What to Do First When Starting an SMS Program

When operators ask what to do first when starting an SMS program, the answer is often simpler than expected. The first step is not buying software, writing procedures, or appointing a safety committee. The first step is establishing clear safety accountability and intent at the leadership level. Without this foundation, even well documented Safety Management System processes tend to stall or become compliance exercises rather than operational tools.

A Safety Management System in business aviation is a structured way to identify hazards, assess risk, manage change, and verify that safety controls are working. FAA 14 CFR Part 5 and ICAO Annex 19 both emphasize that SMS effectiveness depends on management commitment, defined responsibilities, and integration into daily operations. Starting in the wrong place often leads to rework later. Starting in the right place allows the SMS to grow in a controlled and sustainable way.

This article explains what to do first when starting an SMS program, why that step matters, and how it applies across Part 91, 135, 145, 141, and 139 operations.

What Is the First Step in Starting an SMS Program?

The first step in starting an SMS program is establishing safety accountability and governance. This means formally identifying who is responsible for safety performance, how decisions are made, and how safety authority flows through the organization.

Under FAA Part 5, this responsibility ultimately rests with the Accountable Executive. Even for voluntary SMS programs, regulators and auditors expect the same structure. The Accountable Executive must have authority over resources and operational decisions and must be clearly identified in writing.

At a practical level, this first step includes:

• Naming the Accountable Executive

• Defining safety roles and responsibilities

• Establishing a basic safety policy statement

• Agreeing on how safety decisions will be reviewed and approved

This foundational work creates the framework that all other SMS elements depend on. It also aligns directly with the Safety Policy pillar described in guidance such as The Four Pillars of SMS Explained for Business Aviation.

Why Starting with Governance Matters in Business Aviation

Business aviation operations vary widely in size and complexity. A single aircraft Part 91 flight department faces different risks than a multi base Part 135 charter operator or a Part 145 repair station. Despite these differences, the SMS governance requirement is consistent.

Starting with governance matters because:

• It clarifies who owns safety decisions

• It prevents safety from being delegated without authority

• It allows risk acceptance to be consistent and defensible

• It sets expectations before processes are built

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In business aviation, many SMS programs fail early because safety responsibility is assigned without authority or visibility. A safety manager may be named, but leadership remains disengaged. Over time, hazard reports slow down, risk assessments become routine, and the system loses credibility.

Establishing governance first avoids this pattern and supports the intent described in What Is a Safety Management System in Business Aviation?

Defining the Accountable Executive Role

The Accountable Executive is the cornerstone of SMS governance. This role is not symbolic. It carries specific expectations under Part 5 and Annex 19.

The Accountable Executive must:

• Be accountable for SMS performance

• Have authority to allocate resources

• Approve risk acceptance decisions

• Ensure corrective actions are implemented

In a Part 91 operation, this may be the aircraft owner or senior corporate executive. In Part 135 operations, it is often the Director of Operations or Chief Executive. In Part 145 repair stations, it may be the accountable manager listed in the repair station certificate.

Documenting this role early avoids confusion later when risk decisions arise or audits occur.

Establishing Safety Roles and Responsibilities

Once the Accountable Executive is identified, the next task is defining supporting safety roles. This does not require a large team or full time safety staff.

Typical roles include:

• Safety Manager or Safety Officer

• Department level safety points of contact

• Safety committee members if applicable

Each role should have a clear purpose and defined authority. Avoid generic titles without responsibilities. Auditors frequently look for alignment between documented roles and actual practices, a topic discussed in What Auditors Look for in an SMS Program.

Creating the Initial Safety Policy Statement

The safety policy statement is often treated as a formality, but it serves a practical purpose. It communicates management intent and sets expectations for how safety decisions will be made.

An effective safety policy:

• Is signed by the Accountable Executive

• Describes the organization’s commitment to safety

• Supports non punitive hazard reporting

• Aligns with operational realities

This policy does not need to be lengthy or aspirational. Clear language that reflects how the organization operates is more effective than generic statements copied from templates.

How This Applies Across Different Regulatory Parts

Part 91 Operators

For Part 91 operators, SMS is typically voluntary. However, insurers, corporate oversight groups, and international authorities increasingly expect structured safety programs. Governance clarity demonstrates maturity even in non mandated environments.

Part 135 Operators

Part 135 operators face a defined SMS implementation timeline. Governance must align with certificate management roles and operational control. Starting with accountability helps avoid later findings related to authority and resource allocation.

Part 145 Repair Stations

Part 145 SMS requirements emphasize integration with quality systems. Clear governance ensures that safety risk management complements existing processes rather than duplicating them. This distinction is explored in SMS Requirements for Part 145 Repair Stations Explained.

Common Mistakes When Starting an SMS Program

Many operators make similar mistakes early in SMS implementation:

• Starting with software selection before defining processes

• Assigning safety responsibility without authority

• Writing procedures before understanding operational risk

• Treating SMS as a documentation project

These missteps often result in fragmented systems that require restructuring later. Addressing governance first reduces these risks.

What Good Looks Like When Governance Is Done Correctly

When SMS governance is established correctly:

• Leadership understands its role in safety decisions

• Safety managers have defined authority and access

• Risk acceptance is consistent across departments

• Safety discussions are routine and structured

Auditors and regulators can quickly see alignment between policy, practice, and decision making. More importantly, the SMS supports real operational decisions rather than existing only on paper.

When to Move Beyond Governance to the Next Steps

Once governance is in place, operators can move to defining safety risk management processes. This includes hazard identification, risk assessment, and mitigation tracking. A structured sequence is outlined in Step-by-Step Guide to Building an SMS for Business Aviation.

Starting with governance does not delay implementation. It accelerates it by preventing misalignment later.

How Technology Supports Early SMS Implementation

Modern SMS platforms can support governance by:

• Documenting roles and responsibilities

• Managing policy approvals and revisions

• Tracking risk acceptance authority

• Providing visibility into safety performance

Technology does not replace leadership involvement. It supports consistency, traceability, and accountability once the foundational decisions are made.

Summary

What to do first when starting an SMS program is often misunderstood. The first step is establishing safety accountability and governance. This aligns with FAA Part 5 and ICAO Annex 19 expectations and provides the structure that all other SMS elements depend on.

By clearly defining leadership responsibility, safety roles, and policy intent, business aviation operators create an SMS that supports real world operations. From this foundation, risk management, assurance, and promotion activities can be built in a controlled and effective way. Starting correctly reduces rework, improves credibility, and supports long term safety performance.