I fly one aircraft. Does Part 5 still apply?

Yes. Part 5 applies to the certificate or the authorization, not to fleet size. What scales with your operation is how elaborate the system needs to be — the regulation expects processes proportionate to the size, scope and complexity of what you do.

I only do air tours under 91.147. Am I in scope?

Yes, and this is the group most often caught out. The 91.147 letter of authorization is itself a trigger for Part 5.

Does an SMS manual by itself make me compliant?

No. The manual describes the system; compliance is demonstrated by the records the system produces. A manual with nothing behind it is the most common failure.

What happens if I miss 28 May 2027?

You would be operating without a required program, which is an enforcement matter between you and your certificate-holding district office. Talk to your principal inspector early rather than late.

Does 14 CFR Part 5 apply to me?

Yes, if you hold a Part 135 certificate or fly 91.147 air tours. One aircraft counts, and a working SMS is due by 28 May 2027.

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SquawkSMS in 30 seconds: hazard report, risk, fix, closed.

We fly commercial air tours over Las Vegas every day, and we have the same 28 May 2027 deadline as everyone else. SquawkSMS is how we run our own SMS: a pilot or ground crew member files a squawk from their phone in a minute, and the records an inspector will ask for build up as we work.

James McPhail, Owner · Skyline Helicopter Tours, Las Vegas.

Who is covered

The FAA extended safety management system requirements beyond Part 121. The two categories that account for most small operators are:

Part 135 certificate holders — commuter and on-demand operators. One aircraft counts. There is no small-operator exemption.
91.147 commercial air tour operators — holders of a letter of authorization for air tours. This catches operators who have never held a 135 certificate and who often do not expect to be in scope at all.

A Part 145 repair station certificate, by itself, does not bring you under Part 5.

Every week you start earlier is a week of records you can show. SquawkSMS starts logging hazards, risk assessments and training on day one.

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What "having an SMS" actually means

Part 5 defines four components, and all four have to exist and be used. A manual on a shelf satisfies none of them.

Safety policy § 5.21 – 5.27

A signed policy, an accountable executive, and a reporting system crews can use without fear of reprisal.

Safety risk management § 5.51 – 5.55

Find hazards, assess the risk, decide controls, and confirm they worked.

Safety assurance § 5.71 – 5.75

Audits, safety measures, and corrective actions tracked to closed.

Safety promotion § 5.91 – 5.93

Training for every role, and telling people what came of their reports.

What the FAA will expect to see

In practice, an inspector asks for evidence rather than intentions:

Hazard reports, and what happened to each one.
Risk assessments with the reasoning visible, not just a score.
Corrective actions closed out, with verification that they worked.
Training records for the people currently employed.
Records retained for the periods your manual states § 5.97.

Where SquawkSMS fits

SquawkSMS records every item on that list as your people work.

SquawkSMS · everything included

$149 / month after 10 days free

Hazard reports, risk assessment, corrective actions and sign-off
Flight risk assessment (FRAT) for every pilot
Audits, training records and document control
Unlimited aircraft and users. No card to start, no contract.

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Your SMS manual, included. Start your plan by 31 December 2026 and we write your SMS manual and Declaration of Compliance at no extra charge (~~$995~~ free), unlocked after your first monthly payment.

Questions operators actually ask

I fly one aircraft. Does Part 5 still apply?: Yes. Part 5 applies to the certificate or the authorization, not to fleet size. What scales with your operation is how elaborate the system needs to be — the regulation expects processes proportionate to the size, scope and complexity of what you do.
I only do air tours under 91.147. Am I in scope?: Yes, and this is the group most often caught out. The 91.147 letter of authorization is itself a trigger for Part 5.
Does an SMS manual by itself make me compliant?: No. The manual describes the system; compliance is demonstrated by the records the system produces. A manual with nothing behind it is the most common failure.
What happens if I miss 28 May 2027?: You would be operating without a required program, which is an enforcement matter between you and your certificate-holding district office. Talk to your principal inspector early rather than late — that conversation goes better before the date than after it.

SquawkSMS is the system, the records and the paperwork.

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All you need to start is your company name.

This page is written for operators trying to work out where they stand. It is general information about a published regulation, not legal advice, and it is not an FAA publication — SquawkSMS is not affiliated with the FAA and files nothing on your behalf. Your principal inspector is the authority on how Part 5 applies to your certificate.