organization’s goals. 

Several important characteristics of systems and their underlying process are known as “process 

attributes” or “safety attributes.2

” when they are applied to safety related operational and support 

processes. As in the previous discussion of quality, these process attributes must have safety 

requirements built in to their design if they are to result in desired safety outcomes. The 

attributes include: 

(a) Responsibility and authority for accomplishment of required activities, 

(b) Procedures to provide clear instructions for the members of the organization to 

follow, 

(c) Controls which provide organizational and supervisory controls on the activities 

involved in processes to ensure they produce the correct outputs, and 

(d) Measures of both the processes and their products. 

 

1

 ICAO Document 9734, Draft Safety Oversight Manual; ICAO Document 9859, Safety Management Manual,

March 2006; and ICAO Working Paper from the ICAO Air Navigation Commission, Approval of Draft Report to

Counsel on Amendment 30 to Annex 6, part 1. 

2

 The six system characteristics, responsibility, authority, procedures, controls, process measures, and interfaces, are

called “safety attributes” in the FAA’s Air Transportation Oversight System (ATOS). 

Par 5 Page 3 
AC 120-92 6/22/06 

(e) An important aspect of systems management also is recognizing the important 

interrelationships or interfaces between individuals and organizations within the company as 

well as with contractors, vendors, customers, and other organizations with which the company 

does business. 

b. Safety Culture: The Essential Human Component of Organizations. “An 

organization’s culture consists of its values, beliefs, legends, rituals, mission goals, performance 

measures, and sense of responsibility to its employees, customers, and the community.3

” The 

principles discussed above that make up the SMS functions will not achieve their goals unless 

the people that make up the organization function together in a manner that promotes safe 

operations. The organizational aspect that is related to safety is frequently called the “safety 

culture.” The safety culture consists of psychological (how people think), behavioral (how 

people act), and organizational elements. The organizational elements are the things that are 

most under management control, the other two elements being outcomes of those efforts. For this 

reason, the SMS standard that is contained in Appendix 1 of this AC includes requirements for 

policies that will provide the framework for the SMS and requirements for organizational 

functions such as an effective employee safety reporting system and clear lines of 

communications both up and down the organizational chain regarding safety matters. 

6. SYSTEM FUNCTIONS AND RELATIONSHIPS. 

a. System Goals: Production and Protection. The global aviation system is really a 

“system of systems.” Figure 1 depicts the relationship between the systems that are related to 

safety. The Figure depicts the relationships between the technical and management functions in 

the company that are related to providing customers with products or services and the functions 

that are related to controlling risk that is often a byproduct of the operations. The dichotomy 

between “production” and “protection” in the Figure, therefore, refers to the functions and 

requirements that are attendant to producing products or services (e.g. flight operations, flight 

training) and those that are involved in ensuring safety. As pointed out by Dr. James Reason, a 

prominent organizational safety researcher, these functions must be kept in harmony if the 

organization is to remain financially viable while controlling safety risk.4

NOTE: The depiction in Figure 1 refers to functional roles and not 

organizational structures. It is not meant to suggest that safety management 

is the sole responsibility of a “safety department” or “safety manager.” In 

fact, the SMS standard stresses the role of those who manage the productive 

“line operational’ processes in safety management. 

 

3

 Manuele, Fred A. On the Practice of Safety. John Wiley & Sons, 2003, Hoboken, NJ. 

4

 Reason, Dr. James. Managing the Risk of Organizational Accidents. Ashgate Publishing Limited, 1997,

Aldershot, United Kingdom.

Page 4 Par 5 
6/22/06 AC 120-92 

FIGURE 1. SYSTEM RELATIONSHIPS 

Outputs =

Products/

Services

Objective: Serve 

customer 

requirements

Objective:

Control safety

risk

Process Inputs Operator’s Safety

Management

System

(SMS-P)

Protection Production (Operations)

Outputs =

Products/

Services

Objective: Serve 

customer 

requirements

Objective:

Control safety

risk

Process Inputs Operator’s Safety

Management

System

(SMS-P)

Protection Production (Operations)

(1) Production in Aviation Systems: Conducting Operations. The production system

that produces the product or service that is the mission of the aviation service provider’s 

organization. For operators, these services usually involve provision of transportation services 

but may also include providing additional services to other companies such as maintenance and 

flight crew training. One of the first tasks in effective risk management and safety assurance is 

for both the operator and an oversight organization to have a thorough understanding of the 

configuration and structure of this system and its processes. A significant number of hazards and 

risk factors exist from improper design of these processes or a poor fit between the system and 

its operational environment. In these cases, hazards to operational safety may be poorly 

understood and, therefore, inadequately controlled. 

(2) Protection in Aviation Systems: Controlling Risk. Safety risk is a byproduct of 

activities related to production. The aviation service provider’s customers and employees are, 

therefore, the potential direct victims of the consequences of failures in the safety system. It is a 

primary responsibility of the aviation service provider to identify hazards and to control risk in 

the processes they manage and their operational environment. The aviation service provider is 

primarily responsible for safety management. The aviation service provider’s SMS (denoted as 

the SMS-P to differentiate it from the FAA’s safety oversight system, later referred to as the 

SMS-O) provides a formal management system for the operator’s management to fulfill this 

obligation. 

b. Safety Management Systems for Certificated Organizations. As aviation service 

providers develop SMSs, a natural interaction between the safety management efforts of the 

FAA and those of aviation service providers also develops. This relationship can leverage the 

efforts of both parties to provide a more effective, efficient, and proactive approach to meeting 

safety requirements while at the same time increasing the flexibility of companies to tailor their 

safety management efforts to their individual business models. There are distinct roles, 

responsibilities, and relationships (the “three Rs”) for both regulators (FAA) and aviation service 

providers in the “system of systems” that is involved in management of safety. 

(1) Responsibilities of Certificated Operators and Aviation Service Providers. 

Operators who hold out to provide services in common carriage to the public have a special 

responsibility to provide their customers with safe, reliable transportation. Title 49 of the United 

Par 6 Page 5 
AC 120-92 6/22/06 

States Code, subtitle VII, chapter 447, section 44702 states, in part, that “When issuing a 

certificate under this chapter, the Administrator shall consider the duty of an air carrier to 

provide service with the highest possible degree of safety in the public interest and differences 

between air transportation and other air commerce....” This section of the public law makes 

management of safety a specific legal responsibility for air carrier management teams and, as 

such, is a fundamental principle of the FAA oversight doctrine. While this section applies 

specifically to air carriers, the FAA expects all certificated organizations to make safety a top 

priority and holds their managements accountable for doing so. 

(2) Oversight Responsibilities of the FAA. United States Code Title 49 Subtitle VII 

Chapter 447 also prescribes roles and responsibilities of the FAA. The FAA is tasked with 

developing and implementing regulations and standards of other safety oversight activities that

ensure operators apply those regulations and standards to the design and continuing operational 

safety of their organizations. These regulations and standards and the processes that apply them

to certificate holders should be thought of as important safety risk controls, rather than just 

bureaucratic requirements. 

(3) Oversight Systems. The other system on the “protection” side of the model in 

Figure 2 is the SMS-O, the system that is used by the regulator to provide oversight of the 

aviation service provider’s operations. Traditional oversight of aviation service providers 

consists of activities such as certification, surveillance, investigation, and enforcement of 

regulations. The FAA is transitioning the traditional oversight process from a quality control 

approach with principal emphasis on surveillance of compliance with technical standards to a 

systems approach that stresses the systemic nature of aviation businesses and the larger system as 

a whole. While traditional oversight functions will continue to exist in future safety oversight

systems, the primary means of safety oversight will shift more toward system safety methods and 

an emphasis on operator safety management. Moreover, the ability of the government to provide 

the resources that would be required to manage safety through intensive direct intervention in 

aviation service provider’s activities is questionable at best. 

(4) Relationships between Aviation Service Provider’s SMS and Oversight. Figure 2 

depicts the functional relationships between the productive processes in aviation service provider 

organizations, their safety management functions, and the functions of FAA oversight activities. 

On the “protection” side of the model depicted in Figure 2, two management systems exist: the 

aviation service provider’s SMS (noted as SMS-P) and that of the oversight organization or 

regulator (noted as SMS-O). 

