Distribution: Electronic Only Initiated By: AFS-900

NOTICE U.S. DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION N 8900.281

National Policy

Effective Date: 

1/8/15

Cancellation Date: 

1/8/16

SUBJ: Safety Management Systems (SMS) – Approval of Part 121 Certificate 

Holders’ SMS Implementation Plans

1. Purpose of This Notice. This notice provides guidance for Federal Aviation Administration 

(FAA) Flight Standards Service (AFS) personnel on the approval of Title 14 of the Code of 

Federal Regulations (14 CFR) part 121 certificate holders’ Safety Management System (SMS) 

implementation plans, as required by 14 CFR part 5, § 5.1(b) and (c).

2. Audience. The primary audience for this notice is FAA AFS personnel in headquarters (HQ) 

branches, divisions, regions, and field offices. This notice will affect offices with direct 

responsibilities for oversight of certificate holders authorized to conduct operations in 

accordance with the requirements of part 121. The secondary audience includes Flight Standards 

branches and divisions in the regions and in HQ.

3. Where You Can Find This Notice. You can find this notice on the MyFAA employee 

Web site at https://employees.faa.gov/tools_resources/orders_notices. Inspectors can access this 

notice through the Flight Standards Information Management System (FSIMS) at 

http://fsims.avs.faa.gov. Operators can find this notice on the Federal Aviation Administration’s 

(FAA) Web site at http://fsims.faa.gov. This notice is available to the public at 

http://www.faa.gov/regulations_policies/orders_notices.

4. Regulatory Requirement. In accordance with part 5, a certificate holder must submit 

an implementation plan to the FAA Administrator for review no later than September 9, 2015.

The implementation plan must be approved no later than March 9, 2016.

5. References. During evaluation of the certificate holder’s implementation plan, Certificate 

Management Team (CMT) inspectors may have occasion to work with any, all, or none of the 

following documents/tools, in addition to part 5, when evaluating the certificate holder’s

implementation plan.

a. Related Publication. The current edition of AC 120-92, Safety Management Systems for 

Aviation Service Providers.
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b. Tools.

(1) The Air Transportation Oversight System (ATOS) SMS Design Assessment 

Supplement (DAS) Constructed Dynamic Observation Report (ConDOR) and/or the SMS 

Performance Assessment Supplement (PAS) ConDOR Data Collection Tools (DCT).

(2) The ATOS SMS Safety Attribute Inspection (SAI) DCTs for Element 8.1.1, Safety

Policy (OPS/AWS); Element 8.2.1, Safety Risk Management (OPS/AWS); Element 8.3.1, Safety 

Assurance (OPS/AWS); and Element 8.4.1, Safety Promotion (OPS/AWS).1

(3) The 14 CFR Part 5 Gap Analysis Tool for any certificate holder that chooses to use it 

for their part 5 implementation plan development.

(4) The Web-Based Application Tool (WBAT), SMS Implementation Plan Manager 

Module.

Note: Certificate holders may develop their implementation plans in any manner 

and/or medium that meets their needs and is acceptable to the CMT. The above 

tools/documents are only suggestions. Certificate holders in the SMS Pilot Project 

(SMSPP)

2 may continue to develop their SMSs with the Detailed Gap Analysis 

Tool (or the Part 5 Gap Analysis Tool). The gap analysis tools, combined with 

Appendix A, will ensure part 5 compliance. 

6. General Guidance. The following resources are available to a CMT during a certificate 

holder’s SMS implementation plan development and approval process. 

a. Flight Standards National Field Office (AFS-900).

(1) SMS Program Office (SMSPO). The SMSPO is the national point of contact (POC) 

for FAA HQ and field divisions in development of SMS policies, procedures, and work 

instructions. The office is responsible for AFS SMS standardization, training, and guidance.

(2) Implementation Support Team (IST). The SMSPO manages an IST. Part of the 

SMSPO, the IST is the primary interface between the SMSPO and principal inspectors (PI), 

CMT personnel, field offices, and divisional SMS specialists. The IST provides briefings, 

orientation sessions, meetings, and/or seminars, as required. SMS IST members will provide 

guidance, facilitation, and suggestions on SMS issues to both the CMT and the certificate holder. 

This service is expected to be available to existing certificate holders and their respective CMTs 

throughout the part 5 SMS implementation period.

