SMS for Small UAS Cargo Operators — What You Need to Know (and Do) Now
Are you operating—or planning to operate—a Small UAS (sUAS) cargo or other commercial drone service under 14 CFR part 135?
If so, the FAA has made one thing clear:
“Part 135 certification is the only path for small drones to carry the property of another for compensation beyond visual line of sight.”
That means if you’re operating under—or pursuing—part 135 UAS approval, the FAA’s Safety Management System (SMS) rule (14 CFR part 5) applies to you. Whether you’re a new entrant or scaling up, now is the time to think beyond paperwork and start building an SMS that fits your operation.
In this SMS Quick Take, we break down what the SMS rule means for sUAS cargo operators, what the FAA expects, and how to get started—without stifling innovation or overwhelming your team.
Why This Matters
In March 2024, the FAA expanded the SMS rule to apply to more certificate holders—including part 135 UAS operators. If you're flying commercial drones under part 135 for cargo delivery, infrastructure inspections, or other beyond visual line of sight (BVLOS) services, you're expected to—
· ✅Submit an SMS Declaration of Compliance
· ✅Implement a functioning SMS in phases (typically over 36 months)
· ✅Continuously manage risk using the four components of SMS:
o Safety Policy
o Safety Risk Management
o Safety Assurance
o Safety Promotion.
Deadlines vary depending on when your operation became subject to the rule—but you should begin preparing now.
What Makes SMS for sUAS Different?
Cargo operators of sUAS face a unique mix of safety challenges:
Autonomous systems and remote operations
Software-driven aircraft and infrastructure
Risk to people and property on the ground—especially in congested areas
Lost link or communication issues over long distances
Rapid technological changes and evolving mission profiles
A traditional manned-aircraft-style SMS won’t fit. But the principles still apply—and the FAA allows you to scale SMS to match your operation.
5 Things to Focus on Now
1. Start with a Scaled-Down SMS Framework
Begin with the essentials:
✅ A clear, simple safety policy
✅ A method to identify and assess hazards
✅ A process to capture and apply lessons learned
✅ A feedback loop that drives continuous improvement
Even small, low-volume operations need structure to manage risk proactively.
2. Make Technology Work for You
You likely already use flight logging tools, automated diagnostics, and cloud-based systems. Leverage these systems to—
Track safety indicators
Identify trends
Streamline reporting and analysis
No need to reinvent the wheel—just connect the dots.
3. Focus on Human Performance
Even highly automated operations rely on people—often small teams wearing many hats. Ensure your SMS accounts for—
Fatigue and workload in lean teams
Training gaps during scale-up and maintaining currency
Communication challenges in hybrid or remote environments
4. Encourage (and Reward) Hazard Reporting
The FAA doesn’t expect zero incidents; they expect visible, active safety management. Make it easy to report concerns (ideally from mobile devices or flight consoles), and—
Respond quickly
Provide feedback
Recognize and reward participation
5. Get Ahead of FAA Requirements
Even if you haven’t filed a Declaration of Compliance yet, you can—
Draft your SMS Implementation Plan
Identify where your current safety practices are already aligned with 14 CFR part 5
Assign an Account Executive and define key roles
Early action positions you for success—and helps you avoid future delays or enforcement issues.
PAI Perspective: Early Action Is Smart Business
A lean, scalable SMS isn’t just about checking the FAA’s boxes—it helps you operate more reliably, attract customers, and avoid preventable disruptions. Early adopters will likely be better positioned as sUAS operations grow more complex and regulated.
Resources
📝 14 CFR Part 5 — FAA SMS Rule
📝 AC 120-92D — SMS Guidance for All Operators
Planning a Part 135 UAS Cargo Operation?
PAI Consulting can help you design an SMS that fits your tech, your scale, and your mission. Contact us here.
Need help with SMS adoption?
PAI Consulting can help you take your SMS to the next level.
Contact us today for a consultation and let our expert Senior Aviation Analysts help your aviation SMS program succeed.
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