SMS Quick Takes: The Accountable Executive Is More Than Simply a Signature
Let’s define that title, in case you’ve never heard it before: the Accountable Executive (AE) is the single individual in your organization who owns safety performance at the highest level, someone with the authority and resources to act when the SMS identifies a problem. For some operators, that role is well understood and actively fulfilled, but for others, it raises a fair question: what does the AE do beyond putting their name on the safety policy? That’s what Title 14, Code of Federal Regulations (14 CFR) part 5 § 5.25 and Advisory Circular (AC) 120–92D are designed to answer: have you identified the right person, and are they accomplishing something far more substantive than a signature?
What Is an Accountable Executive and Why Does Part 5 Require One?
Part 5 requires every SMS‑obligated operator to designate an AE. The AE is not a committee, a title, or a signature on a form—regardless of your organization’s size, someone within must be accountable for safety performance. Section 5.25 defines who that person is and what they are required to do.
Identifying the Right Person (§ 5.25(a))
Section 5.25(a) establishes four criteria for identifying the AE, who must—
Be the final authority over operations conducted under the organization’s certificate(s) or Letter(s) of Authorization,
Control the financial resources required for those operations,
Control the human resources required for those operations, and
Retain ultimate responsibility for the safety performance of those operations.
AC 120–92D § 3.3.3.3.1.2 makes a critical point that is easy to overlook: whether the individual actually holds decision‑making authority and can commit the resources necessary for safe operations.
If you’re a small 14 CFR part 135 operator, not to worry: the organizational job title is not important when making this determination. The AE is not necessarily the person at the top of the organizational chart—it’s the person who can say yes or no to processes such as adding a new route, approving mitigations, or committing funds to training or safety‑enhancing tools and equipment. In some small operations, that’s the owner‑operator or director of operations; in others, it may be a managing partner who is not directly involved in day‑to‑day flight operations but is willing to commit the resources necessary to prioritize safety. If you are working through the designation process for the first time, AC 120–92D Appendix E includes flowcharts to help.
The key is honest self‑assessment, not defaulting to an org chart.
That said, the AE does not have to do it all alone: § 5.25(c) encourages the AE to designate management personnel to support essential SMS functions, and AC 120–92D § 3.3.3.3.2.4 describes the support they should provide, such as performing analysis, assisting operational managers, and serving as a safety advisor. These individuals should have enough independence to not only report directly to the AE but also recommend improvements. What cannot be delegated, however, is ultimate accountability—under § 5.25(a)(4) that stays with the AE, regardless of how SMS responsibilities are distributed. One practical way to put that in writing: AC 120–92D § 3.3.3.3.2.1 suggests documenting the AE's own duties in a position description; for smaller operators, simply pointing to § 5.25(b) is sufficient.
What the AE Is Actually Required to Do (§ 5.25(b))
Once identified, the AE carries five specific, ongoing responsibilities under § 5.25(b):
Ensure the SMS is properly implemented and performing across all pertinent areas.
Develop and sign the safety policy.
Communicate the safety policy throughout the organization.
Regularly review the safety policy to ensure it remains relevant and appropriate.
Regularly review safety performance and direct actions necessary to address substandard performance, in accordance with § 5.75.
All five responsibilities carry ongoing obligations; even developing and signing the safety policy is not a once‑and‑done task. The commitment begins at signing, but it lives in everything that follows.
What does “regularly” mean in items 4 and 5? The AC addresses each separately but arrives at the same conclusion:
Safety policy review (item 4): AC 120–92D § 3.3.1.3.12 does not define a specific interval, but the operator is expected to determine and document one appropriate for the operation’s size and complexity. The AE must review the safety policy and objectives to confirm they remain relevant under §§ 5.21(d) and 5.25(b)(4).
Safety performance review (item 5): AC 120–92D § 3.3.3.3.2.3 applies the same principle: no defined interval, but reviews should occur frequently enough for issues to be identified and corrected in a timely manner, scaled to the organization’s size, scope, and complexity.
In both cases, the organization’s records should show evidence reviews were completed. In practice, an undocumented review is an undone review. The AC does not prescribe a specific format for that evidence — only that a dated record exists in the organization’s SMS documentation showing the review took place.
The Small Operator Reality
AC 120–92D §§ 3.3.3.4.1–3.3.3.4.2 acknowledges directly that in smaller organizations, the AE may:
Directly supervise operational processes,
Serve in multiple positions within the organization, and
Add safety‑manager duties to an existing role, such as operations manager.
This is the AC’s explicit recognition of how small operators are structured—what is expected is that whoever holds the AE role understands its scope and actively fulfills it, regardless of the other hats they wear.
For a small part 135 operator, that does not require a dedicated safety department or a wall of dashboards. It requires an AE who is genuinely engaged: attending safety reviews, asking questions, and ensuring the people responsible for day‑to‑day SMS functions have the support and resources they need to do their jobs.
One note for the smallest operations: AC 120–92D § 3.3.3.5 specifically excepts single‑pilot operations from § 5.25(b)(3), as there is no organization to communicate with; all other AE responsibilities remain in effect.
Bringing it Back to Ridgeline Air
In our previous posts, we showed how the Director of Operations at Ridgeline Air, our fictional organization, accepted residual risk on a new route after the Safety Risk Management (SRM) team completed its hazard analysis and developed risk controls. That acceptance was not incidental—it was a direct exercise of AE‑level authority under § 5.23(b), and by documenting it, Ridgeline Air created a record that the right person made the right decision.
Now imagine that 3 months later, trend monitoring flags an uptick in flightcrew requests for weather minima exceptions at the destination. Under § 5.25(b)(5), the Director of Operations, as AE, is obligated to review that data and direct corrective action under § 5.75, which could include team review, tightening go/no‑go criteria, or revisiting the route qualification program.
This is what active AE engagement looks like: it is not a quarterly glance at a report, but a direct, documented response to whatever the safety data uncovers. In this case, the data revealed a risk control may not be performing as intended, but it could just as easily have been a new hazard, a change in the operating environment, or a trend that needs monitoring before it becomes an incident or an accident.
The AE as SMS Champion
AC 120–92D § 3.3.3.3.2 describes the AE as responsible for the proper functioning of the SMS: being actively involved in safety assurance, not just safety policy. It means knowing where the organization’s safety data lives, understanding what it is saying, and being willing to act when it signals a problem.
The goal is for the AE to be engaged enough to know where to look, informed enough to recognize a trend, and empowered enough to act on it. Active, informed, documented oversight is where the commitment lives.
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