Page 6 Par 6 
6/22/06 AC 120-92 

FIGURE 2. SYSTEM RELATIONSHIPS. CERTIFICATED OPERATORS 

Outputs =

Products/

Services

Objective: Serve 

customer 

requirements

Objective: 

Control safety

risk

Process Inputs Operator’s Safety

Management

System

(SMS-P)

Protection Production (Operations)

FAA’s Safety

Management

System

(SMS-O)

Objective: 

Public Safety

Audits

Approvals

Internal safety assurance

Risk Management

Safety Promotion

Direct sampling

(e.g. surveillance)

Outputs =

Products/

Services

Objective: Serve 

customer 

requirements

Objective: 

Control safety

risk

Process Inputs Operator’s Safety

Management

System

(SMS-P)

Protection Production (Operations)

FAA’s Safety

Management

System

(SMS-O)

FAA’s Safety

Management

System

(SMS-O)

Objective: 

Public Safety

Audits

Approvals

Internal safety assurance

Risk Management

Safety Promotion

Direct sampling

(e.g. surveillance)

(5) Voluntary Programs and the SMS. The FAA is seeking to increase the use of 

voluntary programs in the process of safety management, particularly use of the Aviation Safety 

Action Program (ASAP) and internal evaluation programs (IEP). Both of these programs have 

strong relationships to the functions of safety assurance and safety promotion in an SMS. 

Aviation service providers are encouraged to consider integrating these programs into a 

comprehensive approach to safety management. 

c. Future Developments in Safety Management. A well-developed SMS and a strong 

relationship with the oversight system provide an excellent place from which to develop an 

integrated program between regulatory programs, voluntary programs, and the operator’s own 

systems. The FAA Flight Standards Service is developing procedures to provide more effective 

interfaces in this process and to make both voluntary and regulatory programs more standardized 

and interoperable. These processes include improved, joint-use auditing tools and processes, 

procedures for information sharing and protection, and voluntary disclosure procedures. In the 

interim, certificated organizations should work closely with their certificate-holding district

office (CHDO) or certificate management office (CMO) to build an SMS that will interface 

smoothly with regulatory oversight programs. For example, an SMS that incorporates the 

operator’s continuing analysis and surveillance system (CASS — for certificated operators), an 

IEP, and an ASAP would allow the operator to derive the multiple benefits of these programs 

with a minimum of duplication. For operators that desire to implement Flight Operations 

Quality Assurance (FOQA) programs, these programs can also contribute to the safety assurance 

function. 

7. THE SMS STANDARD: INTRODUCTION. 

a. The Need for Safety Management Standards. 

Par 6 Page 7 
AC 120-92 6/22/06 

(1) Standardization. The FAA Associate Administrator for Aviation Safety (AVS) is 

interested in developing an integrated SMS in which business and governmental roles and 

relationships are well defined, requirements are based upon sound systems engineering and 

system safety principles, and both regulators and regulated industries participate in a unified 

safety effort. The SMS standard in appendix 1 of this AC provides functional requirements for 

an aviation safety SMS. It is similar in scope to internationally recognized standards for quality 

management, environmental protection, and occupational safety and health management. 

(2) International Harmonization. ICAO, in a recent set of working papers, manuals, 

and proposals5

 for changes to key annexes to the ICAO Conventions, is revamping its standards 

and recommended practices to reflect a systems approach to safety management. This coincides 

with the FAA’s move toward a systems approach for oversight over the past several years. 

Because of the many diverse relationships between organizations and the above stated global 

nature of the aviation system, it is critical that the functions of an SMS be standardized to the 

point that there is a common recognition of the meaning of SMS among all concerned, both 

domestically and internationally. 

(3) Alignment with International Organization for Standardization (ISO) 

Standards. The SMS standard is written at the approximate scope and scale of the international 

standards for quality management (QMS) and management of environmental protection (EMS), 

ISO 9000-2000 and ISO 14001, respectively. The FAA also reviewed the British Standards 

Institute’s standard for occupational health and safety management systems (OHSMS), which is 

based on ISO 14001. The clause structure of the aviation service provider SMS standard initially 

was developed to parallel ISO 14001, with the clauses then being arranged around the four 

building blocks discussed below under “The Four Pillars of Safety Management.” 

(4) Alignment with Other Industry Standards. The SMS standard was developed 

after an extensive review of documented SMS systems used by other countries around the 

world.6

 This review included literature reviews of regulations, policy documents, and advisory 

material, as well as interviews with both government and industry personnel who promulgated 

and used the systems. Existing management system standards from the International 

Standardization Organization (ISO) and the American National Standards Institute (ANSI) were 

reviewed cross-mapped.7

 The review also included consideration of third-party systems 

developed by user organizations such as the International Air Transport Association (IATA), the 

Medallion Foundation, and the International Business Aviation Council (IBAC)8

. 

(5) Auditability. The SMS standard is designed to provide definitive functional 

requirements in a manner that can be audited by the organization’s own personnel, regulators, or 

 

5

 Ibid. See footnote 1. 

6

 The review included review of documents and interviews of government and industry personnel from Australia, 

Canada, New Zealand, and the United Kingdarom.

7

 A matrix showing the functional correlation between the SMS standard in Appendix 1 of this AC and existing 

standards for quality management, environmental control, and occupational safety and health management is 

included as Appendix 2.

8

 This preliminary literature review was conducted to compare content of the various programs and documents and

did not assess any of the reviewed programs for completeness or assurance of regulatory compliance. 

Page 8 Par 7 
6/22/06 AC 120-92 

other third-party consultants. The language in the standard is, therefore, written in a 

requirements-oriented tone. To the maximum extent possible, each indexed statement defines a 

single requirement so that it can easily be used in audits of the system. 

(6) Integration with Other Management Systems. While the SMS standard’s stated 

scope is on product and service safety, the FAA recognizes that managers in real-world 

organizations may often, if not usually, be required to manage not only this aspect of safety, but 

also occupational safety and environmental protection, as well. Managers of these organizations 

typically are required to fit their activities into the framework of the organization’s mission or 

commercial objectives and may operate under an integrated management system. The SMS 

standard therefore can be mapped to other existing standards covering these areas so that 

organizations may develop integrated management systems. Appendix 2 provides a crossreference between the SMS standard presented in Appendix 1 and several other commonly used 

management standards. 

b. Structure and Organization. 

(1) Functional Orientation. The SMS Standard is written as a functional requirements 

document. It stresses “what” the organization must do rather than “how” it will be 

accomplished. The FAA feels that each of the functions detailed in the standard are essential for 

a comprehensive SMS. At the same time, the standard needs to be applicable to a wide variety 

of types and sizes of operators. Therefore, it is designed to allow operators to integrate safety 

management practices into their unique business models. Operators are not expected to 

configure their systems in the format of the standard or to duplicate existing programs that 

accomplish the same function. This was a further reason for using a similar scope, scale, and 

language to the ISO standards, which also are designed for broad application. The standard 

document contained in Appendix 1, therefore, attempts to strike a balance between flexibility of

implementation and functional standardization of essential safety management processes. 

(2) Four Pillars of Safety Management. The standard is organized around four basic 

building blocks of safety management. These four areas are essential for a safety-oriented 

management system, and derive from the SMS principles discussed earlier. 

(a) Policy. All management systems must define policies, procedures, and 

organizational structures to accomplish their goals. Requirements for these elements are outlined 

in Appendix 1, par 4 which in turn provide the framework for SMS functional elements. 

(b) Safety risk management. A formal system of hazard identification and safety 

risk management in Appendix 1, par. 5 is essential in controlling risk to acceptable levels. The 

safety risk management component of the SMS is based upon the system safety process model 

that is used in the system safety training course that is taught at the FAA Academy. 

(c) Safety assurance. Once these controls are identified, the operator must ensure 

they are continuously practiced and continue to be effective in a changing environment. The 

safety assurance function in Appendix 1, par 6 provides for this using quality management 

concepts and processes.

Par 7 Page 9 
AC 120-92 6/22/06 

(d) Safety promotion. Finally, the operator must promote safety as a core value 

with practices that support a sound safety culture. Appendix 1 par. 7 provides guidance for 

setting up these functions. 

(3) Integration of Safety Risk Management and Safety Assurance. Figure 3 shows 

how the safety risk management and safety assurance processes are integrated in the SMS. The 

safety risk management process provides for initial identification of hazards and assessment of 

risk. Organizational risk controls are developed and, once they are determined to be capable of 

bringing the risk to an acceptable level, they are employed operationally. The safety assurance 

function takes over at this point to ensure that the risk controls are being practiced and they 

continue to achieve their intended objectives. This system also provides for assessment of the 

need for new controls because of changes in the operational environment. 

