SMS: Now and Into the Future
In 2024, the U.S. saw 45,000 flights per day. Imagine when millions of drones join that airspace—will today’s SMS still hold? Not long ago, Safety Management Systems (SMS) were seen as something “only big airlines have.” Today, SMS is no longer optional for U.S. commercial operators—14 CFR part 5 mandates it for parts 121, 135, 91.147, and certain part 21 certificate holders. Across the aviation community, SMS continues to evolve in response to new entrants, new technologies, and changing approaches to risk management.
A recent Flight Safety Foundation (FSF) webinar, Safety at Scale: How New Entrants Are Finding Success with SMS, featured leaders from the drone delivery industry, Unmanned Safety Institute (USI), UPS Flight Forward, Wing Aviation LLC (Wing), and Graham Aerospace International. Their message was clear: SMS remains the foundation of aviation safety, but its application must adapt to a world of drones, advanced air mobility (AAM), and highly automated aviation systems (HAAS).
FSF’s accompanying paper, New Words for a New Era in Aviation, challenges the aviation community to rethink the vocabulary we use to describe safety in an increasingly automated future.
SMS Today: Lessons From New Entrants
Even though SMS is codified in regulation, its effectiveness depends on adaptability. The FSF webinar highlighted several key themes:
1. SMS Must Be Tailored, Not Just Transplanted
The traditional SMS framework—the four components and their elements—remains solid, but applying it to drones and AAM means recognizing new risks and data sources. For example:
Real-time monitoring of aircraft health and fleet operations is more feasible (and expected) in unmanned aircraft systems (UAS) than in traditional flight operations.
Safety performance indicators (SPIs) for drones may focus on battery health, data‑link reliability, or geofence violations rather than conventional metrics.
The takeaway: SMS provides the structure, but operators must tailor it to their technologies and operational context.
2. Collaboration Is Essential
As one panelist noted, “Safety should not be treated as a proprietary advantage.” Success in UAS and AAM depends on collaboration among service providers, original equipment manufacturers (OEM), and regulators—domestically and internationally. Because drones may operate across borders, safety knowledge must do the same. Shared data, practices, and lessons learned are critical to building a resilient and scalable safety framework.
3. Culture and Communication Matter
SMS fails when treated as a compliance exercise. Leaders must translate SMS concepts into language that resonates with engineers, software developers, and frontline operators. Safety promotion is more than training; it must be embedded into daily workflows and understood across all stakeholder roles.
4. Cybersecurity Is a Safety Issue
Automation increases exposure to cyber risks—particularly for smaller operators using off‑the‑shelf equipment. SMS must integrate cybersecurity as a core component.
SMS Tomorrow: Automation at Scale
FSF’s paper makes a provocative argument: the future of aviation won’t just involve more automation—it will be defined by it.
Today’s model is still largely pilot-centric, even remotely piloted aircraft systems (RPAS). But what happens when fleets of thousands, or millions, of flights per day must be managed, from package delivery drones to passenger-carrying AAM?
The paper introduces two key ideas:
Highly Automated Aviation Systems (HAAS) – Integrated systems where automation manages most functions, and humans supervise the system rather than individual aircraft.
System Management Organization (SMO) – The teams and structures responsible for managing HAAS safely, with clearly defined roles, authority, and accountability.
This shift parallels transformations in other industries. Just as information technology (IT) roles evolved with cloud computing, aviation will require new human roles as automation scales. As we look to the future, pilots won’t disappear, but their responsibilities will look quite different.
Implications for SMS
Several important shifts are already emerging:
From Aircraft-Level to System-Level Risk Management
Traditional SMS assumes an individual or crew is responsible for each flight. In a HAAS model, SMS must address how organizations manage risks across entire fleets, regions, and time zones.
From “Human-in-the-Loop” to “Human Configuring the Loop”
Instead of reacting in real time, humans may set parameters, configure automation services, and monitor higher-level system performance. SMS documentation must reflect this shift in accountability.
New SPIs and Hazard Categories
Monitoring fleet health, automation failovers (backup system activation during failure), or systemwide anomalies may become more important than tracking isolated incidents. Hazard identification must address automation‑related risks, including software faults and cascading failures that could overwhelm operational capacity, such as failures affecting many aircraft at a time.
Organizational Accountability
Today’s SMS requires a designated accountable executive, tomorrow’s SMS will require defined leadership for SMOs overseeing highly automated fleets. Certification may evolve to recognize organizations—rather than individuals—as the entities responsible for managing safety across complex, automated systems.
Scaling Safety Promotion
When fleets are operated by software teams and network engineers, safety promotion must reach beyond pilots, mechanics, flight attendants, dispatchers, and other traditional operational roles. Training, safety reporting, and just culture principles must extend to new disciplines.
The Road Ahead
For operators, regulators, and safety professionals, this raises some critical questions:
How do we ensure today’s SMS structures are flexible enough to accommodate tomorrow’s roles?
Are we investing adequately in data systems and cybersecurity as core elements of SMS?
How can industry and regulators align on common terminology, standards, and expectations for HAAS and SMOs?
What lessons can we borrow from other industries with scaled automation?
The answers will emerge through the same process that has guided SMS from the start: structured risk management, continuous improvement, and collaboration.
Why It Matters Now
Even if your operation doesn’t involve drones or AAM, these developments matter. SMS evolution in new sectors often sets the stage for broader regulatory and cultural shifts. Just as voluntary SMS in part 121 eventually became mandatory, today’s UAS practices may shape tomorrow’s expectations across aviation.
The timeline for this evolution may be shorter than we think. The U.S. sees 45,000 flights per day today. FSF notes that package delivery alone accounts for 58 million daily deliveries—if even a fraction moves to the air, it will be a scale of operations beyond any precedent. SMS must be ready to grow with it.
Final Thought
SMS is no longer about regulatory compliance. It is about preparing for a future where aviation safety depends on human expertise and automated systems, working together at scale.
The principles remain: identify hazards, manage risk, assure performance, and promote safety. However, the context is changing—from cockpits to code, from single aircraft to integrated fleets, from pilots to organizations.
At PAI Consulting, we believe the future of SMS will look largely different from its past—but its purpose will remain the same: helping the aviation community make smarter, safer decisions in an ever-changing world. Check out our other posts about SMS.
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