(3) SMSPO assistance can be obtained by emailing the SMSPO National Coordination at 

9-NATL-SMS-ProgramOffice@faa.gov.

 

1

As ATOS is replaced by the Safety Assurance System (SAS), equivalent SAS tools and processes will be utilized in place of ATOS.

2

The SMS Pilot Project was replaced in August 2014 with the SMS Voluntary Program (SMSVP). The SMSVP is based on part 5.
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3

b. Regional Point of Contact (RPOC). Most FAA regional Flight Standards division 

(RFSD) offices have an SMS RPOC. RPOCs are part of the regional staff and, with the 

assistance of the SMSPO, stay abreast of the latest SMS developments and information.

7. Implementation Plan Review and Analysis Process. Procedures for review and analysis of 

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

8900.1, Volume 3, Chapter 1, The General Process for Approval or Acceptance.

a. What is an Implementation Plan?

(1) The implementation plan is simply a roadmap describing how the certificate holder 

intends to implement processes that meet the requirements of part 5. Therefore, the 

implementation plan should be a realistic strategy for managing SMS implementation.

(2) The implementation plan need not be complex. However, there should be sufficient 

detail to ensure that the certificate holder will meet the overall objective stated in part 5: “to 

develop and implement a safety management system (SMS) to improve the safety of 

aviation-related activities” by March 9, 2018.

b. Receipt of a Certificate Holder’s Implementation Plan. When the CMT receives 

an SMS implementation plan from the certificate holder (per Order 8900.1, Volume 3, Chapter 1, 

Section 1, paragraph 3-3, Phase Two), the CMT will:

(1) Review the implementation plan to verify that it has been submitted on time (no later 

than September 9, 2015 and is complete (see subparagraphs 7c and d)).

(2) Analyze and evaluate (per Order 8900.1, Volume 3, Chapter 1, Section 1, 

Paragraph 3-4, Phase Three), the certificate holder’s intended plans to develop or bring 

nonconforming safety management processes into compliance with part 5 by March 9, 2018 and 

determine whether the plan is realistic.

c. What the Implementation Plan Should Cover. The certificate holder’s implementation 

plan should include:

(1) Organization-wide SMS development and implementation across all 

aviation safety-related operational functions (i.e., include all activities or systems that directly 

affect aviation safety).

(2) Any existing programs, policies, or procedures the certificate holder intends to 

include in their SMS.3

(3) SMS components and processes that are designed appropriately to the size, scope, and 

complexity of the certificate holder’s operation. Simply stated, small, medium, and large service 

 

3

For example, the certificate holder’s implementation plan should show, if applicable, how their Continuing 

Analysis and Surveillance Systems (CASS), aspects of an Internal Evaluation Program (IEP), aspects of Quality 

Management Systems (QMS), and elements of employee reporting programs such as an Aviation Safety Action 

Program (ASAP) meet specific part 5 SMS requirements.
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provider implementation plans will not look the same. For example, though the Safety Risk 

Management (SRM) processes are identical regardless of the organization’s size, scope, or 

complexity, a small carrier might have only one SRM team for the entire company while a large 

carrier might have multiple SRM teams at the department, division, and/or corporate level.4

d. What to Look for in an Implementation Plan.

(1) The certificate holder should list specific part 5 requirements applicable to their 

operation (e.g., § 5.23(a)(2)(ii)).

(2) For each specific part 5 requirement, the certificate holder’s planning information 

should contain the following minimum information:

(a) Documentation (e.g., reference to a manual or document) that they comply with 

the specific regulatory requirement (SRR); or

(b) Their plan to comply with the SRR. Their plan should include:

 A brief narrative describing what actions the certificate holder intends to use 

to comply with the SRR;

 The responsible organization/group and/or individual(s) who will ensure that 

those actions are completed; and

 The estimated completion date (ECD) (timelines) for compliance with the 

SRR.

(3) Prior to approval, the implementation plan must be reviewed by the AFS-900 

SMSPO.

(a) Implementation reviews conducted by the AFS-900 PO will consider the 

following elements:

 Designation of an appropriate accountable executive in accordance with 

§ 5.25(a).

 Completeness of the plan to implement all of the SMS processes required by

part 5.

 Certificate Holder and CMT activities sufficient to validate compliance with 

part 5 in accordance with the timelines in § 5.1.

