FAA SMS Compliance Deadlines
What You Need to Know
The Federal Aviation Administration (FAA) published its final Safety Management Systems (SMS) rule on April 26, 2024; this marks a significant shift in aviation safety oversight for many organizations, especially Title 14, Code of Federal Regulations (14 CFR) part 135 and part 21 certificate holders and part 91 LOA holders. The rule establishes deadlines for SMS implementation, affecting a wide range of aviation service providers. Let’s break down the key dates and requirements to help you navigate this important transition.
Who Needs to Comply?
The SMS final rule applies to these certificate/LOA holders:
Certificate holders operating under the rules for commuter and on‑demand operations (part 135)
Commercial air tour operators with an LOA (part 91.147)
Production certificate holders that are holders or licensees of a type certificate for the same product (part 21)
Type‑certificate holders that license out that type certificate for production (part 21)
Part 121 air carriers with an SMS that may need revisions to meet the new requirements
Operators with an accepted voluntary SMS program
Must update it to meet the final SMS rule
According to the FAA’s SMS Website, the voluntary program includes the following 14 CFR parts:
| Existing eligible 14 CFR parts | Newly eligible 14 CFR parts |
|---|---|
|
|
Compliance Deadlines
Here is a summary of implementation deadlines. (More details can be found on the FAA’s SMS Website.)
| Organization | Implementation Deadline | Additional Milestones |
|---|---|---|
| Part 121 | If your SMS was accepted by the FAA on or before May 28, 2024, you must revise it according to this rule no later than May 28, 2025. | N/A |
| Part 135 | May 28, 2027 | Submit a declaration of compliance no later than May 28, 2027. |
| LOA holders under 91.147 | May 28, 2027 | Submit a declaration of compliance no later than May 28, 2027. |
| Part 21 (Production certificate issued on/before May 28, 2024) |
May 28, 2027 | Submit an implementation plan no later than November 28, 2024. |
| Part 21 (Production certificate applied for/pending on/after May 28, 2024) |
No later than 36 months after submission of the implementation plan. | |
| Accepted Voluntary SMS Program Participants | If your SMS was accepted by the FAA on or before May 28, 2024, you must revise it according to this rule no later than May 28, 2025. | N/A |
Single Pilot Operators: Special Considerations
If you're a single pilot operator, you may be eligible for relief from certain SMS requirements. Check out our Single Pilot Operator post for details.
Moving Forward
Implementing an SMS is not just about regulatory compliance—it's an opportunity to enhance your organization's safety culture and operational efficiency. As you work towards meeting these new requirements, consider the following:
Engage with industry associations and peers for support and best practices.
Use FAA resources, such as Advisory Circulars (for example, AC 120‑92D, Safety Management Systems for Aviation Service Providers) and guidance materials (for example, Notice 8900.700, Interim Guidance Based on the Amendments to Title 14 of the Code of Federal Regulations Part 5 (faa.gov), which lists the information a declaration of compliance must contain).
Consider seeking expert assistance to streamline your implementation process.
At PAI Consulting, we understand the complexities of SMS implementation and are here to support you every step of the way. Whether you need help developing your SMS plan, training your team, or navigating the nuances of compliance, our experienced consultants are ready to assist.
SMS Readiness Checklist
- Familiarize yourself with FAA's SMS final rule requirements
- Identify which category your organization falls under (Part 121, 135, 91.147, 21, etc.)
- Note your specific compliance deadline
- Assess your current safety management practices
- Identify gaps between current practices and SMS requirements
- Develop an implementation plan (if required)
- Allocate resources for SMS development and implementation
- Train key personnel on SMS principles and practices
- Develop or update necessary SMS documentation
- Implement SMS processes and procedures
- Conduct internal audits to ensure compliance
- Prepare for FAA review or declaration of compliance submission
FAQ
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SMS involves all aspects of an organization, from upper-level executives to pilots and mechanics, from employees to vendors, from management to front-line employees, with everyone contributing to the safety of the operation.
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The rule applies to Part 135 certificate holders, commercial air tour operators with a Part 91.147 LOA, certain Part 21 certificate holders, and Part 121 air carriers. Voluntary SMS program participants may also need to update their systems.
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An SMS typically consists of four components: Safety Policy, Safety Risk Management, Safety Assurance, and Safety Promotion.
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Implementation deadlines vary depending on the type of organization. For example, Part 135 operators and Part 91.147 LOA holders have until May 28, 2027, while some Part 21 certificate holders may have different deadlines based on their certification date.
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In addition to being compliant with FAA regulations, benefits include improved safety performance, enhanced regulatory compliance, better resource allocation, increased operational efficiency, and a stronger safety culture within the organization.
Additional Resources
FAA Advisory Circular AC 120-92D: Safety Management Systems for Aviation Service Providers
International Civil Aviation Organization (ICAO) Safety Management Manual
Ready to Implement Your SMS?
Don’t navigate the complex world of SMS implementation alone. PAI Consulting’s team of experienced aviation safety experts is ready to guide you through every step of the process. From initial assessment to full implementation and ongoing support, we’re committed to helping you build a robust, compliant, and effective SMS.
Do you have questions or concerns about SMS? Share them with us!
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