FIGURE 3. SAFETY RISK MANAGEMENT AND SAFETY ASSURANCE 

PROCESSES9

Describe

System (5.1)

Identify

Hazards (5.2)

Analyze Safety

Risk (5.3)

Control Safety

Risk (5.5)

Assess Safety

Risk (5.4)

Nonconformance

Preventive/

Corrective

Action (6.6)

Aviation 

System

Operation

System

Assessment

(6.5)

Potential New Hazard

or

Ineffective Control

Conformance Safety Assura

n

c

e

S

afety Risk Ma

nagement

Information Acquisition 6.3

Investigation

(6.3.5)

Auditing

(6.3.2, 6.3.3, 

6.3.4)

Continuous 

Monitoring

Unacceptable (6.3.1)

Acceptable

Analysis of

Data

(6.4)

 

9

 The numbers in the process blocks shown in Figure 3 refer to clause numbers in the SMS standard in Appendix 1 

to this AC. 

Page 10 Par 7 
6/22/06 AC 120-92 

8. THE SMS STANDARD. 

a. General Organization of the SMS Standard. The first part of the SMS functional 

requirements (SMS Standard) included as Appendix 1 of this AC follows the general 

organization of ISO 9000-2000 and ISO 14001. The first three clauses describe scope and 

applicability, references, and definitions. The following four clauses address each of the four 

pillars of SMS, as described previously in paragraph 7b(2).

b. Policy: Setting the Framework. 

(1) Safety and Quality: Striking a Balance. As discussed above, the SMS standard 

uses quality management principles, but the requirements to be managed by the system are based 

on an objective assessment of safety risk, rather than customer satisfaction with products or other 

conventional commercial goals. However, management of process quality, with emphasis on 

those characteristics of those processes that affect safety, is an important aspect of safety 

management. The standard specifies that the aviation service provider should prescribe both 

quality and safety policies. The coverage of quality policies is limited in scope to quality in 

support of safety, although operators are encouraged to integrate their management systems as 

much as feasible. However, safety objectives should receive primacy where conflicts are 

identified. 

(2) Roles, Responsibilities, and Relationships: The “Three Rs” of Safety 

Management. Figures 1 and 2 show the relationship between the productive processes of the 

aviation service provider as well as the joint protective processes of the regulator (FAA) in the 

form of an oversight system (SMS-O) and the aviation service provider’s SMS (SMS-P). As 

before, it is important to recognize that the two aviation service provider systems shown 

(Protection and Production) are functional rather than departmental or organizational depictions. 

One of the principal roles of the oversight system (SMS-O) is to promulgate risk controls in the 

form of regulations, standards, and policies. It follows that regulatory compliance, in a manner 

that accomplishes the regulations’ safety objectives, is also part of the aviation service provider’s 

role in safety management. 

(3) Importance of Executive Management Involvement. The standard specifies that 

top management is primarily responsible for safety management. Managements must plan, 

organize, direct, and control employees’ activities and allocate resources to make safety controls 

effective. A key factor in both quality and safety management is top management’s personal, 

material involvement in quality and safety activities. The standard also specifies that top 

management must further clearly delineate safety responsibilities throughout the organization. 

While it is true that top management must take overall responsibility for safe operations, it also is 

true that all members of the organization must know their responsibilities and be both 

empowered and involved with respect to safety. 

(4) Procedures and Controls. Two key attributes of systems are procedures and 

controls. Policies must be translated into procedures in order for them to be applied and 

organizational controls must be in place to ensure that critical steps are accomplished as 

designed. Organizations must develop, document, and maintain procedures to carry out their 

safety policies and objectives. The standard also requires organizations to ensure that employees 

Par 8 Page 11 
AC 120-92 6/22/06 

understand their roles. Moreover, supervisory controls must be used to monitor the 

accomplishment of the procedures. 

c. Safety Risk Management: Setting Requirements for Safety Management. The safety 

risk management process is used to examine the operational functions of the company and their 

operational environment to identify hazards and to analyze associated risk. The safety risk 

management process follows the same sequence of steps as the system safety process model that 

is used in the FAA’s System Safety training course at the FAA Academy. These are also the 

same general steps that are used in operational risk management programs within several of the 

military services. 

(1) Systems and Task Analysis. Safety risk management begins with system design. 

This is true whether the system in question is a physical system, such as an aircraft, or an 

organizational system such as an operator, maintenance or training establishment. These systems 

consist of the organizational structures, processes, and procedures, as well as the people, 

equipment, and facilities used to accomplish the organization’s mission. The system or task 

descriptions should completely explain the interactions among the hardware, software, people, 

and environment that make up the system in sufficient detail to identify hazards and perform risk 

analyses. While systems should be documented, no particular format or is required. System

documentation would normally include the operator’s manual system,

10 checklists, 

organizational charts, and personnel position descriptions. A suggested breakdown of operational 

and support processes for air operators includes: 

(a) Flight operations; 

(b) Dispatch/flight following; 

(c) Maintenance and inspection;

(d) Cabin safety; 

(e) Ground handling and servicing; 

(f) Cargo handling; and 

(g) Training. 

NOTE: Long and excessively detailed system or task descriptions are not 

necessary as long as they are sufficiently detailed to perform hazard and risk 

analyses. While sophisticated process development tools and methods are 

available, simple brainstorming sessions with managers, supervisors, and other 

employees are often most effective. 

(2) Hazard Identification. Hazards in the system and its operating environment must 

be identified, documented, and controlled. It also requires that the analysis process used to 

 

10 While manuals are required only for certificated operators and agencies, all operators are encouraged to develop a 

manuals as a means of documenting their policies and procedures. 

Page 12 Par 8 
6/22/06 AC 120-92 

define hazards consider all components of the system, based on the system description described 

above. The key question to ask during analysis of the system and its operation is “what if?” As 

with system and task descriptions, judgment is required to determine the adequate level of detail. 

While identification of every conceivable hazard would be impractical, aviation service 

providers are expected to exercise due diligence in identifying significant and reasonably 

foreseeable hazards related to their operations. 

(3) Risk Analysis and Assessment. The standard’s risk analysis and risk assessment 

clauses use a conventional breakdown of risk by its two components: likelihood of occurrence 

of an injurious mishap and severity of the mishap related to an identified hazard, should it occur. 

A common tool for risk decision-making and acceptance is a risk matrix similar to those in the 

U.S. Military Standard (MIL STD 882) and the ICAO Safety Management Manual11. Figure 4 

shows an example of one such matrix. Operators should develop a matrix that best represents 

their operational environment. Separate matrices with different risk acceptance criteria may also 

be developed for long-term versus short-term operations. 

(4) Severity and Likelihood Criteria. The definitions and final construction of the 

matrix is left to the aviation service provider’s organization to design. The definitions of each 

level of severity and likelihood will be defined in terms that are realistic for the operational 

environment. This ensures each organization’s decision tools are relevant to their operations and 

operational environment, recognizing the extensive diversity in this area. An example of severity 

and likelihood definitions is shown in Table 1 below. Each operator’s specific definitions for 

severity and likelihood may be qualitative but quantitative measures are preferable, where 

possible. 

TABLE 1. SAMPLE SEVERITY AND LIKELIHOOD CRITERIA12

Severity of Consequences Likelihood of Occurrence 

Severity 

Level 

Definition Value Likelihood Level Definition Value

Catastrophic Equipment destroyed,

multiple deaths 

5 Frequent Likely to

occur many 

times 

5 

Hazardous Large reduction in 

safety margins, 

physical distress or a 

workload such that 

operators cannot be 

relied upon to perform

their tasks accurately or

completely. Serious 

injury or death to a 

number of people. 

4 Occasional Likely to

occur 

sometimes

4 

 

11 Available at: http://www.icao.int/fsix 

12 Adapted from ICAO Safety Management Manual (SMM). ICAO Doc 9859. Available at: http://www.icao.int/fsix 

Par 8 Page 13 
AC 120-92 6/22/06 

Severity of Consequences Likelihood of Occurrence 

Major equipment 

damage. 

Severity 

Level 

Definition Value Likelihood Level Definition Value

Major Significant reduction in 

safety margins, 

reduction in the ability 

of operators to cope 

with adverse operating 

conditions as a result of 

an increase in 

workload, or as result 

of conditions impairing 

their efficiency. Serious 

incident. Injury to 

persons. 

3 Remote Unlikely, but

possible to 

occur 

3 

Minor Nuisance. Operating

limitations. Use of

emergency procedures. 

Minor incident. 

2 Improbable Very unlikely

to occur 

2 

Negligible Little consequence 1 Extremely

Improbable 

Almost 

inconceivable 

that the event 

will occur 

1 

(5) Risk Acceptance. In the development of its risk assessment criteria, aviation service 

providers are expected to develop risk acceptance procedures, including acceptance criteria and 

designation of authority and responsibility for risk management decision making. The

acceptability of risk can be evaluated using a risk matrix such as the one illustrated in Figure 4. 