 Sufficient designated personnel resources to accomplish the implementation 

activities defined in the plan.

(b) Satisfactory reviews will be signed by the AFS-900 SMSPO manager or his or her 

designee.

 

4 During the SMS acceptance process (the next step after implementation plan approval), the CMT must evaluate 

conformance of each pertinent process (e.g., flight operations, maintenance operations, and cabin services) against 

part 5 requirements. The CMT must also ensure that the carrier’s implementation plan addresses each level (e.g., 

corporate or division) and functional operation that directly affects aviation safety (e.g., dispatch, ground, and cargo) 

against each part 5 requirement. 
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(c) Unsatisfactory items resulting from the review will be referred to the manager of 

the certificate holding office.

(d) Engagement of the SMSPO at an early stage of the process is recommended to 

ensure timely review, feedback, and approval; however, the SMSPO may be contacted for 

consultation at any time.

(4) When the CMT agrees that the certificate holder’s implementation plan is satisfactory, 

the CMT manager will approve the plan per subparagraph 8a. If the plan must be rejected, follow 

subparagraph 8b.

e. Functional Considerations.

(1) Because an SMS cannot be a substitute for any other regulatory requirements, during 

the certificate holder’s SMS implementation plan development, the CMT will continue all of its 

normal oversight and certificate management duties. Once the certificate holder’s SMS 

implementation plan is approved, CMT oversight will include monitoring changes to the 

approved plan and conformance to the plan’s schedule for development and implementation of 

the certificate holder’s SMS.

(2) The first of two part 5 FAA responsibilities is approval of the certificate holder’s

implementation plan. The second is to accept the certificate holder’s SMS. The implementation 

plan approval process should consider the CMT workload and the resource requirements of the 

SMS acceptance process. For example, once the certificate holder’s implementation plan is 

approved, they will follow that plan and begin to design, develop, modify, or align SMS 

processes to fit their business model and unique operational environment. An implementation 

plan that has all SMS components due for evaluation the month prior to the deadline would place 

unrealistic expectations on the CMT.

(3) During implementation plan development, the CMT should periodically review the 

plan and include informal feedback on adequacy, timeliness of the proposed implementation 

schedule, and completeness. Communication between the certificate holder and the CMT allows 

time for the CMT to make suggestions, permit course corrections, and provide feedback on the 

adequacy of the plan.

f. Implementation Plan Changes. Any changes made by the certificate holder to 

an approved implementation plan must be documented by the certificate holder and submitted to 

the CMT for approval. Use caution when implementation plan changes are approved that all 

estimated completion dates are not moved back to the end of the 3-year implementation period. 

Approval of a revised implementation plan implies that the CMT has available resources to 

evaluate submitted SMS components for acceptance in a timely manner (see Order 8900.1, 

Volume 16, Chapter 1, Section 1, subparagraph 16-1-1-3B).

8. Implementation Plan Approval Process. Procedures for approval of the certificate holder’s

implementation plan should follow guidance contained in Order 8900.1, Volume 3, Chapter 1.

a. Recording Approval of the Implementation Plan. If the certificate holder has 

submitted an acceptable implementation plan, the manager (office, unit, frontline, etc.) who is 
1/8/15 N 8900.281

6

the approving entity for all collective decisions of the team will approve (per Order 8900.1, 

Volume 3, Chapter 1, Section 1, Paragraph 3-6, Phase Five), the implementation plan by

March 9, 2016 and ensure that implementation plan approval information is entered into the 

Program Tracking and Reporting Subsystem (PTRS) as follows:

(1) Activity number: 1045.

(2) Enter “SMS IP APPROVAL” in the “National Use” box.

b. CMT Rejection of the Certificate Holder’s Implementation Plan. Rejection 

notification and comments will be returned to the certificate holder according to Order 8900.1, 

Volume 3, Chapter 1, Section 1, subparagraphs 3-3B and 3-6 and/or CMT office policy. Failure 

of the certificate holder to submit an acceptable implementation plan by March 9, 2016 should be 

addressed in the same way as a noncompliance with any other 14 CFR requirements. Appropriate 

records of submissions and discrepancy findings by the CMT should be maintained, as well as 

evidence of evaluation timeliness on the part of the CMT. Differences of opinions between the 

certificate holder and the CMT as to the acceptability of the SMS implementation plan should be 

