Why Consultants Are Moving Away from Manual SMS Systems

Why Consultants Are Moving Away from Manual SMS Systems is a question that comes up increasingly often in business aviation safety discussions. The short answer is that manual systems struggle to support the scale, consistency, and trace what auditors look for in an SMS program

expected of a modern Safety Management System in business aviation. Consultants working across multiple operators are encountering the same structural limitations repeatedly, regardless of operation size or regulatory scope.

Manual SMS systems, typically built on spreadsheets, shared drives, and static documents, can meet basic documentation needs. However, as SMS expectations under FAA 14 CFR Part 5 and ICAO Annex 19 have matured, consultants are finding that manual approaches make it difficult to sustain effective risk management, safety assurance, and continuous improvement over time. This shift is less about preference and more about practical realities observed during implementation, audits, and ongoing program oversight.

What Is a Manual SMS System?

A manual SMS system relies primarily on non-integrated tools. These usually include word processing documents for policies and manuals, spreadsheets for hazard logs and risk registers, email for reporting and follow-up, and file storage systems for recordkeeping. Oversight and analysis are largely dependent on human effort, memory, and periodic review.

In many operations, these systems were initially built by consultants to help operators comply with early SMS guidance or prepare for specific audits. While functional at a basic level, manual systems often lack structured workflows, automated controls, and real-time visibility into safety data.

Why This Matters in a Safety Management System in Business Aviation

Business aviation presents unique SMS challenges. Operations are often lean, distributed across locations, and reliant on personnel who perform multiple roles. Safety managers may not be dedicated full time to SMS oversight, especially in Part 91 and smaller Part 135 environments. Consultants frequently fill this gap by designing systems, providing oversight, and supporting audits.

In this context, manual systems place a disproportionate burden on individuals to maintain compliance and situational awareness. Consultants increasingly report that the effort required to keep manual systems current and defensible exceeds the value they provide, especially as regulatory expectations emphasize data-driven decision-making.

How Regulatory Expectations Have Evolved

FAA 14 CFR Part 5 emphasizes ongoing processes rather than static compliance. Elements such as hazard identification, risk assessment, safety assurance, and management of change require continuous activity and documented follow-through. ICAO Annex 19 reinforces these expectations by framing SMS as a living system that must be monitored, measured, and adjusted.

Consultants working across Part 91, Part 135, and Part 145 operators observe that inspectors and auditors are less focused on whether a document exists and more focused on how effectively the system operates. Manual tools often make it difficult to demonstrate that hazards are tracked to closure, mitigations are verified, and lessons learned are incorporated back into operations.

Where Manual SMS Systems Break Down in Practice

Hazard Reporting and Tracking

In manual systems, hazard reporting often relies on email or paper forms. This creates delays, incomplete data, and inconsistent follow-up. Consultants frequently encounter hazard logs that are outdated or lack clear linkage between the reported issue, the risk assessment, and the corrective action.

Over time, this undermines the intent of hazard identification within a Safety Management System in business aviation. Hazards become entries in a spreadsheet rather than inputs to an active risk management process. This issue is commonly discussed in guidance on what makes a good hazard report in aviation.

Risk Assessment Consistency

Manual risk matrices can be applied inconsistently, especially when multiple people assess hazards. Consultants may find that severity and likelihood definitions drift over time or are interpreted differently across departments. Without built-in controls, it becomes difficult to ensure consistent application of risk criteria.

This inconsistency complicates audit preparation and weakens confidence in the operator’s risk profile. It also makes it harder to identify trends or systemic risk patterns across the operation.

Safety Assurance and Follow-Up

Safety assurance activities, such as internal audits, investigations, and performance monitoring, require reliable tracking. Manual systems often rely on calendar reminders or individual follow-up to ensure actions are completed.

Consultants report that corrective actions are frequently closed administratively without evidence of effectiveness. This creates gaps when auditors review how findings are managed, a topic often addressed in discussions about what auditors look for in an SMS program.

Common Misunderstandings About Manual Systems

A frequent misconception is that manual systems are sufficient for smaller operations. While scale does matter, complexity often grows faster than headcount. Even a small Part 135 operator may manage diverse aircraft types, contract maintenance providers, and varying mission profiles.

Another misunderstanding is that manual SMS is required for Part 135 operators

demonstrate greater customization. In practice, consultants often see highly customized documents that are poorly aligned with day-to-day operations. This disconnect makes the SMS harder to use and maintain.

How This Affects Consultants Directly

Consultants are responsible for designing, maintaining, and defending SMS programs across multiple clients. Manual systems increase administrative workload and reduce the consultant’s ability to focus on higher-value activities such as safety analysis and strategic risk management.

As consultants support more operators, they also need consistent frameworks that scale. Rebuilding or heavily modifying manual systems for each client is inefficient and increases the risk of errors. This reality is a key driver behind the move away from manual SMS approaches.

Differences Across Regulatory Scopes

Part 91 Operations

Part 91 operators often adopt SMS voluntarily. Consultants supporting these operators focus on proportional implementation. Manual systems may work initially, but sustaining engagement and visibility over time remains a challenge, particularly as operations grow or diversify.

Part 135 Operators

For Part 135 operators, SMS requirements are more explicit. Consultants note that manual systems struggle to keep pace with the volume of reports, training records, and assurance activities required. This is especially true as operators approach certification milestones or fleet expansion, a topic often explored when discussing when SMS is required for Part 135 operators.

Part 145 Repair Stations

In Part 145 environments, SMS must integrate closely with quality systems and maintenance processes. Manual tools make it difficult to link hazards, human factors, and corrective actions across departments. Consultants supporting repair stations increasingly look for structured systems that align safety and quality data, as discussed in SMS requirements for Part 145 repair stations explained.

What “Good” Looks Like When Implemented Correctly

A well-functioning Safety Management System in business aviation provides clear visibility into hazards, risks, and mitigations. Information flows predictably from reporting to analysis to action. Roles and responsibilities are clearly defined, and leadership can see how safety performance is trending over time.

Consultants describe effective systems as those where data supports decision-making rather than being an administrative byproduct. These systems make it easier to demonstrate compliance, identify emerging risks, and support continuous improvement.

How Technology Supports This Area of SMS

Technology plays a supporting role by structuring workflows, standardizing data, and improving traceability. Modern SMS platforms can help ensure hazards are captured consistently, risk assessments follow defined criteria, and corrective actions are tracked to completion.

For consultants, technology reduces administrative burden and enables more consistent implementation across clients. It also supports the analytical aspects of SMS, such as trend analysis and performance monitoring, without relying on manual aggregation. This aligns closely with discussions on how SMS helps identify systemic risk patterns and what to look for in aviation SMS software.

A Forward-Looking Perspective

The move away from manual SMS systems reflects a broader maturation of SMS practice in business aviation. As regulatory expectations emphasize effectiveness and continuous improvement, consultants are adapting their approaches accordingly.

Manual systems may still serve as transitional tools, but they are increasingly viewed as insufficient for long-term SMS sustainability. By focusing on structured processes, clear data flows, and scalable oversight, consultants are helping operators build Safety Management Systems that better align with both regulatory intent and operational reality.