No, a Part 135 operator is not legally required to have a position titled “Director of Safety.” 14 CFR §5.25 requires two SMS roles: an accountable executive (§5.25(a)) with final authority and ultimate responsibility for safety, and — for operations that are not single-pilot — sufficient management personnel (§5.25(c)) designated to administer the SMS. “Director of Safety” and “Safety Manager” are common job titles for that §5.25(c) role, but the title is your choice, not a regulation. A Director of Safety is also not one of the management positions §119.71 requires (those are Director of Operations, Chief Pilot, and Director of Maintenance). At a small operator, the owner can serve as both the accountable executive and the SMS management person — and a true single-pilot operator is exempt from §5.25(c) entirely. The same May 28, 2027 deadline applies regardless.
If you searched “part 135 director of safety” or “does part 135 need a director of safety,” you have probably already found a dozen pages that talk about a Director of Safety as if the title were in the regulation. It is not. The confusion is understandable — “Director of Safety” is genuinely the most common job title operators give to their SMS person — but conflating a job title with a regulatory requirement leads small operators to think they have to hire someone they may not need, or to miss the role they actually are required to designate. This page fixes that, using the literal text of 14 CFR Part 5.
What the SMS Rule Actually Requires: Two Roles, Named in §5.25
14 CFR §5.25 is titled “Designation and responsibilities of required safety management personnel,” and it creates exactly two roles. Neither is called “Director of Safety.” Here is what each one is, in the regulation's own structure.
The Accountable Executive
14 CFR §5.25(a)Every operator with an SMS must identify a single accountable executive. This is the person who owns safety at the top. Per §5.25(a), the accountable executive must be someone who:
- Is the final authority over operations conducted under the certificate(s) or Letter(s) of Authorization
- Controls the financial resources required for the authorized operations
- Controls the human resources required for the authorized operations
- Retains ultimate responsibility for the safety performance of the operations
Under §5.25(b), the accountable executive must also ensure the SMS is properly implemented, develop and sign the safety policy, communicate it throughout the organization, regularly review it, and review safety performance and direct corrective action.
Designated Management Personnel (the “Safety Manager” / “Director of Safety” role)
14 CFR §5.25(c)§5.25(c) says the accountable executive must “designate sufficient management personnel” who, on the executive's behalf, actually run the SMS. The regulation does not name this position “Director of Safety” or “Safety Manager” — those are the job titles industry uses. What §5.25(c) does is list the duties:
Coordinate the SMS organization-wide
§5.25(c)(1)Coordinate the implementation, maintenance, and integration of the SMS throughout the operation — the connective tissue that keeps safety policy, risk management, assurance, and promotion working together.
Facilitate hazard identification & risk analysis
§5.25(c)(2)Run the process that surfaces hazards and analyzes safety risk (likelihood and severity) for new systems, changed systems, and new operational procedures.
Monitor the effectiveness of safety risk controls
§5.25(c)(3)Confirm the controls you put in place are actually working — and feed what you learn back into the risk-management process when they are not.
Ensure safety promotion
§5.25(c)(4)Make sure SMS training and safety communication happen across the workforce per subpart E — so the people who operate the SMS know how to do their part.
Report SMS performance to the accountable executive
§5.25(c)(5)Regularly report up to the accountable executive on how the SMS is performing — the feedback loop that lets the AE direct corrective action under §5.75.
The FAA “Director of Safety” qualification summary is guidance — not a Part 5 mandate
You may see references to an FAA Director of Safety qualification summary. That is FAA guidance describing what a capable safety leader should be able to do — it is a useful competency checklist, but it does not create a regulatory requirement to hold a position titled “Director of Safety” or set qualification minimums for it the way §119.71 does for the Director of Operations, Chief Pilot, and Director of Maintenance. Treat it as guidance, and design your role around the §5.25(c) duties.
