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VOLUME 17 SAFETY MANAGEMENT SYSTEM

CHAPTER 2 ACCEPTING A CERTIFICATE HOLDER’S SMS

Section 1 Description and Methods

17-2-1-1 GENERAL.

A. Purpose. This chapter provides guidance for Federal Aviation Administration (FAA) 

Flight Standards Service (AFS) personnel on the acceptance of Title 14 of the Code of Federal 

Regulations (14 CFR) part 121 certificate holders’ Safety Management Systems (SMS), as 

required by 14 CFR part 5, §§ 5.1(a) and 5.3(a).

B. Scope. This chapter explains “what” a Certificate Management Team (CMT) should 

evaluate regarding a certificate holder’s SMS and “how” it should evaluate and record the 

acceptance of the SMS.

17-2-1-3 REGULATORY REQUIREMENT. Part 5 requires a certificate holder authorized 

to conduct operations in accordance with the requirements of part 121 to have an SMS that meets 

the requirements of part 5 and is acceptable to the Administrator by March 9, 2018.

17-2-1-5 SMS ACCEPTANCE TOOLS. Air Transportation Oversight System (ATOS) Data 

Collection Tools (DCT).

A. Safety Attribute Inspections (SAI). The FAA has developed eight SAIs (four for 

Operations and four for Airworthiness) in the ATOS System 8 to evaluate and record a 

certificate holder’s SMS design. They are: Element 8.1.1, Safety Policy; Element 8.2.1, Safety 

Risk Management; Element 8.3.1, Safety Assurance; and Element 8.4.1, Safety Promotion, and 

are described in Volume 10, Air Transportation Oversight System. The ATOS system 8 SAIs 

will be the primary tool for inspectors to evaluate and record the certificate holder’s SMS 

implementation efforts and for continuing oversight once an SMS is fully implemented.1

B. System Attributes. Because an SMS is a complete system, system attributes

(e.g., controls, interfaces, and measures) are built into the SMS SAIs’ procedures section 

questions (unlike current ATOS element DCTs). As the other system attribute sections are 

addressed in the procedures section, they require no separate input. Additionally, SMS DCT 

questions are “system oriented.” This means that most SMS questions ask about an entire 

system, process, or policy. In all other aspects, the ATOS System 8 DCTs follow Volume 10 

functionality.

C. National SMS Implementation ConDOR. To aid inspectors in the completion of 

SMS validation activities, System 8 SAIs and, National SMS Implementation Constructed 

Dynamic Observation Reports (ConDOR) templates have been created using the System 8 SAI 

questions. The National SMS Implementation ConDORs may be used, as necessary, to evaluate 

and record the certificate holder’s SMS implementation, piece by piece, as the SMS is 

developed.

 

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As ATOS is replaced by the Safety Assurance System (SAS), equivalent SAS tools and processes will be utilized in place of ATOS.
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17-2-1-7 HOW TO EVALUATE A CERTIFICATE HOLDER’S SMS FOR 

ACCEPTANCE. This paragraph provides standardized guidance for the evaluation process. The 

CMT and the certificate holder or applicant may come to an agreement upon any type of SMS 

that suits the certificate holder’s unique business needs, provided that the result meets the 

requirements of part 5.

A. Follow the Certificate Holder’s Implementation Plan. The certificate holder’s 

implementation plan should describe how they intend to comply with the part 5 requirements 

This may include plans for new systems, processes or procedures as well as incorporation of 

existing programs and processes.

1) The Certificate Holder’s Approved Implementation Plan.

a) Following approval of an implementation plan, the certificate holder will 

begin to develop and implement their SMS. For part 5 requirements with which they are not yet 

compliant, the certificate holder will describe their intended compliance action(s), name the 

organization/group and/or individual(s) responsible for the action(s), and provide an estimated

completion date for compliance.

b) Adjustment of estimated completion dates during the implementation process 

is expected, especially during the first year or two. As the certificate holder proceeds with their 

SMS implementation, they may need to reconsider various facets of their SMS and make 

revisions. Such revisions may necessitate delay of estimated completion dates. Some extension 

of estimated completion dates may be considered acceptable, but an excessive number of 

estimated completion date delays may impact the CMT’s ability to effectively review and 

evaluate the certificate holder’s proposed SMS. Changes to the certificate holder’s approved 

implementation plan must be submitted to the CMT as soon as is practical and may or may not 

be approved.

NOTE: It should be made clear to the certificate holder that CMT approval of 

modified estimated completion dates in no way negates the certificate holder’s 

responsibility to have an SMS that meets the requirements of part 5 and is 

acceptable to the Administrator by March 9, 2018.

2) Determine that the Certificate Holder Complies With Part 5 Requirements.

a) The CMT will evaluate certificate holder documentation to ensure the design 

of the certificate holder’s SMS is in compliance with part 5 requirements.

b) Examples of documentation include:

 References to an organizational manual that describes the policy, 

procedures, controls, interfaces, etc. of the process that complies with 

part 5 requirements.