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

9. Certificate Holders Participating in the SMS Voluntary Program (SMSVP).

a. SMS Implementation under AC 120-92A. Many certificate holders have begun or 

completed SMS implementation through the FAA SMSPP utilizing the framework contained in 

AC 120-92A. Their SMS implementation plans, or some or all components of their SMSs, have 

been validated by the FAA if they have exited level 1 or above. To comply with the 

implementation plan requirements of § 5.1(b), these certificate holders will need to conduct 

a comparison (gap analysis) of the systems currently in place under their SMS 

components/processes and the requirements of part 5. This comparison should identify any gaps 

that need to be addressed to bring their existing SMS into compliance with part 5. However, they

may not have to repeat the entire gap analysis and planning process in areas where there are no 

differences between the final rule and AC 120-92A guidance.

b. Revising Implementation Plans. Certificate holders may use the bridging tool attached 

to this notice (Appendix A) to assist in conducting a comparison (gap analysis) between part 5 

requirements, their current implementation plan, and those SMS processes already completed.

(1) If gaps are found, their current implementation plan will be amended (or a new, 

abridged implementation plan will be created)5to address the gaps identified and the amended 

plan will be submitted to the CMT for review.

(2) If no gaps are found, a current implementation plan (or revised plan) will be 

submitted to the CMT for review.

 

5

Certificate holders that have exited SMSPP level 3 (their implementation plan completed) may conduct a gap analysis of those areas of their 

SMS identified in the bridging document attached to this notice. A new, abridged implementation plan (addressing only the bridging document) 

will be submitted to their CMT for review.
1/8/15 N 8900.281

7

10. SMSs and Applicants for Air Carrier Certification. SMS implementation for a certificate 

applicant is different than that for a certificate holder. The implementation plan requirement and 

the specific deadline for full SMS implementation are dependent on when an organization 

submits its formal application for a part 121 certificate and when that organization completes all 

of the pertinent certification requirements.

a. Applicants Completing Formal Application After March 9, 2015. According to 

14 CFR part 119, § 119.8, applicants that have not completed formal application prior to 

March 9, 2015 must demonstrate that they meet the full requirements of part 5 prior to being 

issued a certificate. The application process can be found in Order 8900.1, Volume 10 (ATOS), 

Chapter 6, Section 2, Certification Process Document, or Volume 2, Chapter 3 for Safety

Assurance System (SAS).

b. Applicants Completing Formal Application Prior to March 9, 2015. Applicants that 

have completed formal application prior to March 9, 2015 may be issued certificates; however, 

they are still responsible for meeting the dates listed in §§ 5.1 and 119.8.

(1) Applicants Completing All Other Certification Requirements Prior to 

September 9, 2015. These applicants can be certificated without an SMS implementation plan. 

However, they must submit an SMS implementation plan prior to September 9, 2015 for 

approval by the FAA.

(2) Applicants Completing All Other Certification Requirements Prior to March 9, 2016.

These applicants must submit an SMS implementation plan for review by the FAA prior to being 

issued a certificate. They must have an approved implementation plan prior to March 9, 2016.

(3) Applicants Completing All Other Certification Requirements After March 9, 2016.

Prior to receiving a part 121 certificate, these applicants will be required to have an approved 

SMS implementation plan for completion of all part 5 requirements prior to March 9, 2018.

(4) Applicants that are Unable to Complete All Certification Requirements Prior to 

March 9, 2018. These applicants will be required to demonstrate compliance with all 

requirements for SMSs prior to being issued a certificate.

11. Disposition. This guidance will not be included in Order 8900.1, as the need for this 

guidance expires 12 months after the effective date of part 5. Direct questions concerning this 

notice to the SMSPO National Coordinator at 9-NATL-SMS-ProgramOffice@faa.gov.

John S. Duncan

Director, Flight Standards Service
1/8/15 N 8900.281

Appendix A

A-1

Appendix A. Safety Management System Pilot Project Participant Bridging Tool

This appendix is provided for certificate holders who have existing plans or documents that were 

developed through the former Safety Management System Pilot Project (SMSPP). The table 

below lists the differences between Advisory Circular (AC) 120-92A, Safety Management 

Systems for Aviation Service Providers, and Title 14 of the Code of Federal Regulations 

(14 CFR) part 5 as the SMS Program Office (SMSPO) has identified them. Each certificate 

holder in the SMS Voluntary Program (SMSVP) has implemented a Safety Management System 

(SMS) according to their own needs; therefore, a close review of their SMSs, this document, and 

part 5 is required.