The example matrix shows three areas of acceptability. Risk matrices may be color coded; 

unacceptable (red), acceptable (green), and acceptable with mitigation (yellow). 

(a) Unacceptable (Red). Where combinations of severity and likelihood cause risk 

to fall into the red area, the risk would be assessed as unacceptable and further work would be 

required to design an intervention to eliminate that associated hazard or to control the factors that 

lead to higher risk likelihood or severity. 

(b) Acceptable (Green). Where the assessed risk falls into the green area, it may be 

accepted without further action. The objective in risk management should always be to reduce 

Page 14 Par 8 
6/22/06 AC 120-92 

risk to as low as practicable regardless of whether or not the assessment shows that it can be 

accepted as is. This is a fundamental principle of continuous improvement. 

(c) Acceptable with Mitigation (Yellow). Where the risk assessment falls into the 

yellow area, the risk may be accepted under defined conditions of mitigation. An example of this 

situation would be an assessment of the impact of a non-operational aircraft component for 

inclusion on a Minimum Equipment List. Defining an Operational (“O”) or Maintenance (“M”) 

procedure in the MEL would constitute a mitigating action that could make an otherwise 

unacceptable risk acceptable, as long as the defined procedure was implemented. These 

situations may also require continued special emphasis in the safety assurance function. 

FIGURE 4. SAFETY RISK MATRIX 

Severity

Likelihood

Less

More

Higher

Lower

Acceptable

Unacceptable

Acceptable with Mitigation

Severity

Likelihood

Less

More

Higher

Lower

Acceptable

Unacceptable

Acceptable with Mitigation

(6) Other Risk Assessment Tools for Flight and Operational Risk Management.

Other tools can also be used for flight or operational risk assessment such as the Controlled 

Flight into Terrain (CFIT), Approach and Landing Accident Reduction (ALAR), operational 

control, and ground operations risk assessment tools available from the Flight Safety Foundation 

(http://www.flightsafety.org/technical_initiatives.html) or the Medallion Foundation 

(http://www.medallionfoundation.org).

(7) Causal Analysis. Risk analyses should concentrate not only on assigning levels of 

severity and likelihood but on determining why these particular levels were selected. This is 

often called “root cause analysis,” and is the first step in developing effective controls to reduce 

risk to lower levels. Several structured software systems are available to perform root cause 

analysis. However, in many cases, simple brainstorming sessions among the company’s pilots, 

mechanics, or dispatchers other experienced subject matter experts is the most effective and 

affordable method of finding ways to reduce risk. This also has the advantage of involving 

employees who will ultimately be required to implement the controls developed. 

(8) Controlling Risk. After hazards and risk are fully understood though the preceding 

steps, risk controls must be designed and implemented. These may be additional or changed 

Par 8 Page 15 
AC 120-92 6/22/06 

procedures, new supervisory controls, addition of organizational, hardware, or software aids, 

changes to training, additional or modified equipment, changes to staffing arrangements, or any 

of a number of other system changes. 

(9) Hierarchy of Controls. The process of selecting or designing controls should be 

approached in a structured manner. System safety technology and practice has provided a 

hierarchy or preferred order of control actions that range from most to least effective. Depending 

on the hazard under scrutiny and its complexity there may be more than one action or strategy 

that may be applied. Further, the controls may be applied at different times depending on the 

immediacy of the required action and the complexity of developing more effective controls. For 

example, it may be appropriate to post warnings while a more effective elimination of the hazard 

is developed. The hierarchy of controls is: 

(a) Design the hazard out – modify the system (this includes hardware/software 

systems involving physical hazards as well as organizational systems). 

(b) Physical guards or barriers – reduce exposure to the hazard or reduce the severity 

of consequences. 

(c) Warnings, advisories, or signals of the hazard.

(d) Procedural changes to avoid the hazard or reduce likelihood or severity of 

associated risk 

(e) Training to avoid the hazard or reduce the likelihood of an associated risk. 

(10) Residual and Substitute Risk. It is seldom possible to entirely eliminate risk, even 

when highly effective controls are used. After these controls are designed but before the system

is placed back on line, an assessment must be made of whether the controls are likely to be 

effective and/or if they introduce new hazards to the system. The latter condition is referred to as

“substitute risk,” a situation where “the cure is worse than the disease.” The loop seen in 

Figure 3 back to the top of the diagram depicts the use of the preceding systems analysis, hazard 

identification, risk analysis, and risk assessment processes to determine if the modified system is 

acceptable. 

(11) System Operation. When the controls are acceptable, the system is placed into 

operation. The next process, safety assurance, uses auditing, analysis, and review systems that 

are familiar from similar quality management systems. These processes are used to monitor the 

risk controls to ensure they continue to be implemented as designed and continue to be effective 

in a changing operational environment. 

Page 16 Par 8 
6/22/06 AC 120-92 

d. Safety Assurance: Managing the Requirements. The safety assurance function applies 

the processes of quality assurance and internal evaluation to the process of making sure that risk 

controls, once designed, continue to conform to their requirements and that they continue to be 

effective in maintaining risk within acceptable levels. These assurance and evaluation functions 

also provide a basis for continuous improvement. 

(1) Relationship between Safety Risk Management, Safety Assurance, and Internal 

Evaluation. Quality assurance processes concentrate on proving, through collection and 

analysis of objective evidence, that process requirements have been met. In an SMS, the 

system’s requirements are based on assessment of risk in the organization’s operation or in the 

products that it produces, as discussed above. Quality assurance techniques, including internal 

auditing and evaluation, can be used to determine if risk controls that are designed into the 

operator’s processes are being practiced and that they perform as designed. The process is, 

therefore, appropriately termed “safety assurance.” If an operator already has an IEP, it should 

be reviewed to ensure that it conforms to the SMS safety assurance standards.13

NOTE: the safety assurance function does not need to be extensive or complex to 

be effective. Smaller organizations may find available tools such as the Internal 

Evaluation Program Audit tools produced by the Medallion Foundation 

(http://www.medallionfoundation.org) to be a good foundation for their 

organization’s safety assurance processes. 

(2) Role of Other Management Systems. As discussed above, safety assurance uses

many of the same practices as those used in quality management systems (QMS). In an SMS 

however the requirements being managed relate to ensuring risk controls, once designed and put 

into place, perform in a way that continues to meet their safety objectives. While operators may 

find it beneficial to integrate their management systems for these other areas, such as quality, 

employee health and safety, or environmental protection with the SMS, it is beyond the scope of 

the safety management standard to address these areas directly. Appendix 2 to this AC contains 

a table of cross-references between ISO standards and other recognized standards for quality 

(ISO 9000:2000), environmental protection (ISO 14001), and employee health and safety 

management (BSI OHSAS 18001). These are provided for convenience for organizations that 

desire to develop integrated management systems or that may already have existing systems in 

one or more of these areas. 

(3) Information for Decisionmaking. Information for safety assurance comes from a 

variety of sources, including formal program auditing and evaluation, investigations of safetyrelated events, and continuous process monitoring of day-to-day activities and inputs from

employees through employee reporting systems. While each of these types of information 

sources exist to some degree in every organization, the standard formalizes requirements for 

each. Specifications for these and other related safety assurance processes are left at a functional 

level, allowing individual organizations to tailor them to the scope and scale appropriate for their 

size and type of organization. 

 

13 The safety assurance functions in the SMS standard contained in Appendix 1 were derived almost directly from

ISO 9000-2000, the international quality management standard and the IEP development guidance in AC 120-59A. 

Par 8 Page 17 
AC 120-92 6/22/06 

(4) Internal Audits by Operating Departments. The primary responsibility for safety 

management rests with those who “own” the operator’s technical processes. It is here where 

hazards are most directly encountered, where deficiencies in processes contribute to risk, and 

where direct supervisory control and resource allocation can mitigate the risk to acceptable 

levels. The standard specifies a responsibility for internal auditing of the operator’s productive 

processes (the Production/Operation side of Figures 1 and 2). As with other requirements, the 

standard’s auditing requirements are left at a functional level, allowing for a broad range of 

complexity, commensurate with the complexity of the organization. 

(a) Line Management Responsibilities. Line managers of operational departments 

have the direct responsibility for quality control and for ensuring that the processes in their areas 

of responsibility function as designed. Moreover, line organizations are the domain technical 

experts in any organization and thus the most knowledgeable about the technical processes 

involved. Line managers of the operational departments should be given the responsibility for 

monitoring these processes and periodically assessing the status of risk controls though an 

internal auditing and evaluation program.

