Hazard Information Reporting Per the 2024 FAA SMS Rule
The 2024 FAA Safety Management Systems (SMS) Rule introduces a structured approach to managing safety risks within aviation organizations. One of the regulation’s essential components is the emphasis on hazard identification and reporting as a vital part of an effective SMS. Under the new rule, affected organizations must foster an environment where employees feel empowered to share information about hazards, incidents, and near misses without fear of reprisal. This cultural shift is crucial to developing a robust safety culture that prioritizes continuous improvement; furthermore, adhering to these guidelines ensures compliance and enhances the organization’s reputation within the industry.
The Importance of Hazard Information Reporting
Hazard‑information reporting serves several critical functions within an SMS framework. First, it enhances risk identification by encouraging proactive hazard identification and reporting, fostering a collaborative safety culture through open communication among employees and external entities that contribute to an organization’s safety. It also enables data‑driven decision‑making by analyzing trends in safety incidents. This approach produces timely interventions, a more informed workforce, and improved safety training and resource allocation.
What is a hazard?
According to Title 14, Code of Federal Regulations (14 CFR) § 5.3, Definitions, a hazard is “any condition or an object that could foreseeably cause or contribute to an incident or aircraft accident.” When you think about it, the aviation operating environment is teeming with hazards—some, like unauthorized aircraft or vehicles on the runway, are immediately apparent; others, such as undetected fatigue among crewmembers, are more subtle. Still more continually emerge over time as the environment evolves and conditions shift.
To mitigate most of these hazards, the FAA plays a vital role in ensuring aviation safety through its functions, including regulating operations, managing airspace, certifying aircraft and personnel, and fostering innovation. It has done an excellent job of creating a strong framework that mitigates risks, promotes safety, and supports the continuous improvement of aviation systems.
Experience has shown, however, that compliance‑based regulations alone cannot address the complexities of a dynamic aviation environment—a performance‑based framework, such as 14 CFR part 5 and SMS, are essential to proactively manage hazards, adapt to change, and enhance safety through data‑driven decisions and a strong safety culture. Let’s have a look at the reporting requirements of part 5 and the guidance provided by Advisory Circular (AC) 120–92D for complying with them.
Hazard Reporting in The Context of Part 5 and AC 120–92D
The FAA bases its SMS requirements on SMS’s four main components: safety policy, safety risk management (SRM), safety assurance (SA), and safety promotion. Hazard reporting is at the heart of a successful SMS, as it drives proactive risk identification and management within an organization’s operating environment, especially regarding SRM and SA. Furthermore, the safety policy and promotion components are essential to successfully implementing and sustaining a robust safety‑reporting culture.
Below, we have provided an overview of the part 5 requirements, their corresponding AC 120–92D guidance, and the role of hazard‑information reporting as this relates to SMS’s four components. Note: small operators are exempted from many part 5 requirements. Furthermore, AC 120–92D’s recommendations are not mandatory—organizations may choose alternative methods of compliance to meet the requirements or create a voluntary SMS that meets their needs.
Safety Policy
14 CFR part 5, Subpart B sets forth the safety policy requirements: §5.21(a)(4) mandates a reporting policy that defines requirements for employee reporting of safety hazards or issues. AC 120–92D provides guidance on creating an open, non‑punitive reporting environment to encourage hazard reporting and building a just culture.
Role of Hazard‑information Sharing: Confidential reporting fosters trust and helps all employees feel safe reporting hazards or issues, or proposing solutions without fear of retaliation. It also aligns with the organization’s commitment to safety as part of its policies.
Safety Risk Management (SRM)
14 CFR §5.51, Subpart C establishes the requirements for SRM application that includes hazard or ineffective risk control identification through the SA process. AC 120–92D, Section 3.4.1 outlines the SRM component and provides guidance for establishing hazard identification and risk analysis techniques and when they are required.
14 CFR §5.57 obligates organizations with an SMS under part 5 to report hazards identified in their operating environment to parties that contribute to their safety and who they feel can best address the hazards or mitigate their risk. AC 120–92D, Section 3.4.7 includes example scenarios and decision diagrams for determining when and how to submit such reports.
Role of Hazard Information Reporting: Employee‑reported hazards play a critical role in SRM by identifying hazards and enabling timely and effective risk management strategies. Reporting or sharing hazard information with other entities in an organization’s operating environment drives the aviation industry to work together to identify and address potential safety issues.
Safety Assurance (SA)
14 CFR part 5, Subpart D outlines the SA requirement. Section 5.71 mandates any organization required to have an SMS under part 5 to develop and maintain processes to collect and analyze safety data for monitoring safety performance, including requirements for a confidential employee‑reporting system and processes for investigating hazard notifications received from external sources. AC 120–92D, Section 3.5 outlines guidance for aviation organizations of varying complexity to implement the part 5’s SA requirements.
Role of Hazard Information Reporting: Hazard reports from employees and external sources provide vital information for SA to ensure the organization’s SMS’s effectiveness by monitoring safety performance, trend identification, analysis, and continuous improvement.
Safety Promotion
14 CFR §5.95 requires organizations to foster engagement through communication and training to support their SMS implementation and operation. AC 120–92D, Section 3.6 emphasizes the importance of safety awareness and training programs, and provides implementation guidance for organizations of all sizes to ensure employees have a solid understanding regarding their safety responsibilities and the organization’s safety policies and expectations, reporting procedures, and risk controls.
Role of Hazard Information Reporting: Providing, encouraging, and rewarding open hazard reporting and solution suggesting promotes a positive safety culture, reinforcing the importance of safety awareness and collaboration throughout the organization and with external entities that contribute to its safety.
We hope we have shown that hazard information reporting is more than just a regulatory requirement—it is the cornerstone of a robust SMS. By embedding this practice into every aspect of SMS, organizations can foster a proactive, collaborative approach to managing risks and maintaining the highest standards of aviation safety.
At PAI Consulting, we understand the challenges and opportunities that come with implementing an effective SMS. Let us assist you in navigating these changes to build a safety culture that sets your organization apart. Contact us today—we’re ready to help you succeed!
References:
Federal Aviation Administration (FAA). (2024). Advisory Circular 120–92D: Safety Management Systems for Aviation Service Providers.
Lawrenson, Anthony, Clarence C. Rodrigues, Shem Malmquist, Matthew Greaves, Graham Braithwaite, and Stephen K. Cusick. 2023. Commercial Aviation Safety. 7th ed. New York: McGraw Hill.
Reason, J. (1997). Managing the Risks of Organizational Accidents. Ashgate Publishing.
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