 Other documents, such as training material, records, interviews, 

observations, correspondence (e.g., email or memo), organizational charts, 

or meeting minutes.
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c) To assist the recording of evaluations, CMTs may utilize the ATOS System 8 

SAI DCTs and National SMS Implementation ConDORs, per Volume 10 (ATOS), Chapter 2, 

Procedures for Design and Performance Assessment. The result of CMT evaluations should be 

maintained in accordance with these procedures. There is no requirement to attach copies of 

certificate holder documents to the ConDOR. See further discussion below.

d) National SMS Implementation ConDORs can be opened and closed relativity

quickly and allow the principal inspector (PI) the flexibility to assign ConDORs as the need 

arises. ConDORs allow the PI to gather oversight information across different time intervals as 

the certificate holder presents SMS processes for evaluation. For example, it may take some 

certificate holders the full 3 years allowed by part 5 to implement their SMS; however, keeping 

an SAI open for 3 years would be impractical. Using one or more National SMS Implementation 

ConDORs and assigning them at different timeframes might be a viable option.

e) The certificate holder may implement the same SMS processes in different

departments or areas of functional responsibility within their organization. For example, the 

certificate holder may have an SRM process at the corporate level, at the maintenance division 

level, and within an engine repair department. This may be the same process (e.g., SRM) that has 

been implemented at the same carrier at three different levels of the organization: the corporate, 

division, and department. Evaluate the manner in which the SRM process is implemented at each 

level. Do not assume that an SRM process implemented at the corporate level reflects equivalent 

implementation of this process at other levels. A certificate holder is under no obligation to 

implement SRM or any other SMS process at multiple levels of their organization, nor is there an 

obligation for SMS to apply to non-aviation-safety-related processes. The SRM process is a 

certificate holder’s responsibility; CMT evaluation should focus on establishment and utilization

of the SRM process. If a certificate holder implements an integrated SMS, the CMT will not 

provide assistance or evaluation on the non-aviation-related processes.

f) In the example above, a PI may want to construct an Element 8.2.1 National 

SMS Implementation ConDOR for the SRM process at the corporate level, another ConDOR for 

the maintenance division, and a ConDOR for the engine department.

g) Certificate holders participating in the Safety Management System Pilot 

Project (SMSPP), the Safety Management System Voluntary Program (SMSVP), and those who 

have implemented an SMS on their own or through third party consultants/vendors may present

their entire SMS to the CMT for acceptance as soon as part 5 becomes effective. Evaluation of 

an entire SMS, even for a small certificate holder, is a time- and resource-intensive activity for 

the CMT. The CMT should develop an evaluation plan and monitor progress against it. The plan 

should include the evaluation process steps, assign responsibility for evaluating sections of the 

SMS to individual CMT inspectors, and set a realistic schedule for completing the evaluation.

For assistance in developing an evaluation plan, see Volume 3, Chapter 1, Section 1, 

subparagraph 3-4F, Phase Four Planning. The CMT should monitor progress and take 

appropriate action (add/reduce resources, extend or contract the timeline, etc.) for the evaluation 

schedule to ensure that the SMS is adequately evaluated within a reasonable time. Should 

noncompliance issues be found, the CMT should provide timely feedback to the certificate 

holder and hold that evaluation step open until it is satisfied. The schedule should be amended 
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accordingly. Within ATOS, the Corrective Action Tracking Tool (CATT) is a viable tool which 

can be used to track initial noncompliance issues that have been discovered.

h) The number and frequency of National SMS Implementation ConDORs is up 

to the CMT and the PIs. Once the PIs have verified that all SAI questions for an SMS component 

have been satisfactorily answered through National SMS Implementation ConDORs, they can 

then complete the corresponding ATOS System 8 SAIs using the information documented from 

the National SMS Implementation ConDORs. When all requirements of part 5 have been 

satisfactorily implemented, the CMT Manager can accept the certificate holder’s SMS. See

paragraph 17-2-1-9, Accepting a Certificate Holder’s SMS, for acceptance procedures.

B. Unsatisfactory Submissions. Section 5.1(a) requires a certificate holder to “have a 

Safety Management System that meets the requirements of this part and is acceptable to the 

Administrator by March 9, 2018.” Unsatisfactory submissions by the certificate holder do not 

imply that the CMT is obligated to accept the submissions if they do not comply with part 5, 

even if the deadline for acceptance is drawing near. Appropriate records of submissions and 

discrepancy findings (National SMS Implementation ConDORs, CATT, etc.) by the CMT should 

be maintained, as should evidence of evaluation timeliness on the part of the CMT. Differences 

of opinions between the certificate holder and the CMT on the acceptability of the SMS should 

be referred to the normal chain of authority through respective FAA regional and national 

offices.

17-2-1-9 ACCEPTING A CERTIFICATE HOLDER’S SMS. Procedures for acceptance of 

the certificate holder’s SMS implementation plan should follow guidance contained in 

Volume 3, Chapter 1, The General Process for Approval or Acceptance.

A. Recording Acceptance of SMS Implementation. Once the CMT has determined 

that the certificate holder’s SMS is satisfactorily implemented, the CMT manager (office, unit, 

frontline, etc.) who is the approving entity for all collective decisions of the team) will accept

(per Volume 3, Chapter 1, Section 1, paragraph 3-6, Phase Five), the certificate holder’s SMS 

implementation in a timely manner and ensure that SMS implementation acceptance information 

is entered into the Program Tracking and Reporting Subsystem (PTRS) as follows:

1) Activity number 1045.

2) Enter “SMS ACCEPTANCE” in the “National Use” box.

B. SMS Acceptance Failures. Failure of the certificate holder to implement an SMS by

March 9, 2018 should be addressed in the same way as a noncompliance with any other 14 CFR 

requirements. The CMT should document and justify any rejection(s) of the certificate holder’s 

SMS per Volume 3, Chapter 1, Section 1, subparagraph 3-3B, Incomplete or Unacceptable 

Proposal, and/or office policy. The result of the National SMS Implementation ConDOR 

evaluations may be helpful in the development of this justification. (See subparagraph

17-2-1-7B, Unsatisfactory Submissions).

17-2-1-11 through 17-2-1-25 RESERVED.