(b) Audit Programs and Tools. In order to promote system integration and a 

minimum of duplication, operators may want to consider using available technical system audit 

tools such as those provided by the Air Transportation Oversight System (ATOS)14 or third party 

tools such as those in the IATA Operational Safety Audit (IOSA). This can be particularly 

advantageous if the operator is already involved with using these programs. 

(5) Internal Evaluation. This function involves evaluation of the technical processes of 

the operator as well as the SMS-specific functions. Audits conducted for the purpose of this 

requirement must be conducted by persons or organizations that are functionally independent of 

the technical process being evaluated. A specialist safety or quality assurance department or 

another sub-organization as directed by top management may accomplish it. The internal 

evaluation function also requires auditing and evaluation of the safety management functions, 

policymaking, safety risk management, safety assurance, and safety promotion. These audits 

provide the management officials designated responsibility for the SMS to inventory the 

processes of the SMS itself. 

NOTE: In very small organizations, the top management may elect to conduct 

the internal evaluation function themselves, in conjunction with the management 

review function. 

(6) Integration of Regulatory and Voluntary Programs. The provisions of the SMS 

standard are not intended to duplicate the functions of required CASS (required for operators 

under part 121 or part 135 of Title 14 of the Code of Federal Regulations) (14 CFR) or IEPs. In 

fact, the FAA encourages an integrated approach where these programs are all part of a 

comprehensive SMS. 

(7) External Audits. External audits of the SMS may be conducted by the regulator 

(FAA), code-share partners, customer organizations, or other third parties selected by the 

 

14 Available at: http://www.faa.gov/safety/programs_initiatives/oversight/atos/library/data_collection 

Page 18 Par 8 
6/22/06 AC 120-92 

operator. These audits not only provide a strong interface with the oversight system (SMS-O) 

but also a secondary assurance system. Organizations may elect to have third-party audits of 

their SMS from organizations such as the IATA or other consultant organizations. 

(8) Analysis and Assessment. Audits and other information-gathering activities are 

useful to management only if the information is distilled into a meaningful form and conclusions 

are drawn to form a bottom line. Recall that the primary purpose of the safety assurance process 

is to assess the continued effectiveness of risk controls put into place by the safety risk 

management process. Where significant deviations to existing controls are discovered, the 

standard requires a structured, documented process for preventive and corrective action to place 

the controls back on track. 

(9) Corrective Action and Followup. The safety assurance process should include 

procedures that ensure that corrective actions are developed in response to findings of audits and 

evaluations and to verify their timely and effective implementation. Organizational responsibility 

for the development and implementation of corrective actions should reside with the operational 

departments cited in audit and evaluation findings. If new hazards are discovered, the safety risk 

management process should be employed to determine if new risk controls should be developed. 

(10) Monitoring the Environment. As part of the safety assurance function, the 

analysis and assessment functions must alert the organization to significant changes in the 

operating environment, possibly indicating a need for system change to maintain effective risk 

control. When this occurs, the results of the assessment start the safety risk management 

process, as depicted in Figure 3. 

e. Safety Promotion: Supporting the Culture. An organizational safety effort cannot 

succeed by mandate or strictly though a mechanistic implementation of policy. As in the case of 

attitudes where individual people are concerned, organizational cultures set the tone that 

predisposes the organization’s behavior. An organization’s culture consists of the values, 

beliefs, mission, goals, and sense of responsibility held by the organization’s members. The 

culture fills in the blank spaces in the organization’s policies, procedures, and processes and 

provides a sense of purpose to safety efforts. 

(1) Safety Cultures. Cultures consist of psychological (how people think and feel), 

behavioral (how people and groups act and perform) and structural (the programs, procedures, 

and organization of the enterprise) elements. Many of the processes specified in the policy, risk 

management, and assurance components of the SMS provide the framework for the structural 

element. However, the organization must also set in place processes that allow for 

communication among employees and with the organization’s management. The aviation 

service provider must make every effort to communicate its goals and objectives, as well as the 

current status of the organization’s activities and significant events. Likewise, the aviation 

service provider must supply a means of upward communication in an environment of openness. 

(2) Communication: A Two Way Street. Dr. James Reason, among other current 

organizational system safety theorists, stresses the need for a “reporting culture” as an important 

aspect of safety culture. The organization must do what it can to cultivate the willingness of its 

members to contribute to the organization’s knowledge base. Dr. Reason further stresses the 

Par 8 Page 19 
AC 120-92 6/22/06 

need for a “just culture,” where employees have the confidence that, while they will be held 

accountable for their actions, the organization will treat them fairly.15 The standard specifies that 

the aviation service provider must provide for a means of employee communication that allows 

for timely submission of reports on safety deficiencies without fear of reprisal. Many 

certificated operators already have invested in ASAP. ASAP is a collaborative, reporting, 

analysis, and problem solving effort among the FAA, operators, and employee unions. This 

program is another example of a voluntary program that could be integrated into the SMS, 

having a strong potential to contribute to the safety assurance and safety promotion. 

(3) Organizational Learning. Another of Dr. Reason’s principles of organizational 

safety culture is that of a “learning culture.”16 The information in reports, audits, investigation, 

and other data sources does no good if the organization does not learn from it. The standard also 

requires a means of analysis of this information and a linkage to the safety assurance process. 

The standard requires an analysis process, a preventive/corrective action process, and a path to 

the safety risk management process for the development of new safety controls, as environments 

change and new hazards are identified. It further requires that the organization provide training 

and information about risk controls and lessons learned. 

9. CONTACT. For additional information or suggestions, please contact AFS-800 at 

(202) 267-8212, or AFS-900 at (703) 661-0526. 

ORIGINAL SIGNED BY

John M. Allen (for) 

James J. Ballough 

Director, Flight Standards Service 

 

15 Reason. Managing the Risks of Organizational Accidents.

16 Ibid. 

Page 20 Par 8 
DATE AC 120-92 

Appendix 1 

APPENDIX 1. AIR OPERATOR SAFETY MANAGEMENT SYSTEM 

(SMS-P) STANDARD: FUNCTIONAL REQUIREMENTS 

PURPOSE OF THIS APPENDIX. To provide a uniform standard for SMS development 

by aviation service providers. 

1. Scope and Applicability 

A) This Standard describes the requirements for a product/service provider’s Safety 

Management System (SMS-P) in the air transportation system. 

1) This standard is intended to address aviation safety related operational and

support processes and activities rather than occupational safety, environmental 

protection, or customer service quality. 

2) The requirements of this standard apply to Safety Management Systems 

developed and used by organizations that provide products and/or services in the air 

transportation system. 

3) Operators and service providers are responsible for the safety of services or 

products contracted to or purchased from other organizations. 

B) This document establishes the minimum acceptable requirements; oversight entities 

can establish more stringent requirements. 

2. References 

This Standard is in accordance with the following documents: 

• Annex 6 to the Convention on International Civil Aviation, Operation of Aircraft

• International Civil Aviation Organization (ICAO) Document 9859, ICAO Safety 

Management Manual 

• ICAO Document 9734, Safety Oversight Manual

3. Definitions 

Accident – an unplanned event or series of events that results in death, injury, occupational 

illness, damage to or loss of equipment or property, or damage to the environment. 

Analysis – the process of identifying a question or issue to be addressed, modeling the issue, 

investigating model results, interpreting the results, and possibly making a recommendation. 

Analysis typically involves using scientific or mathematical methods for evaluation. 

Assessment – process of measuring or judging the value or level of something. 

Audit – scheduled, formal reviews and verifications to evaluate compliance with policy,

standards, and/or contractual requirements. The starting point for an audit is the management

and operations of the organization, and it moves outward to the organization's activities and 

products/services. 

Internal audit – an audit conducted by, or on behalf of, the organization being audited. 

Page 1 
AC 120-92 DATE 

Appendix 1 

External audit – an audit conducted by an entity outside of the organization being

audited. 

Aviation system – the functional operation/production system used by the service provider 

to produce the product/service (see Figure 1). 

Complete – nothing has been omitted and the attributes stated are essential and appropriate 

to the level of detail. 

Continuous monitoring – uninterrupted watchfulness over the system. 

Corrective action – action to eliminate or mitigate the cause or reduce the effects of a 

detected nonconformity or other undesirable situation. 

Correct – accurately reflects the item with an absence of ambiguity or error in its attributes. 

Documentation – information or meaningful data and its supporting medium (e.g., paper, 

electronic, etc.). In this context it is distinct from records because it is the written description 

of policies, processes, procedures, objectives, requirements, authorities, responsibilities, or 

work instructions. 

