Best Practices for Consultants Managing Client SMS Data

Best practices for consultants managing client SMS data focus on governance, data integrity, confidentiality, and clear separation of responsibilities between the consultant and the operator. In a Safety Management System in business aviation, data is not simply administrative information. It is safety intelligence that supports risk identification, decision making, and regulatory compliance. Consultants who manage or support SMS data must do so in a way that preserves the operator’s ownership of the system while enabling effective oversight, analysis, and continuous improvement.

For business aviation operators, SMS data is used to demonstrate conformity with FAA 14 CFR Part 5 concepts and alignment with ICAO Annex 19 principles. For consultants, the challenge is balancing efficiency across multiple clients while maintaining accuracy, confidentiality, and audit defensibility for each individual operation. Poor data practices can undermine an otherwise well designed SMS, particularly during audits, investigations, or leadership reviews.

This article explains how consultants should approach SMS data management, why it matters in business aviation, common mistakes to avoid, and what effective, compliant data management looks like in real world operations.

What Is SMS Data in Business Aviation?

SMS data includes any information created, collected, or analyzed to support the four pillars of an SMS. This typically includes hazard reports, risk assessments, mitigation records, safety assurance activities, audit findings, corrective actions, training records, and safety performance indicators.

In a Safety Management System in business aviation, this data serves multiple purposes. It supports operational risk management, demonstrates compliance, enables trend analysis, and informs leadership decisions. SMS data is also reviewed by auditors, regulators, and sometimes insurers following incidents or events.

Consultants often assist operators by configuring systems, reviewing submissions, performing analyses, and helping interpret trends. In some cases, consultants may temporarily manage data during initial SMS implementation or while an operator builds internal capability. Regardless of the level of involvement, the data remains the operator’s safety record and must be treated as such.

Why SMS Data Management Matters for Consultants

Business aviation operations are diverse. Consultants may support Part 91 flight departments, Part 135 charter operators, Part 145 repair stations, or Part 141 training organizations, sometimes simultaneously. Each operation has different regulatory expectations, risk profiles, and organizational structures.

Poor SMS data practices can create several problems. Data that is incomplete or inconsistent weakens hazard analysis and trend identification. Shared or commingled data between clients creates confidentiality risks. Over centralized consultant control can lead to findings that the SMS is consultant owned rather than operator driven.

Regulators and auditors increasingly expect operators to demonstrate ownership, awareness, and use of their SMS data. Consultants play an important role, but they must do so in a way that supports operator accountability rather than replacing it.

Who Owns SMS Data and Decision Authority?

A fundamental principle in SMS is that the operator owns the system and the data. This includes responsibility for risk acceptance, corrective actions, and safety decisions. Consultants may advise, analyze, and recommend, but they should not be the final authority unless formally delegated under the operator’s governance structure.

In practical terms, this means consultants should avoid acting as the sole reviewer, approver, or closer of safety items without operator involvement. Risk acceptance authority, in particular, should be clearly defined and documented by the operator. Consultants can support assessments, but acceptance decisions must align with the operator’s documented authority levels.

Clear ownership also matters during audits. Auditors often ask who reviews reports, who decides on mitigations, and how leadership is informed. If the answers point primarily to a consultant, it may raise concerns about SMS maturity and sustainability.

How Consultants Should Structure Access to Client SMS Data

Access control is one of the most important best individual practices for consultants managing client SMS data. Consultants should have access appropriate to their role and scope of work, but not unrestricted control by default.

Best practice is to establish role based access that limits what consultants can view, edit, or approve. For example, a consultant may have access to review hazard reports and draft recommendations but not to close corrective actions or approve risk acceptance. Access should also be time limited where appropriate, particularly for short term engagements.

Each client’s data environment should be clearly separated. Even when using the same tools or processes across clients, data should never be pooled or visible across organizations. This separation protects confidentiality and prevents cross contamination of safety records.