Title vs. Role: Why “Director of Safety” Confuses Everyone
The cleanest way to think about it: Part 5 defines duties; you choose the title. The regulation requires that certain SMS functions get performed by a designated person. It is silent on what you call that person. “Director of Safety,” “Safety Manager,” “SMS Manager,” “Safety Officer” — all are legitimate titles for the §5.25(c) role, and the FAA does not care which you pick, as long as the duties are covered and documented.
| What people search / assume | What 14 CFR Part 5 actually says |
|---|---|
| "Part 135 requires a Director of Safety" | Part 5 requires designated management personnel (§5.25(c)); the title is the operator’s choice. |
| "The safety manager is a separate hire" | It can be a collateral duty; "sufficient" personnel is scaled to your operation, and the owner can hold it. |
| "Director of Safety is a required management position" | No — §119.71 requires Director of Operations, Chief Pilot, and Director of Maintenance. Not a Director of Safety. |
| "Single-pilot operators still need a safety manager" | No — §5.9(e) exempts true single-pilot operators from §5.25(c). |
| "The accountable executive and safety manager must be different people" | No — at a small operator the same person can be both; only the accountable-executive criteria (§5.25(a)) constrain who that is. |
This matters most for the operators the 2024 rule swept in for the first time. The FAA itself noted that a large share of Part 135 certificate holders run two or fewer aircraft. For those operators, reading “you need a Director of Safety” as “you need to hire a full-time safety executive” is both wrong and expensive. What you need is to designate someone — possibly yourself — who performs the §5.25(c) duties and keeps the records that prove it. See our companion guide on Part 135 required management personnel qualifications for how the §119.71 positions interact with the SMS roles.
Designating the role is step one — proving it is the part the FAA checks
Whoever you designate, your accountable-executive designation, signed safety policy, and SMS role assignments are documents an inspector will ask to see. FileFlo's free FAA readiness score takes 3 minutes and shows which SMS documentation gaps are most likely to surface in a Part 5 surveillance evaluation. No signup required. Free.
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Who Can Be the Safety Manager? (Yes, the Owner Counts)
One of the most common real-world questions — and one almost no ranking page answers cleanly — is “can the owner be the safety manager?” The answer is yes. Part 5 does not require the §5.25(c) role to be a different person from the accountable executive, and it does not require it to be a dedicated, full-time hire. Here is the appoint-vs-hire reality:
Appoint, don’t necessarily hire
The obligation is to designate someone. That can be an internal appointment — the owner, the director of operations, or the chief pilot taking the SMS role as a collateral duty.
One person can wear both hats
At a small operator, the accountable executive (§5.25(a)) and the SMS management person (§5.25(c)) can be the same individual. The roles are distinct; the people don’t have to be.
Scale up when capacity, not the rule, demands it
"Sufficient" personnel is the standard. When the operation outgrows what one part-time person can actually cover, a dedicated role becomes an audit-survival decision — not a new regulatory trigger.
The honest caveat: “can” is not always “should”
The regulation permits the owner to be the safety manager. Whether that is a good idea depends on honest capacity and independence. The §5.25(c) duties — running the reporting system, performing risk assessments, monitoring controls, keeping the records — take real time, and there is an inherent tension in the person with ultimate operational and financial authority also being the one auditing safety. Many operators start with the owner in the role and move to a dedicated or contracted safety manager as they grow. That is a quality and audit-survival judgment, and it is outside the scope of this compliance-document guide — talk to your FSDO and a qualified aviation safety professional.
Whatever you decide, the FAA does not take your word for who holds the role — it looks for the documentation of the designation. The accountable-executive designation, the signed safety policy (§5.25(b)), and the written assignment of SMS responsibilities are the records that prove your role structure exists. Those records sit alongside the rest of your required Part 135 records, and they are exactly what gets examined in a Part 135 surveillance evaluation.
Single-Pilot Operators: Exempt From §5.25(c), Not From SMS
This is the cleanest exemption in the rule, and it directly answers “do single-pilot operators need a Director of Safety?” No. Under 14 CFR §5.9(e), an operator where a single pilot is the sole individual performing all necessary functions for the safe operation of the aircraft is expressly exempted from a specific list of Part 5 line items — and that list includes §5.25(c) (designate management personnel) and §5.25(b)(3).
§5.9(e) exempts a true single-pilot operator from these line items:
Source: 14 CFR §5.9(e). Confirm the current text against the regulation and your assigned FSDO before relying on any single exemption.
What that means in practice: a true single-pilot Part 135 operator does not have to designate a separate safety manager or Director of Safety. The single pilot still functions as the accountable executive under §5.25(a) — the §5.9(e) list does not exempt §5.25(a) — and still has to meet every other applicable Part 5 requirement. Critically, the deadline does not move: a single-pilot operator's SMS compliance date is the same May 28, 2027 as everyone else's. §5.9(e) is relief from specific organizational requirements, not a later timeline and not a pass on SMS.
