Can SMS Work Without a Dedicated Safety Manager?

Can SMS work without a dedicated Safety Manager? In many business aviation operations, the answer is yes, with important caveats. A Safety Management System in business aviation does not require a full-time Safety Manager to exist or function, but it does require clearly assigned safety responsibilities, active leadership involvement, and consistent execution of core SMS processes. Where operators struggle is not the absence of a titled Safety Manager, but the absence of accountability, authority, and time allocated to safety functions.

FAA 14 CFR Part 5 does not mandate a specific job title. It requires that safety responsibilities are defined, resources are provided, and the system is managed in a way that ensures hazards are identified, risks are assessed, and safety performance is monitored. Many smaller Part 91, Part 135, and even some Part 145 organizations meet these expectations by distributing SMS responsibilities across existing leadership roles rather than hiring a standalone safety position.

This article explains when and how an SMS can work without a dedicated Safety Manager, where the limits of that approach are, and what regulators and auditors expect to see in practice.

What Is a “Dedicated Safety Manager” in Practice?

A dedicated Safety Manager is typically a full-time role responsible for coordinating the operation of the Safety Management System. This person often serves as the focal point for hazard reporting, risk assessment, safety assurance activities, and regulatory interaction. In larger organizations, the Safety Manager may also oversee internal audits, safety data analysis, and safety promotion activities.

In smaller operations, the same responsibilities often exist but are assigned to someone who holds another primary role, such as Director of Operations, Chief Pilot, Maintenance Manager, or Quality Manager. The distinction is not the work being done, but whether safety oversight is a full-time function or an assigned duty among others.

From a regulatory perspective, what matters is that these responsibilities are clearly defined, documented, and consistently carried out.

What the Regulations Actually Require

FAA 14 CFR Part 5 focuses on functions, not job titles. The regulation expects operators to establish policies, processes, and controls that support the four pillars of SMS: Safety Policy, Safety Risk Management, Safety Assurance, and Safety Promotion. It requires an Accountable Executive with ultimate responsibility for the system and clearly assigned safety responsibilities throughout the organization.

ICAO Annex 19 takes a similar approach. It emphasizes accountability, authority, and competence rather than prescribing organizational charts. The intent is to ensure safety decision-making is effective, regardless of organizational size.

For Part 135 operators, SMS is mandatory, but the rule does not state that a full-time Safety Manager must be employed. For Part 91 operators, SMS may be voluntary, but expectations from insurers, auditors, and customers often mirror Part 5 principles. Part 145 repair stations frequently integrate SMS responsibilities into existing quality and compliance structures.

Understanding how SMS applies differently to Part 91, Part 135, and Part 145 operators helps clarify where flexibility exists and where expectations are higher.

Why This Question Matters in Business Aviation

Business aviation operations vary widely in size and complexity. Many flight departments operate with lean teams where individuals already wear multiple hats. Hiring a full-time Safety Manager may not be operationally or financially realistic, especially for single-aircraft or small fleet operators.

At the same time, safety oversight cannot be treated as a secondary concern that is addressed only when time allows. Regulators and auditors recognize operational constraints, but they also expect evidence that SMS processes are active, effective, and sustained over time.

The question is not whether a dedicated Safety Manager exists, but whether the SMS is being actively managed.

How SMS Works Without a Dedicated Safety Manager

In operations without a dedicated Safety Manager, SMS responsibilities are typically distributed across several roles. Common models include:

An Accountable Executive who sets safety policy, allocates resources, and remains visibly engaged in safety decisions.

An operational leader, such as a Director of Operations or Chief Pilot, who oversees hazard identification and risk assessment related to flight operations.

A maintenance or quality leader who manages hazards, investigations, and corrective actions related to technical and maintenance activities.

An administrative or safety coordinator who manages documentation, tracks corrective actions, and supports reporting workflows.

In these models, one person is often designated as the SMS focal point, even if that is not their full-time job. This individual ensures that reports are reviewed, risk assessments are completed, and safety meetings occur as planned.

