What to Do When the Same Hazards Keep Appearing

When the same hazards keep appearing in a Safety Management System in business aviation, the issue is rarely the hazard itself. Repeated hazards are usually a signal that the organization is treating symptoms rather than addressing underlying conditions. This is a common challenge for operators at every level, from small Part 91 flight departments to complex Part 135 and Part 145 organizations.

The purpose of a Safety Management System is not to eliminate all hazards. Aviation will always involve risk. The purpose is to identify hazards early, understand why they exist, and manage risk in a way that prevents accidents and serious incidents. When hazards recur, it indicates that risk controls are either ineffective, incomplete, or misaligned with real-world operations.

This article explains what repeated hazards mean, why they matter in business aviation, and what operators should do when the same issues continue to surface despite corrective action.

What does it mean when hazards keep recurring?

A recurring hazard is one that is reported multiple times over a defined period, often with similar descriptions, locations, operational phases, or contributing factors. Examples include repeated reports of unstable approaches at the same airport, recurring maintenance documentation errors, or ongoing fatigue-related concerns among flight crews.

In an effective Safety Management System in business aviation, hazard reports are expected to decrease in severity over time for known issues. The total number of reports may remain steady or even increase as reporting culture improves, but the underlying risk profile should change. When it does not, the SMS is providing visibility without resolution.

Recurring hazards typically indicate one or more of the following conditions:

• The hazard has been misclassified or oversimplified

• The root cause has not been correctly identified

• The mitigation addresses behavior rather than system design

• The risk controls exist on paper but not in practice

• Operational changes have outpaced the SMS

Understanding which of these conditions applies is the first step toward meaningful improvement.

Why recurring hazards matter in business aviation

Business aviation operations are often lean by design. Crews may operate across multiple aircraft, bases, and mission profiles. Maintenance and management staff frequently perform multiple roles. This flexibility is a strength, but it also increases exposure to systemic risk when processes are unclear or controls are inconsistent.

Under FAA 14 CFR Part 5, operators are expected to identify hazards, assess risk, implement controls, and verify that those controls are effective. Repeated hazards directly challenge the effectiveness requirement. From a regulatory and audit perspective, recurring issues suggest that the SMS is reactive rather than predictive.

For Part 135 operators, this can raise concerns during certification, surveillance, or renewal activities. For Part 145 repair stations, repeated hazards related to human factors or procedural compliance can indicate gaps in training, tooling, or workload management. Even for voluntary Part 91 SMS programs, recurring hazards undermine leadership confidence and reduce trust in the system.

In practical terms, unresolved hazards also increase operational variability. Crews and technicians begin to develop workarounds. Local practices replace standardized procedures. Over time, this erodes safety margins and normalizes deviation.

Are recurring hazards a failure of reporting?

One common misunderstanding is that repeated hazards mean employees are not learning or are ignoring guidance. In most cases, the opposite is true. Repeated reporting often reflects a healthy reporting culture. Personnel are noticing the issue, taking the time to report it, and trusting that the system will respond.

This distinction is critical. A high volume of similar reports does not indicate failure. It indicates data. The failure occurs when the organization treats each report as an isolated event instead of evidence of a broader pattern.

This is where many operators benefit from revisiting foundational concepts described in explanations of what a Safety Management System in business aviation is intended to do. SMS is not a collection of forms. It is a structured way to understand how work actually happens.

How to determine whether a hazard is truly systemic

Before taking corrective action, safety managers should confirm whether the hazard is truly recurring or simply appears that way due to reporting detail. This requires looking beyond titles and categories.

Key questions to ask include:

• Are the reports occurring during the same phase of operation?

• Do they involve the same locations, equipment, or conditions?

• Are the same contributing factors listed repeatedly?

• Do mitigations close without measurable change in outcomes?

Trend analysis is essential at this stage. Modern SMS software can support this by grouping hazards across time, departments, and operational contexts. However, technology only supports the analysis. Human judgment determines what the data means.

When patterns persist across different reporters and time periods, the hazard should be treated as systemic rather than individual.

Common reasons mitigations fail to stop recurrence

Many recurring hazards persist because mitigations are designed to be easy rather than effective. The most common failure modes include the following.

Treating training as the default solution

Training is important, but it is often overused. When a hazard recurs, adding a briefing or refresher course may improve awareness without changing conditions. If crews already understand the procedure but cannot consistently comply due to workload, time pressure, or unclear guidance, training will not resolve the issue.

