A Ridgeline Air followup
Through Safety Risk Management (SRM), Safety Assurance, and, most recently, Safety Promotion, we’ve followed our fictional charter, Ridgeline Air. All the processes we discussed in those posts depend on something we have only brushed against so far: the safety policy required by Title 14, Code of Federal Regulations (14 CFR) part 5, Subpart B. In Accountable Executive: More Than a Signature, we covered who signs it. This post comprises what the policy contains, and why two of its required pieces—the reporting policy and the policy on unacceptable behavior—shape whether an SMS actually hears from its people.
What the Policy Must Contain
Section 5.21(a) lists what a safety policy must include, at a minimum.
Safety objectives and the commitment to fulfill them (under (a)(1) and (2)).
A clear statement about providing the resources the SMS needs (under (a)(3)).
A safety‑reporting policy that defines requirements for employee reporting of safety hazards or issues (under (a)(4)).
A policy that defines unacceptable behavior and conditions for disciplinary action (under (a)(5)).
An emergency response plan for the safe transition from normal to emergency operations (under (a)(6) and § 5.27).
A code of ethics for all employees, management included, making clear safety is the highest priority (under (a)(7)).
The accountable executive signs the policy under § 5.21(b). Next, Paragraph (c) requires it to be documented and communicated throughout the organization, then Paragraph (d) requires the accountable executive to review it regularly. Federal Aviation Administration (FAA) Advisory Circular (AC) 120–92D describes one common approach: a one‑to‑two‑page safety policy and code of ethics statement, backed by more detailed documents (Paragraph 3.3.1.3). For a small operator, a single, signed page posted in work areas can do the job (Paragraph 3.3.1.6.1).
How Ridgeline’s Concern Reached the Table
Recall the hazard‑identification session in our SRM case study, where the safety manager worked through the system description with dispatch, the chief pilot, and a line crewmember. One hazard our 14 CFR part 135 operator discovered was flightcrew unfamiliarity with the new route and its non‑towered traffic environment. This began with that line crewmember, a captain who once diverted into a field much like the new airstrip that was built and remembered how little there was to go on.
That captain was willing to put forth his concerns because Ridgeline’s safety policy had already answered the two questions every employee asks before speaking up: what happens to my report, and what happens to me?
Under § 5.21(a)(4), Ridgeline’s reporting policy spells out what to report—hazards, issues, concerns, occurrences, and ideas for fixing them—and how. The how is the confidential employee reporting system required by § 5.71(a)(7), which, since the 2024 final rule, states employees must be able to report “without concern of reprisal for reporting.”
In our scenario, Ridgeline’s pilots are covered by an Aviation Safety Action Program (ASAP) under a memorandum of understanding with the FAA. The FAA’s preamble to the final rule explains an ASAP satisfies the confidential reporting requirement for the employee groups it covers; for groups it does not cover, the organization must have an alternative means of compliance (89 Fed. Reg. 33089). Ridgeline’s agreement covers only its pilots, so dispatchers and ground crew get a simple online form that goes straight to the safety manager. (AC 120–92D gives the same pairing as an example (para. 3.5.7.3.1).)
The form asks for a name and contact method, visible only to the safety manager. That is deliberate. Anonymous reports are allowed, but both the preamble and the AC point out the cost: if nobody can reach the reporter, nobody can ask a follow‑up question (Paragraph 3.5.7.3.2).
The Other Half: Unacceptable Behavior
Reporting without reprisal does not mean a lack of consequences, and part 5 does not ask for that—§ 5.21(a)(5) requires a policy defining unacceptable behavior and conditions for disciplinary action. The FAA’s preamble explains the 2024 reprisal language does not replace that requirement. Confidential reporting and discipline address different concerns and exist side by side, supporting a just culture. The AC draws the line in the same place, protecting reports not involving gross negligence or willful misconduct (Paragraph 3.5.7.3.3).
Elsewhere, the AC pairs that protection with accountability; a positive safety culture demands it of employees and management alike (Paragraph 2.5.1). When a report points to possible noncompliance (as willful action, not honest errors), the aim is to learn why it happened, not who did it (Paragraph 3.5.6.3.1). Ridgeline’s policy names who makes that call and requires someone with operational experience to be in the room when it happens.
Keeping the Policy Current
Ridgeline’s first policy ran a page and a half and noted most of the right things. It improved the way policies usually proceed: reports came in, and the safety manager saw which questions on the form confused people. Section 5.21 Paragraphs (c) and (d) build that kind of refinement in—the policy must be communicated throughout the organization, which is where Subpart E comes in.
Our Safety Promotion post covers the training and communication requirements in § 5.91 and § 5.93. The accountable executive also must review the policy regularly; however, the rule does not set an interval, so Ridgeline’s accountable executive reviews it once a year. Part of that review is asking who is reporting: if dispatch and ground crew rarely file, the accountable executive treats that as a question to answer, not as good news.
One note for the smallest operators: AC 120–92D Paragraph 3.3.1.5 lists § 5.21(a)(4), (a)(5), and (c) as excepted for single‑pilot organizations, although those operators should still have a way to record and manage the hazards they find.
How the Pieces Fit
- Objectives and commitment
States them in a one‑page policy signed by the accountable executive
Citation§ 5.21(a)(1)–(2) - Resources
Names the people and time set aside for the SMS
Citation§ 5.21(a)(3) - Reporting policy
Says what and how to report, who sees it, and that reporting is free of reprisal
- Unacceptable behavior
Defines willful misconduct and who decides when it applies
Citation§ 5.21(a)(5) - Emergency response
Describes the transition to emergency operations
- Code of ethics
Applies to everyone, management included, with safety first
Citation§ 5.21(a)(7) - Sign, communicate, review
Accountable executive signs the policy, it is posted and briefed, and annually reviewed
Citation§ 5.21(b)–(d)
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