Consulting · Safety Management Systems

SMS that survives an audit.

A Safety Management System is not a manual on a shelf. It is a living process for finding hazards before they find you, and since April 2024 it is federal law for a much larger slice of the industry. DA builds SMS programs that regulators recognize and crews actually use.

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The Mandate

The clock is already running.

Part 135 and air tour operators. The FAA's final rule extends 14 CFR Part 5 to every Part 135 certificate holder and 91.147 LOA air tour operator. A fully implemented SMS and a signed Declaration of Compliance are due to the FAA by May 28, 2027. That date is the finish line, not the starting gun.

Repair stations. U.S. Part 145 repair stations holding EASA approval were required to have SMS fully integrated by December 31, 2025. Oversight has moved from reviewing plans to evaluating performance. The FAA has not yet mandated SMS for all domestic 145s, but it formally asked industry whether it should. Read the direction of travel.

Design and production holders. Certain Part 21 certificate holders were phased in on earlier deadlines and are already under surveillance.

The Build

Four components, working as one system.

§ 5.21

Safety Policy

An accountable executive who actually accounts, a policy people can recite, and a reporting culture with teeth. We draft it with your leadership, not for them.

§ 5.51

Safety Risk Management

Hazard identification, system analysis, and risk controls sized to your operation. A hazard register that gets read, not a spreadsheet that gets buried.

§ 5.71

Safety Assurance

Audits, performance monitoring, and corrective action loops that close. This is where regulators look first, because it is where paper programs die.

§ 5.91

Safety Promotion

Role-based training and communication that makes the system self-sustaining, from the corner office to the newest technician on the floor.

Engagement

What DA delivers.

Gap analysis against Part 5, mapped line by line to what you already do, so you build only what is missing.

Implementation. SMS manual, implementation plan, hazard reporting workflows, risk matrices, and the training to run them, scaled honestly to your size.

Declaration of Compliance readiness. Evidence packages and internal audits so the declaration you sign is one you can defend.

Post-implementation assurance. Recurring audits and safety performance reviews that keep the system alive after the consultants leave. Ours included.

FAQ

Straight answers.

When is the FAA SMS deadline for Part 135 operators?

A fully implemented SMS with a Declaration of Compliance submitted to the FAA is required by May 28, 2027 for Part 135 certificate holders and 91.147 air tour LOA holders.

Does it apply to small operators?

Yes, regardless of fleet size. Part 5 scales, and single-pilot certificate holders get limited exceptions, but the four components still apply.

Are repair stations required to have an SMS?

U.S. 145s with EASA approval were required to be fully implemented by December 31, 2025. A domestic mandate for all repair stations does not exist yet, but the FAA has formally asked whether it should. Building now is cheaper than building under a deadline.

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