This attachment is advisory; Federal Aviation Administration (FAA) Certificate Management 

Teams (CMT) are under no obligation to accept or reject an SMS component, element, or 

process based upon this document; the CMT will evaluate a certificate holder’s SMS against 

14 CFR part 5 and determine compliance. This bridging tool may be utilized in the same manner 

as a gap analysis tool in that objective evidence may be documented for differences already 

complied with and planning information may be documented for actions needed for compliance.

SMSPP Process Part 5 Reference Differences

If a certificate holder 

has implemented or is 

implementing an SMS 

per AC 120-92A, 

Appendix 1, these are 

the processes they have 

developed or are 

developing:

This is the part 5 

reference for the 

specific process:

Here are the noted differences between 

AC 120-92A and part 5. You should pay close 

attention to the processes identified to ensure 

part 5 compliance.

Words in bold are key words to focus on.

Component 1.0 Safety 

Policy and Objectives.

§§ 5.3(a)(1) 

and 5.21–5.27

• Ensure that the company designates an Accountable 

Executive and replaces the term “Top Management”

with the term “Accountable Executive” in their 

manuals and documentation.

[Wording and management concept change]

Element 1.1 Safety 

Policy.

§§ 5.21 and 5.23 • Ensure that the company’s Safety Policy contains 

a commitment to fulfill the organization’s safety 

objectives.

[Bold text not addressed in AC 120-92A]

• Ensure that the company’s Safety Policy defines 

requirements (vice “encourages”) for employee 

reporting of safety hazards or issues.

[Wording and process change, review existing 

process for part 5 compliance.]

• Ensure that the company’s safety policy defines 

unacceptable behavior and conditions for 

disciplinary action.
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Appendix A

A-2

SMSPP Process Part 5 Reference Differences

[Change from AC 120-92A (Element 1.1b(2)(f)]

• Ensure that the company’s Safety Policy contains 

an “emergency response plan which provides for the 

safe transition from normal to emergency operations 

in accordance with the requirements of § 5.27.” (refer 

to § 5.21(a)(6))

[Bold text not addressed in AC 120-92A]

• Ensure that the company’s Safety Policy requires 

regular reviews by the accountable executive (vice 

“organization/company/etc.”) to ensure that it 

remains relevant and appropriate to the certificate 

holder.

[Wording and process change]

• Ensure that the company’s Safety Policy defines 

management’s accountability for safety for SMS 

processes within their area of responsibility, 

including, but not limited to:

(i) Hazard identification and safety risk 

assessment.

(ii) Assuring the effectiveness of safety risk 

controls.

[Bold text not addressed in AC 120-92A]

Element 1.2 

Management 

Commitment and 

Safety 

Accountabilities.

§§ 5.23 and 5.25 • Ensure that the company defines accountabilities: 

for the following individuals:

(1) Accountable executive, as described in § 5.25.

(2) All members of management in regard to 

developing, implementing, and maintaining SMS 

processes within their area of responsibility, 

including, but not limited to:

(i) Hazard identification and safety risk 

assessment.

(ii) Assuring the effectiveness of safety risk 

controls.

(iii) Promoting safety as required in subpart E 

of this part.

(iv) Advising the accountable executive on 

the performance of the SMS and on any need 

for improvement.

(3) Employees relative to the certificate holder’s 

safety performance.

(b) The certificate holder must identify the 

levels of management with the authority to 

make decisions regarding safety risk 

acceptance.

[Wording and process change]
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Appendix A

A-3

SMSPP Process Part 5 Reference Differences

• Ensure that the company requires the accountable 

executive (vice “management”) to assess the SMS 

performance, to review the safety performance and 

direct actions to address substandard performance.

[Wording and process change not addressed in 

AC 120-92A]

Element 1.3 Key Safety 

Personnel.

§ 5.25 • Ensure that the company designates an accountable 

executive who satisfies the following:

(1) Is the final authority over operations 

authorized to be conducted under the 

certificate(s).

(2) Controls the financial resources required for 

the operations to be conducted under the 

certificate(s).

(3) Controls the human resources required for the 

operations authorized to be conducted under the 

certificate(s).

(4) Retains ultimate responsibility for the safety 

performance of the operations conducted under 

the certificate.