Addressing behavior instead of system design

Statements such as “remind crews to be more vigilant” or “ensure technicians follow procedures” focus on outcomes rather than causes. Effective mitigations address why the behavior occurs, not simply that it occurs.

Closing hazards without validation

Under Part 5 principles, mitigations must be verified for effectiveness. Closing a hazard because an action was assigned or acknowledged does not meet this expectation. Verification requires evidence that the risk has changed.

Failing to update risk assessments

Some operators assess risk once and never revisit it. When hazards recur, the original severity or likelihood assumptions may no longer be valid. Risk assessments should evolve as operational data accumulates.

What good hazard management looks like when issues persist

In a mature Safety Management System in business aviation, recurring hazards trigger a deeper level of review. This often includes a structured reassessment process that may resemble a focused internal evaluation.

Effective responses typically involve:

• Reframing the hazard at a higher system level

• Identifying latent conditions rather than active failures

• Engaging operational personnel in solution design

• Implementing controls that change how work is done

• Measuring outcomes over time, not just completion

For example, repeated reports of unstable approaches may initially be classified as pilot technique issues. A deeper review might reveal scheduling practices that increase fatigue, airport-specific constraints, or procedural ambiguity during high workload phases. Addressing these factors is more complex but far more effective.

These practices align closely with concepts discussed in explanations of how SMS helps identify systemic risk patterns, where the emphasis is on trend analysis rather than individual events.

How expectations differ across Part 91, 135, and 145 operations

The approach to recurring hazards should be scaled to the operation, but the underlying principles remain consistent.

Part 91 operators often rely on voluntary reporting and informal communication. When hazards repeat, leadership involvement becomes especially important, as formal enforcement mechanisms may be limited. The SMS must still demonstrate learning and adaptation.

Part 135 operators are expected to show documented evidence that hazards are analyzed and mitigated effectively. Recurring hazards without demonstrable improvement can become findings during FAA oversight activities.

Part 145 repair stations face unique challenges related to human factors, shift turnover, and task interruption. Repeated hazards in these environments often point to workload management, tooling availability, or documentation design rather than individual performance.

Understanding how SMS applies differently across operational types is essential when designing responses that are both effective and proportionate.

How technology supports managing recurring hazards

Technology plays a supporting role in addressing repeated hazards, but it is not a solution by itself. Modern SMS platforms can help by:

• Aggregating hazard data across time and departments

• Highlighting trends that may not be obvious from individual reports

• Linking hazards to risk assessments, mitigations, and outcomes

• Supporting verification through follow-up tracking

The value of technology lies in visibility and consistency. It reduces reliance on memory, spreadsheets, or informal tracking. However, the quality of analysis and decision-making still depends on the safety manager and leadership team.

Operators evaluating tools often benefit from understanding what auditors look for in an SMS program, particularly how recurring issues are identified and addressed.

Common mistakes to avoid when hazards repeat

Several pitfalls consistently undermine efforts to resolve recurring hazards.

One is normalizing recurrence. When the same issues appear for years, organizations may accept them as unavoidable. This erodes the purpose of the SMS.

Another is overcorrecting. Implementing overly restrictive controls can create new hazards or reduce operational flexibility without improving safety.

A third is failing to communicate outcomes. When employees continue to report hazards but never see evidence of improvement, reporting motivation declines.

Avoiding these mistakes requires discipline, transparency, and a willingness to question existing assumptions.

What effective resolution looks like over time

When recurring hazards are managed effectively, several indicators become visible:

• Hazard reports evolve in focus rather than repeating verbatim

• Risk levels decrease or stabilize at acceptable levels

• Mitigations are adjusted based on feedback and data

• Operational personnel describe fewer workarounds

• Leadership discussions shift from reaction to anticipation

Importantly, success does not mean hazards disappear entirely. It means the organization demonstrates learning and control. This is the standard expected under both FAA Part 5 and ICAO Annex 19 frameworks.

A forward-looking perspective on recurring hazards

Recurring hazards are not a sign that an SMS is failing. They are a sign that the system is revealing where attention is needed most. The real measure of effectiveness is how the organization responds.

In a Safety Management System in business aviation, repeated hazards should prompt deeper analysis, stronger engagement with operations, and more thoughtful system design. Over time, this approach builds resilience and trust, which are far more valuable than the appearance of low report counts.

Operators that treat recurring hazards as opportunities to improve systems rather than correct people are the ones that see lasting safety gains.