Part 135 safety policy: what the document must contain and how to write it

The safety policy is the first pillar of 14 CFR Part 5 Safety Management System. It is also the document most operators produce first and update least. A safety policy that was written for certification, signed, laminated, and forgotten is not a functioning SMS foundation — it is a document that will be cited in a finding.

The FAA's requirements for safety policy content are stated in 14 CFR 5.21. They are more specific than most operators realize.

What 14 CFR 5.21 requires

Under Part 5.21, the safety policy must be signed by the accountable executive and must define:

• The safety objectives of the organization
• The management's commitment to safety
• The commitment to provide appropriate resources for SMS implementation
• A commitment to managing safety as a core value — not a priority that can be traded against schedule or cost
• The Safety Manager's authority and responsibility
• The commitment to a reporting system that is non-punitive for good-faith reports
• A commitment to continuous improvement of the SMS

The policy must be communicated throughout the organization — not just available on request, but actively distributed and acknowledged by all personnel.

Content template for Part 135 on-demand charter

The following structure covers the required elements. Each section should be specific to the operator — generic language that could apply to any aviation company is a red flag in an audit. Replace every bracketed item with your organization's actual details.

1. Policy statement

One to two paragraphs signed by the accountable executive (typically the President or CEO of the certificate holder). Should state:

• The organization's commitment to safety as its highest operating priority
• That safety will not be compromised for schedule, cost, or competitive pressure
• That the accountable executive holds personal responsibility for the safety program
• The date of the policy and the revision cycle (annual review minimum)

Example language (adapt, do not copy verbatim):

"[Operator Name] is committed to conducting all flight operations with the highest level of safety. The management of this organization regards safety as a core organizational value — not a priority that competes with operational or commercial objectives. We commit to providing the resources, training, and organizational support necessary to implement and continuously improve our Safety Management System in accordance with 14 CFR Part 5."

2. Safety objectives

Three to five specific, measurable safety objectives for the current year. These must be actual objectives the organization intends to track — not aspirational statements. Examples:

• Maintain a corrective action closure rate of 90% or greater within 30 days of opening
• Conduct safety meetings quarterly at minimum, with attendance documented
• Achieve zero crew currency UNABLE dispatches due to expired training records (i.e., currency tracked proactively)
• Complete FRAT assessment for 100% of flights with score and band documented
• Respond to all hazard reports within 24 hours with a documented disposition

3. Roles and responsibilities

Name the following roles explicitly:

• Accountable Executive. [Name, title]. Holds overall responsibility for the SMS program. Signs and annually reviews the safety policy.
• Safety Manager. [Name, title]. Responsible for day-to-day SMS administration, hazard report processing, corrective action tracking, safety meeting facilitation, and safety promotion activities. Reports directly to the Accountable Executive on safety matters.
• Director of Operations. [Name]. Responsible for implementing safety requirements in operational planning and crew management.
• Director of Maintenance. [Name]. Responsible for implementing safety requirements in maintenance activities and MEL management.
• All personnel. Responsible for reporting hazards, participating in safety training, and complying with safety procedures.

In small operations, the Safety Manager is often the DO or the Chief Pilot. This is acceptable — what matters is that the role is named and the responsibilities are defined, not that it is a separate headcount.

4. Just culture commitment

A specific, unambiguous statement that personnel who report hazards, near-misses, or errors in good faith will not face punitive action as a result of the report. This commitment must cover:

• Voluntary, good-faith reports of inadvertent errors or unsafe conditions
• Reports made through the organization's safety reporting system
• The distinction between good-faith reports (protected) and willful violations or gross negligence (not protected)

5. Resources commitment

A statement that the organization commits to providing adequate resources for SMS implementation — including time for safety meetings, access to training materials, and the authority for the Safety Manager to act on safety findings. This does not need to specify a budget number, but it must indicate that resources will not be withheld as an excuse for non-compliance.

6. Continuous improvement commitment

A statement that the SMS will be reviewed at least annually, that safety objectives will be updated based on performance, and that the organization will use safety data (hazard reports, corrective action trends, FRAT distribution, incident data) to drive improvement.

Format and distribution

The safety policy should be:

• One to two pages — long enough to cover all required elements, short enough to be read
• Signed and dated by the accountable executive
• Posted in the crew room and the dispatch area
• Included in new employee orientation and acknowledged in writing by each new hire
• Reviewed and re-signed annually — the date matters; a policy last signed three years ago signals an organization that has not reviewed its safety commitments recently

What the FAA looks for in an audit

An FSDO SMS audit will pull the safety policy and ask three questions:

1. Does it contain all required elements under 5.21?
2. Is it current — signed within the last 12 months?
3. Is there evidence it has been communicated — acknowledgment signatures, meeting records, orientation documentation?

A policy that passes all three is not the goal — it is the floor. The policy is the foundation of the SMS. The goal is an organization where the commitments in the policy are reflected in how decisions are actually made. An auditor who reads a commitment to non-punitive reporting and then talks to a crew member who says "we don't really report things" has found the real finding.