• Ensure that the company defines the following 

responsibilities for the accountable executive:

(b) Responsibilities of the accountable executive. 

The accountable executive must accomplish the 

following:

(1) Ensure that the SMS is properly 

implemented and performing in all areas of 

the certificate holder’s organization.

(2) Develop and sign the safety policy of the 

certificate holder.

(3) Communicate the safety policy 

throughout the certificate holder’s 

organization.

(4) Regularly review the certificate holder’s 

safety policy to ensure it remains relevant and 

appropriate to the certificate holder.

(5) Regularly review the safety performance 

of the certificate holder’s organization and 

direct actions necessary to address 

substandard safety performance in 

accordance with § 5.75.

• Ensure that the company requires the accountable 

executive (vice “top management”) to designate

sufficient management personnel (vice “a member 

of management”) who must be responsible for the 

following:
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Appendix A

A-4

SMSPP Process Part 5 Reference Differences

[Wording and process change]

(2) Facilitating hazard identification and safety 

risk analysis, and

(3) Monitoring the effectiveness of safety risk 

controls.

[Bold text not addressed in AC 120-92A]

Element 1.4 

Emergency 

Preparedness and 

Response.

§ 5.27 • Ensure that the company requires and the 

accountable executive approves as part of the Safety 

Policy, an emergency response plan that addresses at 

least the following:

(1) Delegation of emergency authority 

throughout the organization,

(2) Assignment of employee responsibilities 

during the emergency, and

(3) Coordination of the certificate holder’s 

emergency response plans with the emergency 

response plans of other organizations it must

interface with during the provision of its services.

[Bold text not addressed in AC 120-92A]

Element 1.5 SMS 

Documentation and 

Records.

§§ 5.95 and 5.97 • Ensure that the company requires the following 

record retention times:

(1) Output of SRM must be retained as long as 

controls are relevant,

(2) Output of SA records must be retained for 

a minimum of 5 years,

(3) Training records must be retained for as 

long as the individual is employed by the 

certificate holder, and

(4) Records of all communications for a 

minimum of 24 consecutive calendar-months.

[Bold text not addressed in AC 120-92A]

Component 2.0 Safety 

Risk Management 

(SRM).

Subpart C, Safety 

Risk Management, 

§§ 5.3(a)(2), 5.51, 

5.53, and 5.55

Element 2.1 Hazard 

Identification and 

Analysis.

Process 2.1.1 System 

Description And Task 

Analysis.

§ 5.53(a) and (b), 

System Analysis 

and Hazard 

Identification

• Ensure that procedures are in place, when 

conducting the system analysis, to require 

consideration of:

(1) Function and purpose of the system.
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Appendix A

A-5

SMSPP Process Part 5 Reference Differences

(2) The system’s operating environment.

(3) An outline of the system’s processes and 

procedures.

(4) The personnel, equipment, and facilities 

necessary for operation of the system.

[Bold text not addressed in AC 120-92A]

Process 2.1.2 Identify 

Hazards.

§ 5.53(c), System 

Analysis and 

Hazard 

Identification

No change noted.

Element 2.2 Risk 

Assessment And 

Control.

Process 2.2.1 Analyze 

Safety Risk.

§ 5.55(a), Safety 

Risk Assessment 

and Control

No change noted.

Process 2.2.2 Assess 

Safety Risk. 

§ 5.55(b), Safety 

Risk Assessment 

and Control

No change noted.

Process 2.2.3 

Control/Mitigate 

Safety Risk. 

§ 5.55(c), Safety 

Risk Assessment 

and Control

No change noted.

Component 3.0 Safety 

Assurance.

Subpart D, Safety 

Assurance, 

§§ 5.3(a)(3), 5.71, 

5.73, and 5.75

Element 3.1 Safety 

Performance 

Monitoring and 

Measurement.

Process 3.1.1 

Continuous 

Monitoring.

§ 5.71(a)(1) 

and (2), Safety 

Performance 

Monitoring and 

Measurement

• The company may consider replacing the term 

“Continuous Monitoring”, with the term 

“Monitoring” in their manuals and documentation.

[Optional wording change, no change to the process, 

review existing process for part 5 compliance. No 

requirement to match part 5 wording if the process is 

in compliance.]