Evaluation – [ref. AC 120-59A] a functionally independent review of company policies, 

procedures, and systems. If accomplished by the company itself, the evaluation should be 

done by an element of the company other than the one performing the function being 

evaluated. The evaluation process builds on the concepts of auditing and inspection. An 

evaluation is an anticipatory process, and is designed to identify and correct potential 

findings before they occur. An evaluation is synonymous with the term systems audit. 

Hazard – any existing or potential condition that can lead to injury, illness, or death to 

people; damage to or loss of a system, equipment, or property; or damage to the environment. 

A hazard is a condition that is a prerequisite to an accident or incident. 

Incident – a near miss episode with minor consequences that could have resulted in greater 

loss. An unplanned event that could have resulted in an accident, or did result in minor 

damage, and indicates the existence of, though may not define, a hazard or hazardous 

condition. 

Lessons learned – knowledge or understanding gained by experience, which may be

positive, such as a successful test or mission, or negative, such as a mishap or failure.

Lessons learned should be developed from information obtained from within, as well as 

outside of, the organization and/or industry. 

Likelihood – the estimated probability or frequency, in quantitative or qualitative terms, of 

an occurrence related to the hazard. 

Line management – management structure that operates the aviation system. 

Nonconformity – non fulfillment of a requirement (ref. ISO 9000). This includes but is not 

limited to noncompliance with Federal regulations. It also includes company requirements, 

requirements of operator developed risk controls or operator specified policies and 

procedures. 

Operational life cycle – period of time spanning from implementation of a product/service 

until it is no longer in use. 

Page 2 
DATE AC 120-92 

Appendix 1 

Oversight – a function that ensures the effective promulgation and implementation of the

safety-related standards, requirements, regulations, and associated procedures. Safety 

oversight also ensures that the acceptable level of safety risk is not exceeded in the air

transportation system. Safety oversight in the context of the safety management system will 

be conducted via oversight’s safety management system (SMS-O). 

Preventive action – action to eliminate or mitigate the cause or reduce the effects of a

potential nonconformity or other undesirable situation. 

Procedure – specified way to carry out an activity or a process. 

Process – set of interrelated or interacting activities which transforms inputs into outputs. 

Product/service – anything that might satisfy a want or need, which is offered in, or can be 

purchased in, the air transportation system. In this context, administrative or licensing fees

paid to the government do not constitute a purchase.

Product/service provider – any entity that offers or sells a product/service to satisfy a want 

or need in the air transportation system. In this context, administrative or licensing fees paid 

to the government do not constitute a purchase. Examples of product/service providers 

include: aircraft and aircraft parts manufacturers; aircraft operators; maintainers of aircraft,

avionics, and air traffic control equipment; educators in the air transportation system; etc. 

(Note: any entity that is a direct consumer of air navigation services and or operates in the 

U.S. airspace is included in this classification; examples include: general aviation, military 

aviation, and public use aircraft operators.) 

Records – evidence of results achieved or activities performed. In this context it is distinct 

from documentation because records are the documentation of SMS outputs.

Residual safety risk – the remaining safety risk that exists after all control techniques have

been implemented or exhausted, and all controls have been verified. Only verified controls 

can be used for the assessment of residual safety risk. 

Risk – The composite of predicted severity and likelihood of the potential effect of a hazard 

in the worst credible system state. 

Risk Control – refers to steps taken to eliminate hazards of to mitigate their effects by

reducing severity and/or likelihood of risk associated with those hazards.

Safety assurance – SMS process management functions that systematically provide 

confidence that organizational products/services meet or exceed safety requirements. 

Safety culture – the product of individual and group values, attitudes, competencies, and 

patterns of behavior that determine the commitment to, and the style and proficiency of, the

organization's management of safety. Organizations with a positive safety culture are

characterized by communications founded on mutual trust, by shared perceptions of the 

importance of safety, and by confidence in the efficacy of preventive measures. 

Safety Management System (SMS) – the formal, top-down business-like approach to 

managing safety risk. It includes systematic procedures, practices, and policies for the

management of safety (as described in this document it includes safety risk management, 

safety policy, safety assurance, and safety promotion). 

Page 3 
AC 120-92 DATE 

Appendix 1 

Product/Service Provider Safety Management System (SMS-P) – the SMS owned and 

operated by a product/service provider. 

Oversight Safety Management System (SMS-O) – the SMS owned and operated by an 

oversight entity. 

Safety objectives.

17– something sought or aimed for, related to safety. 

NOTE 1: Safety objectives are generally based on the organization’s safety policy. 

NOTE 2: Safety objectives are generally specified for relevant functions and levels 

in the organization. 

Safety planning18 – part of safety management focused on setting safety objectives and 

specifying necessary operational processes and related resources to fulfill the quality 

objectives. 

Safety risk – the composite of predicted severity and likelihood of the potential effect of a 

hazard. 

Safety risk control – anything that reduces or mitigates the safety risk of a hazard. Safety 

risk controls must be written in requirements language, measurable, and monitored to ensure 

effectiveness. 

Safety risk management (SRM) – a formal process within the SMS composed of describing 

the system, identifying the hazards, assessing the risk, analyzing the risk, and controlling the 

risk. The SRM process is embedded in the processes used to provide the product/service; it 

is not a separate/distinct process. 

Safety promotion – a combination of safety culture, training, and data sharing activities that

support the implementation and operation of an SMS in an organization 

Severity – the consequence or impact of a hazard in terms of degree of loss or harm. 

Substitute risk – risk unintentionally created as a consequence of safety risk control(s). 

System – an integrated set of constituent elements that are combined in an operational or 

support environment to accomplish a defined objective. These elements include people,

hardware, software, firmware, information, procedures, facilities, services, and other support 

facets. 

Top Management – (ref. ISO 9000-2000 definition 3.2.7) the person or group of people who 

directs and controls an organization. 

4. Policy 

4.1. General Requirements 

A) Safety management shall be included in the complete scope of the operator’s systems

including: 

 

17 Adapted from definition 3.2.5 in ISO 9000-2000 for “quality objectives.” 

18 Adapted from definition 3.2.9 in ISO 9000-2000 for “quality planning.” 

Page 4 
DATE AC 120-92 

Appendix 1 

1) flight operations; 

2) dispatch/flight following; 

3) maintenance and inspection; 

4) cabin safety; 

5) ground handling and servicing; 

6) cargo handling; and 

7) training. 

B) SMS processes shall be: 

1) documented; 

2) monitored; 

3) measured; and 

4) analyzed. 

C) SMS outputs shall be: 

1) recorded; 

2) monitored; 

3) measured; and 

4) analyzed. 

D) The organization shall promote the growth of a positive safety culture (described in

Sections 4.2 and 7.1). 

4.2. Safety Policy 

A) Top management shall define the organization’s safety policy. 

B) The safety policy shall: 

1) include a commitment to implement an SMS; 

2) include a commitment to continual improvement in the level of safety; 

3) include a commitment to the management of safety risk; 

4) include a commitment to comply with applicable regulatory requirements; 

5) include a commitment to encourage employees to report safety issues without 

reprisal; 

6) establish clear standards for acceptable behavior; 

7) provide management guidance for setting safety objectives; 

8) provide management guidance for reviewing safety objectives; 

9) be documented; 

10) be communicated to all employees and responsible parties; 

Page 5 
AC 120-92 DATE 

Appendix 1 

11) be reviewed periodically to ensure it remains relevant and appropriate to the 

organization; and 

12) identify responsibility of management and employees with respect to safety 

performance. 

4.3. Quality Policy 

Top management shall ensure that the organization’s quality policy is consistent with the

SMS. 

4.4. Safety Planning 

The organization shall establish and maintain a safety management plan to meet the safety

objectives described in its safety policy. 

4.5. Organizational Structure and Responsibilities 

A) Top management shall have the ultimate responsibility for the SMS. 

B) Top management shall provide resources essential to implement and maintain the 

SMS. 

C) Top management shall appoint a member of management who, irrespective of other 

responsibilities, shall have responsibilities and authority that includes: 

1) ensuring that process needed for the SMS are established, implemented and 

maintained 

2) reporting to top management on the performance of the SMS and the need for 

improvement, and 

3) ensuring the promotion of awareness of safety requirements throughout the 

organization. 

D) Aviation safety-related positions, responsibilities, and authorities shall be: 

1) defined; 

2) documented; and 

3) communicated throughout the organization. 

4.6. Compliance with Legal and Other Requirements 

A) The SMS shall incorporate a means of compliance with safety-related legal and 

regulatory requirements. 

B) The organization shall establish and maintain a procedure to identify to current

safety-related legal and regulatory requirements applicable to the SMS. 

Page 6 
DATE AC 120-92 

Appendix 1 

4.7. Procedures and Controls 

A) The organization shall establish and maintain procedures with measurable criteria to

accomplish the objectives of the safety policy19. 

