How Fractional Safety Managers Manage Multiple SMS Programs

How Fractional Safety Managers Manage Multiple SMS Programs is What Is a Safety Management System in Business Aviation practical question that comes up frequently in business aviation. Many operators rely on fractional or outsourced safety managers to design, oversee, or maintain their Safety Management System in business aviation, often across several unrelated organizations. This model can be effective, but only when the SMS is structured correctly and managed with discipline.

Fractional safety managers succeed by treating each operator’s SMS as a distinct system while applying consistent processes, governance practices, and regulatory alignment. They do not manage safety by memory or informal checklists. Instead, they rely on standardized frameworks, documented roles, predictable workflows, and clear boundaries between operators.

This article explains how fractional safety managers manage multiple SMS programs in real-world operations, why this approach matters for business aviation, and what effective oversight looks like under FAA 14 CFR Part 5 and ICAO Annex 19 principles.

What Is a Fractional Safety Manager

A fractional safety manager is an individual or organization that provides Safety Management System oversight and administration to more than one operator, typically on a part-time or contractual basis. These arrangements are common in business aviation, especially among smaller Part 91 flight departments, Part 135 operators with limited staffing, Part 145 repair stations, and Part 141 training organizations.

The fractional safety manager may be responsible for some or all of the following:

• SMS design and documentation

• Hazard reporting oversight

• Risk assessment facilitation

• Safety assurance activities

• Audit preparation and corrective action tracking

• Safety promotion and training support

Importantly, the fractional safety manager does not replace operational leadership. Under Part 5 concepts, accountability remains with the operator’s Accountable Executive and management team.

Why This Model Exists in Business Aviation

Business aviation presents unique challenges for staffing safety roles. Many operators do not have the scale to justify a full-time safety manager, yet they still face increasing expectations from regulators, auditors, insurers, and customers.

Fractional safety management allows operators to:

• Access experienced SMS expertise

• Maintain continuity across audits and leadership changes

• Scale SMS capability without permanent headcount

• Meet SMS expectations appropriate to their regulatory environment

This model aligns closely with guidance discussed in What Is a Safety Management System in Business Aviation? and How to Implement an SMS Without Hiring a Full-Time Safety Manager.

How Fractional Safety Managers Structure Multiple SMS Programs

Effective fractional safety managers do not run a single blended system across multiple operators. Each operator’s SMS is structured as a standalone program with its own documentation, records, risk profile, and governance.

Common structural elements include:

Separate Governance for Each Operator Each SMS has defined roles, authorities, and escalation paths specific to that organization. Even when the same individual serves multiple operators, decision-making authority is never shared across organizations.

Consistent Frameworks, Not Shared Content Fractional safety managers often use consistent templates, processes, and workflows, but the outputs are customized. Hazard registers, risk assessments, and corrective actions are operator-specific.

Clear Regulatory Alignment Differences between Part 91, Part 135, Part 145, Part 141, and Part 139 operations are reflected in SMS scope, documentation depth, and assurance activities. This distinction is critical and often misunderstood, as discussed in How SMS Applies Differently to Part 91, Part 135, and Part 145 Operators.

Managing Hazard Reporting Across Multiple Operators

One of the most demanding aspects of managing multiple SMS programs is hazard reporting. Fractional safety managers must ensure reports are:

• Captured promptly

• Reviewed consistently

• Assessed using the operator’s approved risk matrix

• Tracked through mitigation and closure

Good practice involves:

• Standardized intake processes that reduce variation

• Defined review timelines aligned with Part 5 expectations

• Clear documentation of risk acceptance authority

• Independent hazard tracking for each operator

Weak programs often fail by allowing reports to accumulate without review or by applying inconsistent severity and likelihood assessments across different operators.

Risk Assessment and Risk Acceptance Boundaries

Fractional safety managers facilitate risk assessments but do not own risk acceptance. Under FAA Part 5 principles, risk acceptance must be performed by individuals with the appropriate authority within the operator’s organization.

Effective programs define:

• Who may accept risk at each severity level

• When escalation is required

• How decisions are documented and reviewed

This approach prevents the fractional safety manager from becoming an informal decision-maker, which is a common audit finding in poorly structured SMS programs.

Safety Assurance and Oversight at Scale

Managing safety assurance across multiple operators requires disciplined scheduling and tracking. Fractional safety managers typically maintain:

• Operator-specific audit calendars

• Separate corrective action registers

• Defined performance indicators aligned with each operation

Assurance activities are tailored to operational complexity. A Part 91 flight department will not require the same level of internal audit depth as a Part 135 certificate holder, but both must demonstrate systematic monitoring and continuous improvement.

These expectations align closely with themes addressed in What Auditors Look for in an SMS Program.

Common Misunderstandings About Fractional SMS Oversight

Several misconceptions frequently undermine fractional SMS arrangements:

One SMS Can Cover Multiple Operators This is incorrect. Each operator must have its own SMS structure, documentation, and records.

The Fractional Safety Manager Is the Accountable Executive Accountability cannot be outsourced. The Accountable Executive must remain actively involved.

Technology Alone Solves Oversight Challenges Tools support the process but do not replace governance, discipline, or leadership engagement.

All Operators Need the Same SMS Depth SMS should be scalable and proportional to operational risk and regulatory requirements.

What Good Looks Like in Practice

Well-run fractional SMS programs share several characteristics:

• Clear boundaries between operators

• Predictable review and reporting cycles

• Documented decision-making

• Consistent engagement with management

• Audit-ready records at all times

Fractional safety managers operating at this level function as system integrators rather than task executors. They ensure the SMS operates continuously, not just before audits.

The Role of Technology in Managing Multiple SMS Programs

Modern SMS platforms support fractional safety managers by providing structure, traceability, and visibility across programs. Technology helps by:

• Centralizing records while maintaining separation

• Automating reminders and follow-ups

• Standardizing workflows

• Supporting trend analysis within each operator’s data set

Technology does not remove the need for judgment or oversight, but it reduces administrative friction and improves consistency. These capabilities are often discussed in What to Look for in Aviation SMS Software.

Looking Ahead

Fractional safety management will continue to play an important role in the Safety Management System in business aviation. As SMS expectations mature, the ability to manage multiple programs systematically and defensibly will become increasingly important.

Operators considering this model should focus on structure, accountability, and clarity rather than convenience. When implemented correctly, fractional safety managers provide sustainable SMS oversight that aligns with both FAA Part 5 intent and ICAO Annex 19 principles while remaining practical for business aviation operations.