Safety Management Systems for Aviation Service Providers
Appendix G, Small Operator Implementation
    Section and Topic
    Exemptions from SMS Requirements for Single Pilot 
Operators
    AC 120-92D Guidance
  


    Safety Policy 
  

    5.21(a)(4), 
Safety policy.
    (a) The certificate holder must have a safety policy that 
includes at least the following:

(4) A safety reporting policy that defines requirements for 
employee reporting of safety hazards or issues.
    Note: A single-individual organization is not required 
to have a process to communicate safety information 
throughout the aviation organization.
  

    5.21(a)(5), 
Safety policy.
    (a) The certificate holder must have a safety policy that 
includes at least the following:

(5) A policy that defines unacceptable behavior and
conditions for disciplinary action.
  

    5.21(c), 
Safety policy.
    (c) The safety policy must be documented and 
communicated throughout the person’s organization.
  

    5.23(a)(2), 
Safety accountability and 
authority.
    (a) Any person required to have an SMS under this part
must define in its safety policy the accountability for 
safety of the following individuals:

(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.
    In single-individual organizations, this structure will
be very simple and consist of the sole individual being 
the accountable executive and assuming the various 
roles and responsibilities, which would normally be 
assigned to other members of management. The 
single individual would also be responsible for 
accepting all risks associated with the aviation
organization’s products or services.

As their organizational duties change, which could
happen many times during the day, the single 
individual could be said to be changing hats as their 
role changes as they manage the activities required in
§ 5.23.

Note: §§ 5.23(a)(2), (a)(3), and (b) not apply to those 
organizations with a single pilot who is the sole 
individual performing all necessary functions in the
conduct and execution related to, or in direct support 
of, the safe operation of the aircraft:
  

    5.23(a)(3), 
Safety accountability and 
authority.
    (a) Any person required to have an SMS under this part
must define in its safety policy the accountability for 
safety of the following individuals:

(3) Employees relative to the person’s safety
performance.
  

    5.23(b), 
Safety accountability and 
authority.
    (b) The person must identify the levels of management 
with the authority to make decisions regarding safety risk 
acceptance.
  

    5.25(b)(3), 
Designation and 
responsibilities of required 
safety management 
personnel.
    (b) Responsibilities of the accountable executive. The 
accountable executive must accomplish the following:

(3) Communicate the safety policy throughout the
person’s organization.
    In a single-individual operation, these duties would be
fulfilled by the accountable executive.

Note: 5.25(b)(3) does not apply to those 
organizations with a single pilot who is the sole 
individual performing all necessary functions in the 
conduct and execution related to, or in direct support 
of, the safe operation of the aircraft.
  

    5.25(c), Designation and 
responsibilities of required 
safety management 
personnel.
    (c) Designation of management personnel. The 
accountable executive must designate sufficient 
management personnel who, on behalf of the 
accountable executive, are responsible for the following:

(1) Coordinate implementation, maintenance, and
integration of the SMS throughout the person’s 
organization,

(2) Facilitate hazard identification and safety risk
analysis,

(3) Monitor the effectiveness of safety risk controls,

(4) Ensure safety promotion throughout the person’s
organization as required in subpart E of this part,

(5) Regularly report to the accountable executive on
the performance of the SMS and on any need for 
improvement.
    In a single-pilot organization, the accountable
executive would perform these designated duties as 
part of their duties under §5.25. Effective 
communication of safety information is still 
important, even in a single-pilot or single-individual 
organization. Communication would be focused 
outside of the organization (i.e., regular 
communication with aviation system stakeholders, 
industry associations, clients, the FAA, and other
organizations).

Note: § 5.25(c) does not apply to those organizations 
with a single pilot who is the sole individual 
performing all necessary functions in the conduct and 
execution related to, or in direct support of, the safe 
operation of the aircraft.
  

