Why Safety Culture Can’t Be Mandated

Safety culture is frequently discussed in aviation, often referenced in audit findings, management meetings, and training sessions. It is also commonly misunderstood. Many operators assume that once policies are written, procedures are approved, and training is completed, a strong safety culture will naturally follow. In practice, that rarely happens. This is why safety culture cannot be mandated.

In business aviation, safety culture develops through consistent leadership behavior, operational decision-making, and the way safety concerns are handled over time. A Safety Management System in business aviation provides the structure to support safety culture, but it does not create culture by itself. Regulations can require processes and accountability, but they cannot force trust, openness, or professional judgment.

Understanding why safety culture cannot be mandated is critical for Safety Managers, Accountable Executives, and operational leaders who are responsible for implementing and sustaining an effective SMS.

What Is Safety Culture in an Aviation Context

Safety culture refers to the shared values, beliefs, and behaviors that determine how an organization manages safety risks during normal operations and abnormal situations. In aviation, it is reflected in how personnel report hazards, how management responds to those reports, and how operational pressure is balanced against safety considerations.

A strong safety culture does not mean an absence of risk or incidents. Instead, it means the organization recognizes risk early, discusses it openly, and takes appropriate action before minor issues become serious events.

In a Safety Management System in business aviation, safety culture is the environment in which the four pillars of SMS operate. Without that environment, SMS processes often exist only on paper.

What Regulations Can and Cannot Do

FAA 14 CFR Part 5 establishes requirements for implementing a Safety Management System. It defines expectations for hazard identification, risk management, safety assurance, and safety promotion. ICAO Annex 19 reinforces these principles at the international level and emphasizes the role of management commitment and employee involvement.

However, neither Part 5 nor Annex 19 attempts to define or mandate safety culture directly. Instead, they require organizations to establish processes that encourage safe behavior and informed decision-making.

Regulations can require:

• A reporting system

• Defined safety responsibilities

• Risk assessment processes

• Internal evaluation and assurance activities

Regulations cannot require:

• Employees to trust management

• Personnel to report concerns honestly

• Leaders to consistently prioritize safety under pressure

• Operational staff to believe reporting will lead to improvement rather than punishment

This distinction is intentional and important.

Why This Matters in Business Aviation

Business aviation operations often involve small teams, close working relationships, and decentralized decision-making. Pilots, maintenance personnel, dispatchers, and managers may interact daily and wear multiple roles. In this environment, culture has a direct and immediate effect on safety outcomes.

For example:

• In a Part 91 flight department, a weak safety culture may discourage a pilot from questioning an unrealistic schedule.

• In a Part 135 operation, it may prevent a mechanic from reporting a procedural shortcut.

• In a Part 145 repair station, it may lead to underreporting of human factors issues during heavy maintenance.

A Safety Management System in business aviation must account for these realities. Culture determines whether the system is used as intended or treated as a compliance exercise.

How Safety Culture Actually Develops

Safety culture develops through repeated actions and decisions, not policy statements. It is shaped by how leadership behaves when safety issues arise and how the organization responds to uncomfortable information.

Several factors consistently influence safety culture:

• Leadership credibility and consistency

• Transparency in decision-making

• Fair and predictable responses to errors

• Practical alignment between procedures and real-world operations

When management responds to reported hazards with defensiveness or inaction, reporting declines. When safety concerns are acknowledged and addressed, reporting improves. Over time, these patterns become cultural norms.

Common Misunderstandings About Safety Culture

“If We Train It, We Have It”

Training is necessary but insufficient. Safety training can explain expectations, but it does not guarantee behavior. Personnel quickly recognize whether training messages align with actual management priorities.

If training emphasizes conservative decision-making but performance evaluations reward schedule completion at all costs, the message is clear.

“Culture Is a Soft Concept”

Safety culture is often dismissed as subjective. In reality, it produces observable outcomes. Reporting rates, repeat findings, risk acceptance patterns, and audit results all provide insight into cultural health.

Auditors frequently assess culture indirectly by examining how hazards are identified, tracked, and resolved. This is explored further in discussions about what auditors look for in an SMS program.

“Culture Belongs to the Safety Manager”

Safety culture is not owned by the Safety Manager. It is established by leadership and reinforced across all levels of the organization. When safety is viewed as a separate function rather than an operational responsibility, culture suffers.

Practical Examples from Real Operations

Consider a flight crew that submits a hazard report about fatigue risk related to scheduling practices. If the report is acknowledged, assessed, and leads to a meaningful discussion or change, trust is reinforced.

If the report is ignored or results in negative attention toward the reporter, future reports will likely stop. The reporting system still exists, but the culture supporting it does not.

Similarly, a maintenance team may recognize that a procedure does not reflect actual workflow. If management invites feedback and updates the procedure, the system improves. If management insists the procedure is followed exactly despite known issues, personnel may quietly deviate without reporting.

These examples illustrate why safety culture cannot be mandated. It is experienced, not declared.

What Good Looks Like When It Works

In organizations with a healthy safety culture:

• Personnel understand why SMS processes exist

• Hazard reporting is routine and professional

• Management decisions are explainable and consistent

• Safety data is used to improve operations, not assign blame

Importantly, good safety culture does not eliminate accountability. It distinguishes between acceptable errors, at-risk behavior, and intentional violations. This balance supports learning while maintaining standards.

A Safety Management System in business aviation works best when culture supports open communication and disciplined follow-through.

Differences Across Part 91, 135, and 145 Operations

The regulatory requirements differ across operational types, but the cultural principles remain consistent.

• Part 91 operators may have more flexibility but fewer formal structures, making leadership behavior even more influential.

• Part 135 operators operate under defined SMS requirements, where culture determines whether compliance adds value.

• Part 145 repair stations rely heavily on human performance and procedural discipline, making trust and reporting essential.

Understanding how SMS applies differently to Part 91, Part 135, and Part 145 operators helps clarify why culture must be adapted, not imposed.

How Technology Supports Safety Culture

Technology cannot create safety culture, but it can support it when implemented thoughtfully. Modern SMS platforms can make reporting easier, improve visibility into risk trends, and reduce administrative friction.

When tools are intuitive and accessible:

• Reporting becomes part of normal work

• Follow-up actions are more transparent

• Safety data is easier to discuss objectively

Technology supports consistency and accountability, which reinforces cultural expectations. However, tools only amplify existing behaviors. They do not replace leadership judgment or interpersonal trust.

Looking Forward

Safety culture remains one of the most important and least understood aspects of aviation safety. It cannot be mandated because it depends on human behavior, organizational trust, and leadership integrity.

A Safety Management System in business aviation provides the framework to support safety culture, but culture determines whether that framework delivers real value. Operators who recognize this distinction are better positioned to manage risk effectively and sustain long-term safety performance.