This approach can work well when responsibilities are clearly documented, authority is aligned with responsibility, and leadership actively supports the system.

Practical Examples From Real Operations

Consider a small Part 135 operator with five aircraft. The Director of Operations serves as the SMS focal point, the Chief Pilot manages flight-related hazards, and the Director of Maintenance manages maintenance-related risks. The Accountable Executive chairs quarterly safety meetings and approves risk acceptance decisions above defined thresholds.

Hazard reports are submitted by line personnel, reviewed by the appropriate functional lead, and tracked through closure. Safety performance indicators are reviewed quarterly, and trends are discussed during management meetings.

In this scenario, no one holds the title of Safety Manager, but the SMS functions are clearly owned and actively managed.

Contrast this with an operation where SMS responsibilities are vaguely assigned, hazard reports sit unreviewed, and safety meetings are skipped due to operational pressure. In that case, the absence of a dedicated Safety Manager exposes underlying governance issues that no amount of documentation can fix.

Common Misunderstandings About Safety Manager Roles

One common misunderstanding is that assigning SMS duties to an existing leader automatically satisfies regulatory expectations. If that person lacks time, authority, or training, the system will degrade over time.

Another misconception is that software or documentation can replace human oversight. Tools can support consistency and visibility, but they do not make safety decisions.

Some operators also assume that auditors will accept informal arrangements. In practice, auditors look for evidence that SMS responsibilities are defined, understood, and exercised consistently. They often ask who reviews reports, who approves risk acceptance, and how leadership stays informed.

These expectations are consistent with what auditors look for in an SMS program, regardless of operator size.

What “Good” Looks Like Without a Dedicated Safety Manager

When SMS works well without a dedicated Safety Manager, several characteristics are consistently present:

Clear role definitions for SMS responsibilities, documented in manuals and procedures.

A named SMS focal point with sufficient authority to coordinate activities and escalate issues.

Regular safety meetings with documented outcomes and follow-up actions.

Timely review and closure of hazard reports and investigations.

Active involvement from the Accountable Executive in safety decisions.

Evidence of safety performance monitoring and continuous improvement.

In these organizations, SMS is part of normal business operations rather than an add-on task.

When a Dedicated Safety Manager Becomes Necessary

As operations grow in size, complexity, or risk exposure, the distributed model becomes harder to sustain. Increased reporting volume, multiple operating bases, and more complex regulatory environments all increase the workload associated with SMS.

At a certain point, safety oversight competes directly with operational responsibilities. When safety tasks are consistently delayed or delegated without follow-through, it is often a signal that a dedicated role is needed.

This transition point varies by operator, but it is usually driven by workload rather than regulatory mandate.

The Role of Technology in Supporting This Model

Modern SMS platforms can help operators manage SMS responsibilities without a dedicated Safety Manager by standardizing workflows, tracking accountability, and providing visibility into safety performance. Automated notifications, role-based access, and centralized reporting reduce the administrative burden on individuals who already hold other roles.

Technology does not replace judgment or leadership involvement, but it can reduce friction and help ensure that nothing falls through the cracks. This is especially valuable in distributed responsibility models where coordination is critical.

Understanding what to look for in aviation SMS software can help operators select tools that support their organizational structure rather than work against it.

A Practical, Forward-Looking Perspective

A Safety Management System in business aviation can function effectively without a dedicated Safety Manager when responsibilities are clearly assigned, leadership is engaged, and processes are consistently followed. This approach aligns with the intent of FAA Part 5 and ICAO Annex 19, particularly for smaller and mid-sized operators.

The key question for any organization is not whether a specific role exists, but whether the system is actively managed and capable of identifying and controlling risk. As operations evolve, operators should periodically reassess whether their SMS governance structure still supports effective oversight.

An SMS that adapts alongside the organization is more resilient, more credible, and more likely to deliver meaningful safety outcomes over time.