• The certificate holder must develop and maintain 

processes and systems to acquire data with respect to 

its operations, products, and services to monitor the 

safety performance of the organization. These 
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Appendix A

A-6

SMSPP Process Part 5 Reference Differences

processes and systems must include, at a minimum, 

the monitoring of the operational environment to 

detect changes.

[Bold text not addressed in AC 120-92A]

Process 3.1.2 Internal 

Audits by Operational 

Departments.

§ 5.71(a)(3), Safety 

Performance 

Monitoring and 

Measurement

• The certificate holder must develop and maintain 

processes and systems to acquire data with respect to 

its operations, products, and services to monitor the 

safety performance of the organization. These 

processes and systems must include, at a minimum, 

auditing of operational processes and systems.

[The term “Systems” is not addressed in AC 120-92A 

in reference to this process. This is an optional 

wording change as there are no functional differences 

in the processes. There is no requirement to match 

part 5 wording if the process is in compliance.]

Process 3.1.3 Internal 

Evaluation.

§ 5.71(a)(4), Safety 

Performance 

Monitoring and 

Measurement

• The certificate holder must develop and maintain 

processes and systems to acquire data with respect to 

its operations, products, and services to monitor the 

safety performance of the organization. These 

processes and systems must include, at a minimum, 

evaluations of the SMS and operational processes 

and systems.

[The term “Systems” is not addressed in AC 120-92A 

in reference to this process. This is an optional 

wording change as there are no functional differences 

in the processes. There is no requirement to match 

part 5 wording if the process is in compliance.]

Process 3.1.4 External 

Auditing of the SMS.

§ 5.71(a)(3), Safety 

Performance 

Monitoring and 

Measurement

• This process has been included with § 5.71(a)(3)

[Combining of processes]

Process 3.1.5

Investigation.

§ 5.71(a)(5) 

and (6), Safety 

Performance 

Monitoring and 

Measurement

No change noted.

Process 3.1.6 Employee 

Reporting And 

Feedback System.

§ 5.71(a)(7), Safety 

Performance 

Monitoring and 

Measurement

• The company may consider replacing the term 

“Employee Reporting and Feedback System”, with 

the term “Confidential Employee Reporting 

System” in their manuals and documentation.

[This is an optional wording change as there are no 

functional differences in the processes. No 
1/8/15 N 8900.281

Appendix A

A-7

SMSPP Process Part 5 Reference Differences

requirement to match part 5 wording if the process is 

in compliance.]

• The certificate holder must develop and maintain 

processes and systems to acquire data with respect to 

its operations, products, and services to monitor the 

safety performance of the organization. These 

processes and systems must include, at a minimum, 

the following:

(7) A confidential employee reporting system in 

which employees can report hazards, issues, 

concerns, occurrences, incidents, as well as propose 

solutions and safety improvements.

[Bold text is not addressed in AC 120-92A with 

reference to the Employee Reporting System]

Process 3.1.7 Analysis 

of Data.

§ 5.71(b), Safety 

Performance 

Monitoring and 

Measurement

• The certificate holder must develop and maintain 

processes and systems to acquire data with respect to 

its operations, products, and services to monitor the 

safety performance of the organization. These 

processes and systems must include, at a minimum, 

processes, the following:

(8) The certificate holder must develop and maintain 

processes that analyze the data acquired through the 

processes and systems identified under paragraph (a) 

of this section and any other relevant data with 

respect to its operations, products, and services.

[Bold text is not addressed in AC 120-92A. There is 

a requirement for this process in the AC but it only 

refers to “operations”. Review existing process, if 

“operations” includes products and services. No 

change is required.]

Process 3.1.8 System 

Assessment.

§ 5.73, Safety 

Performance 

Assessment

No change noted.

Element 3.2 

Management Of 

Change.

§ 5.73(a)(4), Safety 

Performance 

Assessment

• This process has been included with § 5.73(a)(4)

[Combining of processes]

Element 3.3 

Continuous 

Improvement.

§ 5.75, Continuous 

Improvement

No change noted.

Process 3.3.1 

Preventive/Corrective 

Action.

§ 5.75, Continuous 

Improvement

No change noted.

Process 3.3.2 § 5.73(a)(4), Safety • This process has been included with § 5.73(a)(4)
1/8/15 N 8900.281

Appendix A

A-8

SMSPP Process Part 5 Reference Differences

Management Review. Performance 

Assessment [Combining of processes]

Component 4.0 Safety 

Promotion. 

