Part 135 SMS Readiness: Can You Demonstrate That It Works?

The best test is one real event

A practical way to evaluate SMS implementation is to select one actual operational event and trace it from beginning to end:

Report → Hazard → Risk Analysis → Control → Responsible Manager → Implementation → Assurance → Closure

For example, an operator might select a recurring issue involving incomplete information being passed to a flight crew, a training-record discrepancy, a vendor problem, or an operational-control concern.

The SMS record should show:

• Report: How was the issue identified and reported?
• Hazard: What unsafe condition could result?
• Risk analysis: How likely was the hazard to occur, and what could happen if it did?
• Control: What action was selected to reduce the risk?
• Responsible manager: Who had authority to own the action?
• Implementation: How was the control put into daily practice?
• Assurance: How did the operator verify that the control was being followed and was effective?
• Closure: Who determined that the issue had been adequately addressed?

If the operator can show every part of that chain, the SMS is producing evidence of actual use. If it can show a report but not the risk analysis, or a corrective action but no effectiveness check, the process is incomplete.

Part 5 requires evidence, not just a policy

Part 5 requires an SMS that is appropriate to the size, scope, and complexity of the organization. It also requires the operator to make available, upon request, the information and data needed to demonstrate that the SMS meets the rule. Review 14 CFR Part 5 ↗

For a large Part 135 operator, that evidence may involve multiple reporting channels, departments, databases, formal assurance programs, trend analysis, and management reviews. A smaller operator may use a simpler system with fewer layers and more direct ownership.

The level of complexity may be different, but the expectation is the same: the system should be used, understood, documented, and checked for effectiveness.

Where voluntary self-disclosure fits

The FAA’s Notice 8900.774 adds another important consideration for Part 135 managers. The notice provides interim guidance for certain Part 121 and Part 135 regulated entities that submit a Voluntary Self-Disclosure through their Part 5 SMS. Under the process described in the notice, the disclosure is submitted through the SAS External Portal, managed within the operator’s SMS, and monitored and tracked by the FAA through SAS. Read FAA Notice 8900.774 ↗

This does not mean every safety report is a voluntary self-disclosure. The processes serve different purposes:

• A safety report identifies a hazard, unsafe condition, occurrence, or concern.
• A corrective action addresses the cause or risk associated with the issue.
• A Voluntary Self-Disclosure notifies the FAA of an apparent regulatory violation under the applicable voluntary disclosure process.

In some cases, one event may involve all three. An employee may report a recordkeeping problem through the SMS. The operator may identify the underlying hazard, conduct a risk assessment, establish corrective actions, and determine that the issue also involves an apparent regulatory violation that should be considered for voluntary disclosure.

That decision should not be improvised after the event occurs. Notice 8900.774 describes prompt notification, immediate action to stop the noncompliance, identification of root causes, a comprehensive fix, and a follow-up self-audit. It generally calls for notification immediately, and no later than 24 hours after discovery, before the FAA learns of the apparent violation by another means, subject to the notice’s acceptance criteria.

The notice is interim guidance and specifically addresses Part 121 and Part 135 entities. Part 91.147 LOA holders should confirm their applicable reporting and SMS processes with the FAA.

Questions managers should settle now

A working SMS should make the answers to these questions clear:

• Who evaluates an initial safety report?
• Who decides whether an apparent regulatory violation exists?
• Who has authority to submit a voluntary self-disclosure?
• How are safety reports, corrective actions, and VSDs linked?
• Who owns the corrective action and its due dates?
• What evidence shows that the action was implemented?
• Who performs the effectiveness review?
• Who can close the issue, and what does closure mean?

These are management-system questions, not just paperwork questions. If the answers depend on one person’s memory, the process is vulnerable when that person is unavailable or the operation becomes more complex.

A practical readiness exercise

Choose one real event from the past six to twelve months. Retrieve the original report, risk assessment, action plan, training or communication records, assurance evidence, and closure documentation.

Then ask whether someone unfamiliar with the event could follow the story without needing a private explanation. If not, identify where the chain breaks and fix that part of the system first.

This exercise often reveals whether the operator has a working SMS or only a manual that describes one.

How Easy Star Aviation Intelligence can help

Easy Star Aviation Intelligence helps Part 135 operators and § 91.147 LOA holders move from having an SMS manual to operating an SMS that can be demonstrated.

Support may include:

• Reviewing an existing SMS manual against the actual operation.
• Conducting a readiness review using a real operational event.
• Mapping the process from report through closure.
• Identifying gaps in hazard identification, risk analysis, corrective action, and assurance.
• Clarifying management responsibilities and decision authority.
• Reviewing how safety reports, compliance issues, corrective actions, and voluntary disclosures interact.
• Developing practical forms, tracking tools, and implementation procedures.
• Scaling the SMS to the size, scope, and complexity of the operation.
• Preparing management and employees to explain how the SMS works.
• Conducting a mock FAA or POI readiness review focused on the evidence an operator may be asked to produce.

The objective is straightforward: when the FAA asks for an example, your team should be able to select a real event, explain what happened, show what the organization did, and demonstrate how management confirmed that the risk was controlled.

Start with one real example

An SMS that works does not have to be complicated. It does have to be used, understood, documented, and checked for effectiveness.

If your operation has a manual but has not tested the process with a real event, now is the right time to begin. Easy Star Aviation Intelligence can help you identify where the process is strong, where it breaks down, and what needs to be done before the May 28, 2027 deadline.

Move from “we have an SMS document” to “we can show how our SMS works.”