Data Consistency Across Multiple Operators

Consultants often strive for consistency to improve efficiency, especially when supporting multiple clients. Standardization can be helpful, but it must be applied carefully.

Templates for hazard categories, risk matrices, and report structures can support consistency while still allowing customization for each operator. However, consultants should avoid forcing identical classifications or thresholds where they do not fit the operation. A Part 91 flight department and a Part 145 repair station may use similar tools but face different risks and regulatory expectations.

Consistency should support clarity, not replace operational relevance. SMS data should reflect how the operator actually works, not how the consultant prefers to see the data organized.

Confidentiality and Protection of Safety Information

SMS relies on trust. Employees are more likely to report hazards when they believe their information is handled responsibly. Consultants must treat client SMS data as sensitive safety information, even when not explicitly protected under voluntary reporting programs.

This includes limiting access to those with a need to know, avoiding informal sharing of examples between clients, and being cautious when using anonymized data for training or marketing purposes. Even de identified data can sometimes be traced back to an operation based on context.

Consultants should also understand any contractual or policy commitments related to data confidentiality. Operators may have internal policies governing safety data use, and consultants should align their practices accordingly.

Common Mistakes Consultants Make With SMS Data

One common mistake is over centralizing data management. When consultants act as the primary data administrators for too long, operators may fail to build internal competence. This can lead to gaps when the consultant steps away or when the operation grows.

Another frequent issue is treating SMS data as a compliance artifact rather than an operational tool. When data is only updated for audits or reviews, its value for proactive risk management is reduced. Consultants should encourage regular use of data for safety meetings, trend reviews, and management discussions.

A third mistake is inconsistent documentation. Informal notes, offline analyses, or undocumented decisions can create gaps between what was done and what can be demonstrated. In an SMS, if it is not documented, it effectively did not happen.

What Good SMS Data Management Looks Like in Practice

Effective SMS data management is structured, transparent, and integrated into daily operations. Consultants support this by helping operators establish clear workflows for data entry, review, analysis, and action.

In a mature system, hazard reports are reviewed promptly, risk assessments are documented consistently, and mitigations are tracked to closure. Data is summarized and presented to leadership in a way that supports informed decisions. Consultants may assist with analysis and interpretation, but the operator remains actively involved.

Good practice also includes periodic reviews of data quality. This may involve checking for incomplete fields, inconsistent classifications, or overdue actions. These reviews help maintain the credibility of the SMS and support continuous improvement.

Differences Across Part 91, 135, and 145 Operations

While SMS principles are consistent, their application varies by operational context. Part 135 operators often have more formal requirements and external oversight, which increases the importance of structured data management and traceability. Part 91 operators may have more flexibility, but still benefit from disciplined practices that support safety culture and risk awareness.

Part 145 repair stations face different hazards related to maintenance activities, human factors, and tooling. SMS data for these organizations often focuses on task specific risks and corrective actions tied to quality and safety processes.

Consultants should tailor data practices to reflect these differences while maintaining alignment with overarching SMS principles.

How Technology Supports SMS Data Management

Modern SMS platforms can significantly improve how data is managed, especially for consultants working across multiple operators. Key capabilities include role based access, audit trails, standardized workflows, and integrated reporting.

Technology can reduce manual errors, improve data consistency, and make trends easier to identify. It also supports transparency by showing who did what and when. However, technology is only a tool. Consultants should ensure that systems are configured to support the operator’s governance structure rather than override it.

Effective use of technology also includes training operators to use the system themselves. Consultants should aim to make themselves less central to routine data tasks over time.

Forward Looking Considerations for Consultants

As SMS expectations continue to evolve, data quality and governance will receive increasing attention. Consultants who adopt disciplined data management practices will be better positioned to support clients through audits, growth, and organizational change.

Best practices for consultants managing client SMS data emphasize respect for operator ownership, careful access control, consistent but flexible structures, and a focus on operational value. When done well, SMS data becomes a shared asset that supports safer operations and more informed decision making across business aviation.