Single Safety Manager Strategies for Small Operators
For small operators—especially those where the safety manager role is just one of many hats—complying with Title 14, Code of Federal Regulations (14 CFR) part 5 can feel like a challenge. The good news? Federal Aviation Administration (FAA) guidance allows you to scale your Safety Management System (SMS) to match your organization’s size, scope, and complexity—the key is knowing where to focus so your SMS is both effective and sustainable.
In this SMS Quick Take, we outline five practical strategies that align with FAA Advisory Circular (AC) 120–92D and meet the requirements of part 5.
Five Strategies to Keep it Practical
1. Scale your SMS to fit your operation
What the FAA says:
14 CFR § 5.5(a): “An SMS under this part must be appropriate to the size, scope, and complexity of the person’s organization…”
AC 120–92D, p. 1: “There is no one‑size‑fits‑all method for complying with the requirements of part 5…”
What to do: Tailor forms, meetings, and documentation to fit your workload and operational profile. Avoid overcomplication—small operators don’t need air carrier‑scale processes.
How to do it:
Use simple forms or spreadsheets for hazard reporting and tracking instead of full‑scale software systems.
Schedule short, focused safety reviews quarterly (or monthly if activity is higher) rather than large committee meetings.
Keep SMS documentation concise and in one location (binder, shared folder, or secure cloud drive) so it’s easy to update and find.
Adapt AC 120–92D sample forms/templates to fit your operation, removing non‑applicable sections.
2. Focus on the biggest risks
What the FAA says:
14 CFR § 5.53(c): “[D]evelop and maintain processes to identify hazards within the context of the system analysis.”
14 CFR § 5.55(b): “Define a process for conducting risk assessment that allows for the determination of acceptable safety risk.”
AC 120–92D ¶ 3.3.1.4.1: “[T]he focus should be where resources will have the greatest safety benefit,…so the focus should be on the top one, two, or three risks….”
What to do: Maintain a living hazard registry; prioritize hazards with the highest likelihood and severity.
How to do it:
Keep a running hazard log (Excel or on paper) with date reported, description, risk rating, and status.
Rank hazards using a simple risk matrix from AC 120–92D, with “high,” “medium,” and “low” categories.
Review your top hazards at each safety review meeting and defer low‑impact issues until high‑risk ones are resolved.
Involve frontline personnel in hazard discussions: they often spot the early warning signs.
3. Close the loop (assurance→assessment→improvement)
What the FAA says:
14 CFR § 5.71(a): “[D]evelop and maintain processes and systems to acquire data…to monitor the safety performance of the organization.”
14 CFR § 5.73(a)(3): “Evaluate the effectiveness of the safety risk controls….”
14 CFR § 5.75: “[E]stablish and implement processes to correct safety performance deficiencies….”
AC 120–92D, Ch. 2, ¶ 2.1.4: “[S]afety assurance requires monitoring and measuring safety performance…to maintain the integrity of risk controls.”
What to do: Review reports, maintenance discrepancies, and operational data regularly. Take action, track results, and verify fixes are working.
How to do it:
Use a simple checklist for monthly reviews of reports, incidents, and maintenance findings.
Assign responsibility and due dates for corrective actions—track them until closure.
When an action is closed, validate the fix (observation, data check, or followup conversation).
Keep before‑and‑after evidence (photos, logs, or reports) for audits to demonstrate effectiveness.
4. Make safety part of the conversation (training and communication)
What the FAA says:
14 CFR § 5.91: “[P]rovide training…to ensure…individuals attain and maintain the competencies necessary to perform their duties relevant to the operation and performance of the SMS.”
14 CFR § 5.93: “[D]evelop and maintain means for communicating safety information….”
AC 120–92D ¶ 3.6.2.4: “Effective communication…[and] the delivery system should be appropriate to the size and complexity of the organization.”
What to do: Brief flightcrews and staff during operational meetings. No need for separate safety meetings—frequent, informal updates remind everyone that safety is the top priority.
How to do it:
Add a 5‑minute safety topic discussion to the start or end of every staff or operational meeting.
Use real events (internal or industry‑wide) as discussion starters.
Post short updates on a bulletin board, email, or group chat.
Keep a training log showing who attended sessions or read updates, even for informal briefings.
5. Use what’s already out there (external data and interfaces)
What the FAA says:
14 CFR § 5.71(a)(8) requires operators to investigate notifications received from external sources.
14 CFR § 5.57 requires you to notify interfacing persons when they can address a hazard.
14 CFR § 5.95(b) Requires you to document all “SMS processes and procedures,” including how you gather, evaluate, and act on safety information from outside your organization.
AC 120–92D ¶ 3.5.8.3.1 reminds organizations that hazards from external sources must be evaluated using the same safety assurance processes as internal hazards.
What to do: Proactively gather safety information from credible outside sources—such as FAA programs, manufacturers, industry groups, and peer networks—and use it to identify hazards, manage risks, and improve your safety program. Document how you obtain, assess, and share this information so it’s part of your formal SMS and shared with the right people in your organization.
How to do it:
Subscribe to FAA Safety Alerts for Operators (SAFO), Special Airworthiness Information Bulletins (SAIB), and National Transportation Safety Board (NTSB) safety recommendations relevant to your operation.
Sign up for FAASTeam WINGS notices and webinars.
Monitor ASIAS public data and other industry safety reports for trends that may apply to your operation.
Monitor original equipment manufacturer (OEM) service bulletins, safety newsletters, and operational advisories for your aircraft, engines, and major equipment.
Participate in regional safety groups, industry working groups, or online professional forums.
Network with other small‑operator safety managers to share lessons learned.
Keep a centralized record (binder, shared folder, or cloud drive) of all external safety information you review, with notes on what was relevant and what action you took.
Run applicable external hazards through your risk assessment process just like the internal ones and record the results.
Final Thoughts:
For a single safety manager, the challenge isn’t about doing more—it’s about doing the right things, consistently. A scaled, focused SMS lets you meet FAA requirements, manage risk effectively, and maintain a healthy safety culture without creating unnecessary complexity or paperwork. The best results come when you know your top risks, keep your processes lean, and use all the resources available to you.
How PAI Consulting Can Help
At PAI Consulting, we specialize in helping small operators implement right-sized, audit-ready SMS programs that comply with 14 CFR part 5 and follow AC 120–92D guidance. Whether you need—
A tailored SMS implementation plan,
Templates and tools scaled for your operation,
Guidance on hazard tracking and risk assessment, or
Ongoing safety program support,
…our team of experienced aviation, regulatory, and technical writing professionals can help you build an SMS that works for your operation—not against it.
Contact us today to discuss your needs and see how we can help you streamline compliance and improve safety performance.
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