“Single-pilot” has a strict definition — don't assume you qualify
The §5.9(e) relief applies only where one pilot is the sole individual performing all necessary functions — operational control, ground handling, flight planning, and so on. The moment you bring on a second pilot or split those functions across people, you are outside the single-pilot definition and §5.25(c) applies again. Confirm your status with your FSDO. Our dedicated guides go deeper: single-pilot Part 135 SMS and single-pilot operator records.
Where FileFlo Fits: Proving Your SMS Role Structure to the FAA
FileFlo holds the proof — it does not run your SMS or replace your safety manager
FileFlo is a compliance document intelligence platform — the proof layer. It classifies, indexes, version-controls, and tracks the expiration of the documents that prove your SMS roles are designated and functioning. It is not an SMS platform, does not run your safety management system, does not author your SMS manual, and does not replace a safety manager or Director of Safety. It does not decide who holds your §5.25 roles or give legal or safety-program advice — it keeps the records that prove those roles exist audit-ready, so you can produce them on demand.
The role question — accountable executive, safety manager, owner-as-both, single-pilot exemption — is a decision you make with your FSDO and your safety professional. Once you make it, you generate a set of documents that prove the decision: the signed accountable-executive designation, the signed safety policy under §5.25(b), the written SMS role assignments, and the training and reporting records the designated person produces over time. That paperwork is what an inspector verifies — and keeping it organized, current, and retrievable for years is the document problem FileFlo is built for.
Role-Designation Documents, Classified & Versioned
Your accountable-executive designation (§5.25(a)), signed safety policy (§5.25(b)), and written SMS role assignments are classified against the specific Part 5 section they satisfy and version-controlled — so when the FAA asks "show me your accountable-executive designation," it is one search away, in its current signed version.
Expiration & Currency Tracking
The records your designated safety person produces — SMS training completions (§5.91), audits, and reviews — carry retention and recurrence clocks. FileFlo surfaces recurrent items 90/60/30 days out so a designated role does not quietly fall out of currency between surveillance visits.
One-Click Part 5 Evidence Binder
When your principal inspector asks for SMS documentation — including who is designated to administer it — FileFlo generates a Part 5-organized evidence binder in seconds, indexed by component and section. The same binder supports ACSF, IS-BAO, and ARGUS audit preparation.
Coverage Across the Full Part 135 Stack
Your SMS role-designation records sit alongside the rest of your Part 135 file. FileFlo classifies 600+ document types against the governing CFR — GOM/GMM revisions, pilot currency, training records, drug & alcohol program records and more — so the whole compliance picture lives in one audit-ready place.
Starter Plan
$89/mo
Up to 100 documents/month · 3 users
For solo owner-operators and small teams documenting their SMS roles and starting their Part 5 evidence file.
Professional Plan
$299/mo
Unlimited documents + users · audit trail · employee auto-detection
For Part 135 operators managing SMS role records alongside the full compliance document load.
Frequently Asked Questions
Does a Part 135 operator need a Director of Safety?
No — 14 CFR Part 5 never uses the title "Director of Safety," and it does not require a Part 135 operator to create that position. What Part 5 actually requires is two roles: an accountable executive under §5.25(a), and — for operations that are not single-pilot — "sufficient management personnel" designated under §5.25(c) to coordinate and run the SMS. Many operators give that management-personnel role the job title "Director of Safety" or "Safety Manager," but the title is a choice, not a regulation. Separately, §119.71 lists the management positions a Part 135 certificate holder must fill — Director of Operations, Chief Pilot, and Director of Maintenance — and a Director of Safety is not on that list either. So the honest answer most ranking pages miss: you must designate someone to administer the SMS, but you are not legally required to hire a person with the words "Director of Safety" on their business card.
What is a safety director in aviation?
In aviation, a "safety director" (or safety manager) is the person an operator designates to run the day-to-day Safety Management System on behalf of the accountable executive. Under 14 CFR §5.25(c), that designated management person is responsible for coordinating SMS implementation and maintenance, facilitating hazard identification and safety-risk analysis, monitoring the effectiveness of safety risk controls, ensuring safety promotion under subpart E, and regularly reporting SMS performance back to the accountable executive. "Director of Safety" is the common industry job title for this function, but it is not a regulatory term — Part 5 calls it "management personnel," not a director of safety. The role is about administering the SMS; it does not have to be a dedicated full-time hire at a small Part 135 operator.
What is the difference between an accountable executive and a safety manager?