B) The organization shall establish and maintain process controls to ensure procedures 

are followed for safety-related operations and activities. 

4.8. Emergency Preparedness and Response 

The organization shall establish procedures to: 

1) identify the potential for accidents and incidents; 

2) coordinate and plan the organization’s response to accidents and incidents; and 

3) execute periodic exercises of the organization’s response. 

4.9. Documentation and Records Management 

A) General. 

The organization shall establish and maintain information, in paper or electronic form, to 

describe: 

1) safety policies; 

2) safety objectives; 

3) SMS requirements; 

4) safety-related procedures and processes; 

5) responsibilities and authorities for safety-related procedures and processes; 

6) interaction/interfaces between safety-related procedures and processes; and 

7) SMS outputs. 

B) Documentation Management. 

1) Documentation shall be: 

a) legible; 

b) dated (with dates of revisions); 

c) readily identifiable; 

d) maintained in an orderly manner; and 

e) retained for a specified period as determined by the organization (and 

approved by the oversight organization). 

2) The organization shall establish and maintain procedures for controlling all 

documents required by this Standard to ensure that: 

 

19 Measures are not expected for each procedural step. However, measures and criteria should be of sufficient depth 

and level of detail to ascertain and track accomplishment of objectives. Criteria and measures can be expressed in

either quantitative or qualitative terms. 

Page 7 
AC 120-92 DATE 

Appendix 1 

a) they can be located; 

b) they are periodically: 

(1) reviewed, 

(2) revised as necessary, and 

(3) approved for adequacy by authorized personnel; 

c) the current versions of relevant documents are available at all locations where 

operations essential to the effective functioning of the SMS are performed; and 

d) obsolete documents are promptly removed from all points of use or otherwise 

assured against unintended use. 

C) Records Management. 

1) For SMS records, the organization shall establish and maintain procedures for 

their: 

a) identification; 

b) maintenance; and 

c) disposition. 

2) SMS records shall be: 

a) legible; 

b) identifiable; and 

c) traceable to the activity involved. 

3) SMS records shall be maintained in such a way that they are: 

a) readily retrievable; and 

b) protected against: 

(1) damage, 

(2) deterioration, or 

(3) loss. 

4) Record retention times shall be documented. 

5. Safety Risk Management 

A) SRM shall, at a minimum, include the following processes: 

1) system and task analysis; 

2) identify hazards; 

3) analyze safety risk; 

4) assess safety risk; and 

5) control safety risk. 

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B) The SRM process shall be applied to: 

1) initial designs of systems, organizations, and/or products; 

2) the development of operational procedures; 

3) hazards that are identified in the safety assurance functions (described in 

Section 6); and 

4) planned changes to the operational processes to identify hazards associated with

those changes. 

C) The organization shall establish feedback loops between assurance functions

described in Section 6 to evaluate the effectiveness of safety risk controls. 

D) The organization shall define acceptable and unacceptable levels of safety risk (or 

safety risk objectives). 

1) Descriptions shall be established for: 

a) severity levels, and 

b) likelihood levels. 

2) The organization shall define levels of management that can make safety risk 

acceptance decisions. 

3) The organization shall define acceptable risk for hazards that will exist in the 

short-term while safety risk control/mitigation plans are developed and executed. 

E) The following shall not be implemented until the safety risk of each identified hazard 

is determined to be acceptable in: 

1) new system designs; 

2) changes to existing system designs; 

3) new operations/procedures; and 

4) modified operations/procedures. 

F) The SRM process shall not preclude the organization from taking interim immediate 

action to mitigate existing safety risk. 

5.1. System and Task Analysis 

A) System and task descriptions shall be developed to the level of detail necessary to

identify hazards. 

B) System and task analyses should consider the following: 

1) the system’s interactions with other systems in the air transportation system (e.g. 

airports, air traffic control); 

2) the system’s functions for each area listed in para 4.1 A); 

3) employee tasks required to accomplish the functions in 5.1 B) 2); 

4) required human factors considerations of the system (e.g. cognitive, ergonomic, 

environmental, occupational health and safety) for:

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a) operations, and 

b) maintenance; 

5) hardware components of the system; 

6) software components of the system; 

7) related procedures that define guidance for the operation and use of the system; 

8) ambient environment; 

9) operational environment; 

10) maintenance environment; 

11) contracted and purchased products and services; 

12) the interactions between items in Section 5.1.B., 2 - 10 above; and 

13) any assumptions made about: 

a) the system, 

b) system interactions, and 

c) existing safety risk controls. 

5.2. Identify Hazards 

A) Hazards shall be: 

1) identified for the entire scope of the system that is being evaluated as defined in 

the system description20; and 

2) documented. 

B) Hazard information shall be: 

1) tracked, and 

2) managed through the entire SRM process. 

5.3. Analyze Safety Risk 

The safety risk analysis process shall include: 

1) existing safety risk controls; 

2) triggering mechanisms; and; 

3) safety risk of reasonably likely outcomes from the existence of a hazard, to 

include estimation of the: 

a) likelihood; and 

b) severity. 

 

20 While it is recognized that identification of every conceivable hazard is impractical, operators are expected to 

exercise due diligence in identifying and controlling significant and reasonably foreseeable hazards related to their 

operations. 

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5.4. Assess Safety Risk 

A) Each hazard shall be assessed for its safety risk acceptability using the safety risk 

objectives described in Section 5D. 

B) The organization shall define levels of management that can make safety risk

acceptance decisions. 

5.5. Control Safety Risk 

A) Safety control/mitigation plans shall be defined for each hazard with unacceptable 

risk. 

B) Safety risk controls shall be: 

1) clearly described; 

2) evaluated to ensure that the requirements have been met; 

3) ready to be used in the operational environment for which they are intended; and 

4) documented. 

C) Substitute risk shall be evaluated in the creation of safety risk controls/mitigations. 

6. Safety Assurance and Internal Evaluation 

Figure 3 illustrates how Safety Assurance functions (described in Sections 6.2 – 6.6) are 

linked to the SRM process (described in Section 5). 

6.1. General Requirements 

The organization shall monitor heir systems and operations to: 

1) identify new hazards; 

2) measure the effectiveness of safety risk controls; and 

3) ensure compliance with regulatory requirements. 

6.2. System Description 

The safety assurance function shall be based upon a comprehensive system description as 

described in Section 5.1. 

6.3. Information Acquisition 

The organization shall collect the data necessary to demonstrate the effectiveness of the 

organization’s: 

1) Operational processes; and 

2) the SMS. 

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6.3.1 Continuous Monitoring 

A) The organization shall monitor operational data (e.g., duty logs, crew reports, work

cards, process sheets, or reports from the employee safety feedback system specified in 

Section 7.1.5 to: 

1) assess conformity with safety risk controls (described in Section 5); 

2) measure the effectiveness of safety risk controls (described in Section 5); 

3) assess system performance; and 

4) identify hazards. 

B) The organization shall monitor products and services received from subcontractors. 

6.3.2 Internal Audits by Operational Departments 

A) Line management of operational departments shall ensure that regular internal audits 

of safety-related functions of the organization’s operational processes (production 

system) are conducted. This obligation shall extend to any subcontractors that they may 

use to accomplish those functions. 

B) Line management shall ensure that regular audits are conducted to: 

1) determine conformity with safety risk controls; and 

2) assess performance of safety risk controls. 

C) Planning of the audit program shall take into account: 

1) safety significance of the processes to be audited; and 

2) the results of previous audits. 

D) The audit program shall include: 

1) definition of the audit: 

a) criteria, 

b) scope, 

c) frequency, and 

d) methods; 

2) the processes used to select the auditors; 

3) the requirement that individuals shall not audit their own work; 

4) documented procedures, which include: 

a) the responsibilities; and 

b) requirements for: 

(1) planning audits, 

(2) conducting audits, 

(3) reporting results, and 

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(4) maintaining records; and

5) audits of contractors and vendors. 

6.3.3 Internal Evaluation 

A) The organization shall conduct internal evaluations of the operational processes and 

the SMS at planned intervals to determine that the SMS conforms to requirements. 

B) Planning of the evaluation program shall take into account: 

1) safety significance of processes to be audited; and 

2) the results of previous audits. 

C) The evaluation program shall include:

1) definition of the evaluation: 

a) criteria; 

b) scope; 

c) frequency; and 

d) methods; 

2) the processes used to select the auditors; 

3) the requirement that auditors shall not audit their own work; 

4) documented procedures, which include: 

a) the responsibilities, and 

b) requirements for: 

(1) planning audits, 

(2) conducting audits, 

(3) reporting results, 

(4) and maintaining records; and 

5) audits of contractors and vendors. 

