Turn Your Safety Policy Into a Power Tool for Everyday Decision Making
If you’re a small aviation operator—or even a single pilot wearing every hat from flight planning to maintenance—you already know safety isn’t just a regulation, it’s personal. The right Safety Policy can make the difference between checking boxes and building a safety culture that truly protects you, your passengers, and your reputation. The good news? Setting one up doesn’t have to be complicated or expensive. Here’s how to create a clear, compliant, and meaningful Safety Policy that fits your operation—and meets 14 CFR Part 5 requirements.
Under 14 CFR § 5.21, each certificate holder must create a safety policy that defines management’s commitment to safety, outlines accountability for safety management, and promotes continual improvement. Advisory Circular (AC) 120–92D § 3.3 outlines seven key elements that must be addressed: safety objectives, management commitment, resources, safety reporting, disciplinary standards, emergency response planning, and a code of ethics. The policy must be signed by the accountable executive and reviewed periodically to ensure it remains relevant as the organization evolves.
This article explains what the regulation requires and what makes a safety policy meaningful and shares practical examples to help you craft one that fits your organization.
1️⃣ The Regulatory Foundation
14 CFR § 5.21(a) requires that a safety policy include—
A clear statement of the organization’s safety objectives and commitment to safety,
A definition of management and employee responsibilities,
Provisions for continual improvement, and
A means for employees to communicate safety issues without fear of reprisal.
AC 120–92D § 3.3 reinforces that the safety policy should be signed by the accountable executive (typically the CEO or Director of Operations) and periodically reviewed to ensure it remains relevant as the organization evolves.
One of the seven required elements is a code of ethics declaring safety as the organization’s highest priority. It applies to all employees, including management personnel and officers. The code of ethics complements the safety policy by defining expected standards of professional conduct and reinforcing that ethical behavior and safety performance are inseparable.
2️⃣ What Makes a Good Safety Policy
An effective safety policy isn’t long or complicated—it’s credible, authentic, and actionable. The best ones—
Reflect the organization’s voice and scale. A small charter operator’s policy shouldn’t read like one from a major airline.
Tie directly to the SMS framework. Each element should connect to the four SMS components: safety policy, Safety Risk Management (SRM), safety assurance, and safety promotion.
Demonstrate leadership engagement. The accountable executive’s signature shows top‑level commitment and accountability for safety performance.
3️⃣ Example Excerpt: Policy Commitment
Here’s an example of how a safety policy opening statement might read:
“Our organization is committed to the highest standards of safety in all flight and ground operations. We will actively manage safety risks through a structured Safety Management System (SMS) in compliance with 14 CFR Part 5. All employees are encouraged to report safety hazards and participate in our safety programs without fear of reprisal.”
This brief statement covers the essentials: commitment, compliance, and a non‑punitive reporting expectation.
4️⃣ Example Excerpt: Roles and Responsibilities
Every safety policy should clarify who’s responsible for what. A simple paragraph is often sufficient.
“The accountable executive is responsible for ensuring adequate resources are available to support our SMS and that safety performance objectives are met. All managers and employees share responsibility for identifying hazards, reporting safety concerns, and following established risk controls.”
This fulfills the regulatory requirement for defining responsibilities while reinforcing a culture of shared accountability.
5️⃣ Example Excerpt – Continuous Improvement
The SMS is a living system, not a binder on a shelf. The safety policy should make that clear.
“We are committed to continuous improvement in safety performance through proactive hazard identification, risk management, and the analysis of safety data. Regular reviews of our policies, procedures, and safety performance indicators will ensure lessons learned are applied across the organization.”
This connects your policy to SMS’s safety assurance and promotion components—a vital signal that safety is a continual process, not a one‑time declaration.
AC 120–92D Appendix C encourages organizations to tailor their safety policy to their unique operations, rather than to adopt a generic template. The AC also recommends embedding cross‑references (“pointers”) to related manuals or procedures—such as the General Operations Manual (GOM) or Emergency Response Plan (ERP)—so employees can easily locate supporting information without duplicating content.
6️⃣ Defining Safety Objectives
Regulations require safety objectives to be documented and measurable. Many organizations include them as an appendix or table following the main policy statement. For example—
| Objective | Measure | Target |
|---|---|---|
| Reduce unstable approaches | Percentage of unstable approaches (from flight data monitoring) | < 2% per quarter |
| Increase voluntary hazard reports | Number of reports received in the safety reporting system | +15% year over year |
| Complete all safety audits on time | Percent of scheduled audits completed | 100% compliance |
The key is to select specific, measurable, achievable, relevant, and time-bound (SMART) objectives—and to review them regularly with leadership.
7️⃣ Communicating the Policy
According to AC 120–92D, the safety policy must be signed by the accountable executive, documented, and communicated throughout the organization so it is understood by all personnel. The AC further notes organizations should establish documented processes describing how the policy is communicated—for example, through postings, training programs, and electronic documentation systems—and reviewed periodically by leadership to ensure its continued relevance.
That means—
Posting it in common work areas,
Including it in initial and recurrent SMS training,
Reinforcing it in safety briefings and newsletters, and
Making the signed version readily accessible in your SMS manual or safety portal.
A safety policy that is signed once and forgotten is just a document. If it’s discussed, displayed, and referenced in daily operations, it becomes the foundation of your safety culture.
8️⃣ Keeping It Current
A safety policy isn’t static. Review it annually (or whenever significant organizational or regulatory changes occur), and update it if—
Leadership changes,
New operational areas or aircraft types are added, or
Internal evaluations identify gaps in safety communication or accountability.
Keep previous versions on file: they show auditors your SMS is maturing over time.
AC 120–92D also links the safety policy to an organization’s code of ethics, which specifies that safety is the highest priority for all personnel, including management. Incorporating a brief code of ethics statement—either within the safety policy or as a companion document—reinforces that safety is not only a regulatory requirement but also a shared ethical responsibility across the organization.
✈️ Example Excerpt – Code of Ethics
“Code of Ethics Statement “We will conduct all operations with honesty, professionalism, and respect for others. Safety is our highest priority and will never be compromised for operational or commercial gain.”
This concise statement meets the intent of 14 CFR § 5.21(a)(7) and AC 120–92D Appendix C, making it clear ethical conduct and safety performance are inseparable. It’s short enough to be embedded directly within the safety policy or displayed as a companion statement in training and communications materials.
✅ Final Thoughts
A Safety Policy isn’t just paperwork—it’s your organization’s heartbeat. Whether you’re flying solo, managing a small fleet, or leading a larger certificated operation, your policy defines how seriously you take safety and sets the standard for everyone who flies or works with you.
If you’re ready to strengthen your Safety Management System—or just want a second set of eyes on your existing policy—our team can help you develop practical solutions that fit your size, mission, and goals.
✈️ Need help crafting or reviewing your Safety Policy? Contact PAI Consulting for tailored SMS support.
📘 Continue learning: Explore our other SMS articles on Single Pilot SMS Concerns, SMS Services from PAI Consulting, and SMS for Small UAS Cargo Operators — What You Need to Know (and Do) Now to strengthen every pillar of your system.
Do you have questions or concerns about SMS? Share them with us!
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