Safety Promotion: Training, Talking, and Making the SMS Stick
A Ridgeline Air Case Study, Part Two
In our SRM in Action case study, we followed Ridgeline Air, our fictional Title 14, Code of Federal Regulations (14 CFR) part 135 charter operator, through a full Safety Risk Management (SRM) cycle as it added a new destination: a remote Pacific Northwest airstrip with a short runway and challenging terrain. Ridgeline described the system, identified the hazards, assessed the risk, developed controls, and accepted residual risk under 14 CFR part 5, Subpart C. Next, in Safety Assurance, we covered how Ridgeline verifies those controls keep working.
Identifying new controls is only part of the process—someone must be trained on them and must explain why they exist. That is where Subpart E, Safety Promotion, comes in: the part of the SMS that turns a risk‑control decision made in a conference room into changed operational behavior.
What Is Safety Promotion?
Part 5 at § 5.3 defines safety promotion as a combination of training and safety‑information communication that supports the implementation and operation of an SMS. Subpart E breaks that into two requirements:
§ 5.91, Competencies and training: Any person required to have an SMS must train each individual identified in § 5.23—meaning the accountable executive, management, and employees—so they attain and maintain the competencies needed to do their SMS‑related jobs.
§ 5.93, Safety communication: Any person required to have an SMS must maintain a way to communicate safety information that, at minimum, keeps employees aware of the SMS policies and tools relevant to their job, conveys hazard information relevant to their responsibilities, and explains why safety actions were taken or procedures changed.
Neither requirement dictates a format; Federal Aviation Administration (FAA) Advisory Circular (AC) 120–92D is explicit that training can be in person or virtual. Likewise, communication can happen through a manual revision, a briefing, a poster, or an email, provided it is consistent and reaches the people who need it (paragraph 3.6). A one‑person flight department and a regional air carrier must both comply with §§ 5.91 and 5.93; however, implementation will vary with the organization’s size and complexity.
Back at Ridgeline Air
Recall the four controls of Ridgeline’s SRM process produced for the new airstrip:
Route‑qualification training for pilots,
Company‑specific weather minima above Federal Aviation Regulation (FAR) minimums,
Dispatch go/no‑go criteria tied to weather and Notice to Air Missions (NOTAM) review, and
A fuel‑quality verification process with the contract fueler.
Ridgeline’s director of operations accepted the resulting medium risk and signed the hazard‑registry entry following § 5.55(d); however, the director’s signature did not close the file. Instead, the process moved to Subpart E, where the new controls had to be communicated to the rest of the team.
Training. Route‑qualification training is, by definition, a § 5.91 obligation: Ridgeline must ensure every flightcrew member assigned to the new route attains and maintains the competencies the SRM process decided they need—the terrain picture, the traffic pattern at a non‑towered field, and the destination’s non‑standard procedures—before their first revenue flight there. AC 120–92D’s guidance that training be role‑specific and scaled to the organization applies directly (paragraph 3.6.1): a line pilot flying the route needs the full module, while a pilot who will never fly it does not. Ridgeline tracks completion in its training‑records system, which is both a § 5.91 competency check and, as the case study noted, part of how the safety manager monitors whether the control is working under § 5.73(a)(3). The completion records themselves are a recordkeeping obligation under § 5.97(c).
Communication. The other three controls are not training obligations, but they do not work unless the correct people know about them. Dispatch must apply the new go/no‑go criteria and the elevated weather minima to every flight release for that destination, meaning dispatch must understand not just what the numbers are but why they are higher than the FAR floor. The safety manager also needs the fuel‑quality documentation reaching whoever coordinates supplier evaluations. None of that is § 5.91 training in the competency sense—it is § 5.93 communication, and it has a specific job under paragraphs (b) and (d): convey hazard information relevant to the employee’s responsibilities and explain why the procedure was introduced. Ridgeline handles this the way AC 120–92D describes for smaller organizations: through an operations manual revision, a briefing item, and a short explanation of what changed and why (paragraph 3.6.2.4).
This is also where safety promotion connects back to our post on § 5.57: notifying interfacing persons. While § 5.57 is about telling outside organizations, such as a fixed‑base operator (FBO) or an airport, about a hazard they could help address, § 5.93 focuses on communicating those hazards to your own people. Ridgeline needs both, and confusing the two is a common gap: an operator that is diligent about external notification can still leave its own dispatchers or ramp crew in the dark about why a procedure exists.
Why This Matters
It is worth pausing on something easy to miss. With safety promotion covered, this series has now touched every component listed in § 5.5: safety policy, safety risk management, safety assurance, and safety promotion, plus the documentation and recordkeeping obligations that bolster all four. An SMS that stops at the risk‑control decision without training the people who carry it out or telling the people who need to know has not actually managed the risk; it has just written it down.
How the Pieces Fit
Ridgeline Air · New-route rollout
From risk-control decision to changed behavior
- Training · § 5.91
- Communication · § 5.93
Training
-
Step 2
Deliver role-specific training
What Ridgeline did: Route-qualification module on terrain, non-towered traffic pattern, and destination-specific procedures
-
Step 3
Retain training records
What Ridgeline did: Completion tracked in the training-records system
Communication
-
Step 5
Retain communication records
What Ridgeline did: Manual revision and briefing notes kept at least 24 months
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