They are two distinct SMS roles, and Part 5 defines both. The accountable executive (§5.25(a)) is the single person with final authority over the operation, control of the financial and human resources the operation needs, and ultimate responsibility for safety performance — at a small Part 135 operator this is almost always the owner or CEO. The safety manager / designated management personnel (§5.25(c)) is who the accountable executive appoints to actually coordinate and run the SMS day to day — hazard ID, risk analysis, monitoring controls, safety promotion, and reporting performance back up. The key nuance: at a very small operator, the same person can fill both roles. The accountable executive can also be the person administering the SMS. They are separate responsibilities in the regulation, but not necessarily separate people.
Can the owner be the safety manager under the Part 135 SMS rule?
Yes. Nothing in 14 CFR Part 5 prohibits the owner, CEO, or accountable executive from also serving as the person who administers the SMS. The rule is deliberately scalable: the FAA recognizes that a large share of Part 135 certificate holders operate only one or two aircraft, so it requires you to designate "sufficient management personnel" (§5.25(c)) — "sufficient" for your size — rather than mandating a separate, dedicated safety department. For a small operator, that designated person can be the owner. The obligation is that someone is clearly designated, documented, and actually performing the SMS coordination, hazard-identification, monitoring, promotion, and reporting duties. Who that person is — and whether they wear other hats — is up to the operator.
Do single-pilot Part 135 operators need a safety manager or Director of Safety?
No. Under §5.9(e), a single-pilot operator — defined as one where a single pilot is the sole individual performing all necessary functions for the safe operation of the aircraft — is expressly exempted from §5.25(c), the requirement to designate management personnel to run the SMS, and from §5.25(b)(3). In plain terms: a true single-pilot Part 135 operator does not have to designate a separate safety manager or Director of Safety. The single pilot still functions as the accountable executive under §5.25(a) and still has to meet the rest of the applicable Part 5 requirements, and the compliance date is the same May 28, 2027 as for every other Part 135 operator — there is no later deadline for single-pilot operations. The §5.9(e) relief is from specific organizational line items, not from SMS itself.
Is a Director of Safety a required management position under Part 135?
No. The required management positions for a Part 135 certificate holder are set by 14 CFR §119.71, and they are Director of Operations, Chief Pilot, and Director of Maintenance (with qualification requirements for each). A Director of Safety is not among the §119.71 required positions. The SMS rule in Part 5 adds the accountable executive (§5.25(a)) and designated management personnel (§5.25(c)) as required SMS roles, but it does not add "Director of Safety" as a named, required management position. So whether you call your SMS person a Director of Safety, a Safety Manager, or simply the designated SMS coordinator, the title is yours to choose — what the FAA checks is that the §5.25 roles are designated, documented, and functioning.
What are the duties of an aviation Director of Safety under SMS?
When an operator designates a Director of Safety as its SMS management person, the duties track 14 CFR §5.25(c): coordinating implementation, maintenance, and integration of the SMS throughout the organization; facilitating hazard identification and safety-risk analysis; monitoring the effectiveness of the operation's safety risk controls; ensuring safety promotion (training and safety communication) under subpart E; and regularly reporting SMS performance to the accountable executive. In practice that means owning the safety reporting system, running risk assessments on new procedures and changes, keeping the SMS manual current, tracking corrective actions to closure, and maintaining the records that prove all of it. The FAA also publishes a Director of Safety qualification summary as guidance — it is guidance, not a Part 5 mandate, but it is a useful checklist for what a capable SMS person should be able to do.
Does the Director of Safety / safety manager have to be a full-time hire?
No. Part 5 requires "sufficient management personnel" (§5.25(c)) to administer the SMS — "sufficient" relative to the size and complexity of your operation — but it does not require a dedicated, full-time Director of Safety. At a small Part 135 operator the role is frequently a collateral duty held by the owner, the director of operations, or the chief pilot, and the FAA's scalable approach is built to accommodate exactly that. What the FAA evaluates is whether the SMS functions and whether the documentation proves it — not whether the safety job is somebody's only job. The practical limit is honest capacity: the designated person has to actually perform the §5.25(c) duties and keep the records, so when an operation grows past what one part-time person can cover, a dedicated role becomes a quality and audit-survival decision, not just a regulatory one.
Designate the role. Prove it on demand.
You decide who holds your §5.25 SMS roles. FileFlo keeps the documents that prove it — the accountable-executive designation, the signed safety policy, the SMS role assignments and the records behind them — classified against the right Part 5 section and ready for your FSDO. Starter at $89/mo · Professional at $299/mo · No credit card required.
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