    5.27(a), 
Coordination of emergency 
response planning.
    Where emergency response procedures are necessary, 
any person required to have an SMS under this part must 
develop, and the accountable executive must approve as 
part of the safety policy, an emergency response
response plan that addresses at least the following:

(a) Delegation of emergency authority throughout the
person’s organization.
    Effective communication of safety information is
important, even in a single-pilot organization. In an 
organization with a single pilot or single individual, the 
communication focus may be outside the 
organization (e.g., regular communication with 
aviation system stakeholders, industry associations, 
clients, the FAA, and other organizations). Interfacing
with maintenance, fixed-based operators, and flight 
followers (if one is used) all require communication, 
so they are aware of the aviation organization’s 
activities. This will aid in scheduling support activities 
as well as having someone keep an eye out in case 
plans do not go as predicted.,

In a single-pilot or single-individual organization, this 
could be met by simply filing flight plans with air 
traffic control (ATC) or leaving an envelope with 
emergency contact information at the local Fixed-
Base Operator (FBO) if the aircraft does not return on 
time.

Note: §§ 5.27(a) and (b) do not apply to those 
organizations with a single pilot who is the sole 
individual performing all necessary functions in the 
conduct and execution related to, or in direct support 
of, the safe operation of the aircraft
  

    5.27(b), 
Coordination of emergency 
response planning.
    Where emergency response procedures are necessary, 
any person required to have an SMS under this part must 
develop, and the accountable executive must approve as 
part of the safety policy, an emergency response plan that 
addresses at least the following:

(b) Assignment of employee responsibilities during the
emergency.
  

    Subpart C – Safety Risk Management 
  

    Safety Assurance 
  

    5.71(a)(7), 
Safety performance 
monitoring and 
measurement.
    (a) Any person required to have an SMS under this part
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, without concern of reprisal for
reporting.
    In small organizations, data collection for the
reporting system can take many forms, from a simple 
suggestion box to organizational websites or intranets 
or a dedicated email address. Data management can 
be accomplished with a common desktop 
spreadsheet, database software, or specialized 
software, such as WBAT.

Note: § 5.71(a)(7) does not apply to those 
organizations with a single pilot who is the sole 
individual performing all necessary functions in the 
conduct and execution related to, or in direct support 
of, the safe operation of the aircraft.
  

    Subpart E – Safety Promotion 
  

    § 5.93, 
Safety communication.
    In smaller or lower complexity aviation organizations, 
communicating safety considerations to employees may 
be simple and direct. For example, the accountable 
executive could conduct regular all-hands/employee 
meetings, such as “hangar talk sessions.” Additionally, 
communication could include regular and periodic 
briefings to the employees, posting the status of safety 
issues on bulletin boards, emails to employees, and 
face to face meetings with division management teams. 
Aviation organizations with only a few employees could
utilize a required reading list consisting of material from 
industry or other sources. The selected material would be 
applicable to the operations conducted. Documentation 
of what was reviewed would meet the requirements of 
§ 5.97(d).
    Small organizations should consider the methods 
they will use when sharing information with other
aviation service providers they interface with. 
Methods used can be as simple or as complex as the 
organization chooses, but they should be consistent.
Maintaining a “Journey Log” or “Unusual 
Occurrences” log may be useful for regular review 
and reinforcement of safety concerns identified when 
performing the aviation service. This will facilitate 
entering the occurrences into the safety assurance 
component (§ 5.71) for tracking and resolution.

Note: Section § 5.93. does not apply to those 
organizations with a single pilot who is the sole 
individual performing all necessary functions in the 
conduct and execution related to, or in direct support 
of, the safe operation of the aircraft:
  

    Subpart F – SMS Documentation and Recordkeeping 
  

    5.97(d), 
SMS records.
    (d) Retain records of all communications provided under
§ 5.93 or § 5.57 for a minimum of 24 consecutive calendar 
months.

The process developed for record retention should be
appropriate for the aviation organization. As an example, 
digital photographs of safety-related posters or signs in a 
maintenance hangar could be retained as a record of the 
communication. Read and initial documents would also 
provide a record. Hangar talks and flight crew alerts are 
also types of communications that would be retained. 
These communications can be retained electronically or
in paper format. The method utilized should be 
appropriate to the size and complexity of the aviation 
organization.
    In smaller or lower complexity aviation organizations,
the owner/manager (accountable executive) or 
designee may be responsible for maintaining 
auditable records. Documentation may consist of 
handwritten records, spreadsheets, phone and email 
logs, and completed forms that are kept
in file cabinets or binders.

Note: § 5.97(d) does not apply to those organizations 
with a single pilot who is the sole individual 
performing all necessary functions in the conduct and 
execution related to, or in direct support of, the safe 
operation of the aircraft:
  