D) The program shall be under the direction of the management official described in 

Section 4.5. 

E) The program shall include an evaluation of the program required described in 

Section 6.3.2. 

F) The person or organization performing evaluations of operational departments must

be functionally independent of the department being evaluated. 

6.3.4 External Auditing of the SMS 

A) The organization shall include the results of oversight organization audits in the 

analyses conducted as described in Section 6.4. 

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6.3.5 Investigation 

A) The organization shall collect data on: 

1) incidents, and 

2) accidents. 

B) The organization shall establish procedures to: 

1) investigate accidents; 

2) investigate incidents; and 

3) investigate instances of potential regulatory non-compliance. 

6.3.6 Employee Reporting and Feedback System. 

A) The organization shall establish and maintain a confidential employee safety 

reporting and feedback system as in Section 7.1.5). 

B) Employees shall be encouraged to use the safety reporting and feedback system 

without reprisal as in Section 4.2 B) 5). 

C) Data from the safety reporting and feedback system shall be monitored to identify 

emerging hazards. 

D) Data collected in the safety reporting and feedback system shall be included in 

analyses described in Section 6.4. 

6.4. Analysis of Data 

A) The organization shall analyze data the data described in Section 6.3 to demonstrate 

the effectiveness of: 

1) risk controls in the organization’s operational processes, and 

2) the SMS. 

B) Through data analysis, the organization shall evaluate where improvements can be 

made to the organization’s: 

1) operational processes, and 

2) SMS. 

6.5. System Assessment 

A) The organization shall assess the performance of: 

1) safety-related functions of operational processes against their requirements, and 

2) the SMS against its requirements. 

B) System assessments shall result in a finding of: 

1) conformity with existing safety risk control(s)/ SMS requirement(s) (including 

regulatory requirements); 

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2) nonconformity with existing safety risk control(s)/ SMS requirement(s) (including 

regulatory requirements); and 

3) new hazard(s) found. 

C) The SRM process will be utilized if the assessment indicates: 

1) the identification of new hazards; or 

2) the need for system changes. 

D) The organization shall maintain records of assessments in accordance with the 

requirements of Section 4.9. 

6.6. Preventive/Corrective Action 

A) The organization shall develop, prioritize, and implement, as appropriate: 

1) corrective actions for identified nonconformities with risk controls; and 

2) preventive actions for identified potential nonconformities with risk controls 

actions. 

B) Safety lessons learned shall be considered in the development of: 

1) corrective actions; and 

2) preventive actions. 

C) The organization shall take necessary corrective action based on the findings of 

investigations. 

D) The organization shall prioritize and implement corrective action(s) in a timely 

manner. 

E) The organization shall prioritize and implement preventive action(s) in a timely 

manner. 

F) Records shall be kept of the disposition and status of corrective and preventive

actions per established record retention policy. 

6.7. Management Reviews 

A) Top management will conduct regular reviews of the SMS, including: 

1) the outputs of SRM (Section 5); 

2) the outputs of safety assurance (Section 6); and 

3) lessons learned (Section 7.5). 

B) Management reviews shall include assessing the need for changes to the 

organization’s: 

1) operational processes, and 

2) SMS. 

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6.8 Continual Improvement 

The organization shall continuously improve the effectiveness of the SMS and of safety risk 

controls through the use of the safety and quality policies, objectives, audit and evaluation 

results, analysis of data, corrective and preventive actions, and management reviews. 

7. Safety Promotion 

7.1. Safety Culture 

Top management shall promote the growth of a positive safety culture through: 

1) publication of senior management’s stated commitment to safety to all employees; 

2) visible demonstration of their commitment to the SMS; 

3) communication of the safety responsibilities for the organization’s personnel; 

4) clear and regular communication of safety policy, goals, objectives, standards, 

and performance to all employees of the organization 

5) an effective employee safety feedback system that provides confidentiality as is

necessary; 

6) use of a safety information system that provides an accessible efficient means to 

retrieve information; and

7) allocation of resources essential to implement and maintain the SMS. 

7.2. Communication and Awareness 

A) The organization shall communicate outputs of the SMS to its employees, as

appropriate. 

B) The organization shall provide access to the outputs of the SMS to its oversight

organization, in accordance with established agreements and disclosure programs. 

7.3. Personnel Requirements (Competence) 

A) The organization shall document competency requirements for those positions 

identified in Section 4.5.D). 

B) The organization shall ensure that those individuals in the positions identified in

4.5.D) meet those competency requirements. 

7.4. Training 

Training shall be developed for those individuals in the positions identified in 4.5.D). 

1) Training shall include: 

a) initial training; and 

b) recurrent training. 

2) Employees shall receive training commensurate with their: 

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a) Level of responsibility; and 

b) impact on the safety of the organization’s product or service. 

3) To ensure training currency, it shall be periodically: 

a) reviewed; and 

b) updated. 

7.5. Safety Lessons Learned 

A) The organization shall develop safety lessons learned. 

B) Lessons learned information shall be used to promote continuous improvement of 

safety. 

C) The organization shall communicate information on safety lessons learned. 

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Appendix 2 

APPENDIX 2. COMPARISON OF SMS-P STANDARD WITH OTHER STANDARDS 

1. PURPOSE OF THIS APPENDIX. 

a. The table below is provided to assist those organizations developing and implementing an 

SMS. It provides a link between existing standards and this standard. It includes links to the 

following: 

(1) Quality Management Systems via International Standards Organization 

(ISO) 9001:2000 and the Aerospace Basic Quality System Standard (AS 9100) requirements; 

(2) Environmental Management Systems via ISO 14001 requirements; and 

(3) Occupational Safety and Health Management Systems via OHSAS 18001. (NOTE:

OHSAS 18001 is an Occupation Health and Safety Assessment Series for health and safety 

management systems, which was created through a concerted effort from a number of the 

world’s leading national standards bodies, certification bodies, and specialist consultancies.) 

b. The table is intended to assist the developer in building on existing management systems

to develop the SMS and/or integrating its SMS with these existing management systems. 

2. SMS-P STANDARD COMPARED WITH OTHER STANDARDS. 

Content (Standards) SMS-P 

Standard 

ISO 

9001:2000/ 

AS 9100 

ISO 14001 OHSAS 

18001 

Scope and application 1 1 1 1

References (Normative) 2 2 2 2

Definitions 3 3 3 3

Management system description 4 4 4 4 

General requirements (and 

Responsibility/Authority (ISO 9000)) 4.1 4.1, 5.5 4.1 4.1

Policy (safety, environmental, 

quality) 4.2, 4.3 5.1, 5.3, 8.5 4.2 4.2 

Planning 4.4 5.4 4.3 4.3

Requirements (hazard/risk, 

environmental aspects, customer 

requirements) 

5 5.2, 7.2.1, 

7.2.2 4.3.1 4.3.1

Legal and other requirements, 

customer focus (ISO 9000) 4.6 5.2, 7.2.1 4.3.2 4.3.2

Objectives and targets 4.2.B), 5D. 5.4.1 4.3.3 4.3.3 

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Appendix 2 

Content (Standards) SMS-P 

Standard 

ISO 

9001:2000/ 

AS 9100 

ISO 14001 OHSAS 

18001 

Programs, action planning to meet 

targets, continual improvement 

4.1.A), 4.4, 

5.5 5.4.2, 8.5.1 4.3.4 4.3.4 

Management responsibility and 

organizational structure 4.5 

5, 6 

(Resource 

mgmt.) 

4.4.1 4.4.1

Training 7.3, 7.4 6.2.2 4.4.2 4.4.2

Communications 6.3.6, 7.2, 7.5 5.5.3, 7.2.3 4.4.3 4.4.3 

Documentation and quality manual 

(ISO 9000) 4.9 4.2 4.4.4 4.4.4

Document and data control 4.9 4.2.3 4.4.5 4.4.5 

Operational control and product 

realization 4.7 7 4.4.6 4.4.6

Emergency preparedness and 

response, control of nonconforming 

product (ISO 9000) 

4.8 8.3 4.4.7 4.4.7

Performance measurement and 

monitoring 

4.1, 6.3.1, 

6.4, 6.5 8 4.5 4.5

Accidents, incidents, nonconformity, 

corrective and preventive action 6.3.5, 6.5, 6.6 8.3, 8.5.2, 8.5.3 4.5.2 4.5.2

Auditing 6.3.3 – 6.3.5 8.2.2 4.5.4 4.5.4 

Management review 6.7 5.6 4.6 4.6

Continual Improvement 6.8 8.5.1 4.3.4 4.3.4

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