Subpart E, Safety 

Promotion

Element 4.1 

Competencies and 

Training.

§ 5.91, 

Competencies and 

Training

No change noted.

Process 4.1.1 Personnel 

Expectations 

(Competence).

§ 5.91, 

Competencies and 

Training

No change noted.

Process 4.1.2 Training. § 5.91, 

Competencies and 

Training

No change noted.

Element 4.2 

Communication and 

Awareness.

§ 5.93, Safety 

Communication

• Compare and contrast these AC 120-92A, 

Appendix 1 elements/processes with part 5

requirements to ensure compliance: 1.1b(2)(l), 

1.2b(3), 1.3b(1)(c), 3.3b(2)(b), 4.0b(1)(c) and (d), 

and 4.2b(1).
1/8/15 N 8900.281

Appendix B

B-1

Appendix B. Comparison Table for Safety Management System Pilot Project 

Participants

The following table compares Advisory Circular (AC) 120-92A, Appendix 1, Aviation Service 

Provider Safety Management System Framework: Functional Expectations, with Title 14 of the 

Code of Federal Regulations (14 CFR) part 5. It is designed for certificate holders participating 

in the SMSPP who have implemented Safety Management Systems (SMS) according to the AC. 

This appendix is for information only.

AC 120-92A Appendix 1 (SMSPP) 14 CFR Part 5

Component 1.0 Safety Policy and Objectives Subpart B, Safety Policy, § 5.51(a)(1)

Element 1.1 Safety Policy § 5.21 Safety Policy

Element 1.2 Management Commitment and Safety 

Accountabilities § 5.23 Safety Accountability and Authority

Element 1.3 Key Safety Personnel § 5.25 Designation and Responsibilities of 

Required Safety Management Personnel

Element 1.4 Emergency Preparedness and 

Response

§ 5.27 Coordination of Emergency Response 

Planning

Element 1.5 SMS Documentation and Records Subpart F, SMS Documentation and 

Recordkeeping, §§ 5.95 and 5.97

Component 2.0 Safety Risk Management Subpart C, Safety Risk Management, § 5.51 

Applicability

Element 2.1 Hazard Identification and Analysis § 5.53 System Analysis and Hazard Identification

Process 2.1.1 System Description and Task 

Analysis § 5.53(a) and (b)

Process 2.1.2 Identify Hazards § 5.53(c)

Element 2.2 Risk Assessment and Control § 5.55(a) Safety Risk Assessment and Control

Process 2.2.1 Analyze Safety Risk § 5.55(a)

Process 2.2.2 Assess Safety Risk § 5.55(b)

Process 2.2.3 Control/Mitigate Safety Risk § 5.55(c) and (d)

Component 3.0 Safety Assurance Subpart D, Safety Assurance

Element 3.1 Safety Performance Monitoring and 

Measurement

§ 5.71 Safety Performance Monitoring and 

Measurement

Process 3.1.1 Continuous Monitoring § 5.71(a)(1) and (2)

Process 3.1.2 Internal Audits by Operational 

Departments § 5.71(a)(3)

Process 3.1.3 Internal Evaluation § 5.71(a)(4)

Process 3.1.4 External Auditing of the SMS § 5.71(a)(3)

Process 3.1.5 Investigation § 5.71(a)(5) and (6)
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Appendix B

B-2

AC 120-92A Appendix 1 (SMSPP) 14 CFR Part 5

Process 3.1.6 Employee Reporting and 

Feedback System § 5.71(a)(7)

Process 3.1.7 Analysis of Data § 5.71(b)

Process 3.1.8 System Assessment § 5.73(a) Safety Performance Assessment

Element 3.2 Management of Change § 5.73(a)(2)–(5) and (b)

Element 3.3 Continuous Improvement § 5.75 Continuous Improvement

Process 3.3.1 Preventive/Corrective Action § 5.75 Continuous Improvement

Process 3.3.2 Management Review § 5.73(a)

Component 4.0 Safety Promotion Subpart E, Safety Promotion

Element 4.1 Competencies and Training § 5.91 Competencies and Training

Process 4.1.1 Personnel Requirements 

(Competence) § 5.91 

Process 4.1.2 Training § 5.91 

Element 4.2 Communication and Awareness § 5.93 Safety Communication