A Part 135 SMS manual documents the four components of a Safety Management System required by 14 CFR Part 5: safety policy (§5.21), safety risk management (Subpart C), safety assurance (Subpart D), and safety promotion (§5.91/§5.93), plus a documentation and records-control section under §5.95 and §5.97. There is no official FAA fill-in template — Part 5 sets the required outcomes, and FAA guidance (AC 120-92D) describes how to document them. Critically, every section of the manual promises that certain records exist; the §5.97 records are what prove the manual is being followed. Every Part 135 operator must have this in place by May 28, 2027.
New to the 2027 mandate? Start with the FAA Part 135 SMS 2027 deadline explainer for the four-component overview, then come back here for the manual structure. For the records the manual promises and how long to keep them, see Part 135 SMS recordkeeping requirements.
Is There an Official Part 135 SMS Manual Template?
This is the question almost everyone types first — “sms manual template part 135,” “aviation sms manual pdf,” “part 135 sms manual example.” The honest answer matters, so here it is straight: the FAA does not publish a fill-in SMS manual template you can download, complete, and submit.
14 CFR Part 5 is written in terms of outcomes your SMS must achieve, not a form to fill out. §5.95 simply says you must “develop and maintain” documentation consisting of (a) the safety policy and (b) the SMS processes and procedures. It is silent on format. FAA guidance — chiefly Advisory Circular AC 120-92D and its appendices — describes how to build and document an SMS along the four-component framework, and it is the closest thing to an official outline. But AC 120-92D is guidance, not a regulation: following it is one acceptable means of compliance, not the only one.
What a template can do
- Give you a reasonable starting structure organized around the four components
- Save drafting time on boilerplate policy language
- Prompt you to address each §5.21 policy element
What a template can't do
- Make you compliant on its own — the §5.97 records must actually exist
- Match your real operation without tailoring to your fleet, routes, and people
- Generate the hazard analyses, audits, and training the manual promises
A manual is a promise; the records are the proof
The trap with buying a polished template is mistaking the manual for the SMS. Every section of the manual promises certain records exist — a risk assessment behind each operational change, an audit report each cycle, a training record for each person. Under §5.97 those records have to be there and retained for set periods. A beautiful template with empty record folders behind it is still an audit finding.
So the useful framing is not “where do I get the template” but “which sections must my manual contain, and what records does each section promise?” That is the rest of this guide. Build the structure below from the CFR, tailor it to your operation (or have a safety professional do it), and make sure the records each section references actually exist and are retained.
The Required Sections of a Part 135 SMS Manual
Mapped to 14 CFR Part 5, the manual breaks into the four SMS components plus a documentation-and-records section. Each card below gives the CFR source, what the section documents, and — the part templates skip — the records that section promises exist under §5.97.
Safety Policy (Subpart B)
14 CFR §5.21The foundation section. It documents the signed safety policy plus the accountability, authority, and emergency-response structure the rest of the SMS hangs from. This is the section an inspector reads first because it establishes who owns safety and what the organization has committed to.
The records this section promises: the signed policy itself, the org/accountability chart, and the approved emergency response plan.
What this section must document
- Safety policy statement with all seven §5.21 elements (objectives, commitment, resources statement, safety reporting policy, unacceptable-behavior/disciplinary policy, emergency response plan, code of ethics)
- Safety accountability and authority structure under §5.23 — accountable executive, management, and employee responsibilities, plus who has authority to accept risk
- Designation and responsibilities of the accountable executive and required safety personnel (§5.25)
- Emergency response plan coordination — delegation of authority, employee responsibilities, coordination with interfacing organizations (§5.27)
Safety Risk Management (Subpart C)
14 CFR §5.51The "how we find and manage hazards" section. It describes the system, defines the processes for identifying hazards and assessing/controlling risk, and explains the change-management trigger. Every operational change runs through what this section documents.
The records this section promises: hazard identification worksheets, risk-assessment matrices, and risk-control decisions (§5.97(a)).
What this section must document
- System description and analysis approach used to identify hazards
- Hazard identification process — how hazards are surfaced from reports, audits, and operational changes
- Safety risk assessment process — likelihood and severity criteria and the risk matrix
- Safety risk control process and the basis for accepting residual risk
Safety Assurance (Subpart D)
14 CFR §5.71The "how we prove it is working" section. It describes performance monitoring, internal auditing, management review, and continuous improvement. This is the section that drives the highest-volume, longest-retention records in the whole SMS.
The records this section promises: audit reports, monitoring/performance data, investigation outputs, and management-review minutes — minimum 5-year retention (§5.97(b)).
What this section must document
- Performance monitoring and measurement, including safety performance indicators and targets
- Internal audit and evaluation process with finding and corrective-action tracking
- Process for investigating safety events and monitoring effectiveness of risk controls
- Management review and continuous-improvement process under §5.75
Safety Promotion (Subpart E)
14 CFR §5.91The "people" section. It documents how the operator trains individuals to perform their SMS duties and how it communicates safety information across the organization. Scaled down for single-pilot operators, but still present for the training side.
The records this section promises: a per-individual training record (kept as long as employed, §5.97(c)) and safety-communication logs (minimum 24 months, §5.97(d)).
What this section must document
- Competency-based SMS training for each individual identified in §5.23 (§5.91)
- Safety communication that ensures awareness of SMS policies/processes, conveys hazard information, and explains why actions and procedure changes happen (§5.93)
- Distribution and acknowledgment process for safety communications
- Competency assessment / qualification tracking per role
SMS Documentation & Records Control
14 CFR §5.95The "how the manual maintains itself" section. §5.95 requires you to develop and maintain the documentation; §5.97 requires you to retain the records the manual promises exist. This section is where the manual states its own version-control and retention rules — and where most templates stop while the real work begins.
This section promises a controlled, current manual plus a retention schedule covering all four §5.97 clocks.
What this section must document
- SMS documentation procedure: how the safety policy and processes/procedures are developed and maintained (§5.95)
- Revision control — revision numbers, dates, accountable-executive review, and retention of superseded versions
- Records-control procedure mapping each output to its §5.97 retention clock
- Distribution and access control for the current manual
Manual drafted — but do the records behind it exist?
The free FAA readiness score surfaces the SMS and Part 135 records most likely to be missing or expired before a surveillance evaluation — in about 3 minutes, no signup. It checks whether your manual's promises are backed by records.
A Build Checklist: From Blank Page to Audit-Ready
Use this as the order of operations for building (or finishing) your Part 135 SMS manual. Steps 1–6 are the manual and the SMS itself — your work, your safety manager's, or an SMS consultant's. Step 7 is where FileFlo comes in: proving the records exist.
Name your accountable executive and safety personnel
Identify the accountable executive who meets the §5.25 criteria (final authority, controls financial and human resources, ultimate responsibility for safety performance) and the management personnel responsible for SMS administration. This drives the §5.23 accountability structure.
Draft and sign the safety policy with all seven §5.21 elements
Objectives, commitment, resources statement, safety reporting policy, unacceptable-behavior/disciplinary policy, emergency response plan, and code of ethics. The accountable executive develops, signs, communicates, and reviews it (§5.25).
Document your safety risk management process (Subpart C)
Describe the system, the hazard identification process, the risk-assessment criteria and matrix, and the risk-control/residual-risk-acceptance process. Define the change-management trigger so operational changes route through SRM.
Document your safety assurance process (Subpart D)
Performance monitoring with indicators and targets, internal audit/evaluation with finding and corrective-action tracking, safety-event investigation, and the §5.75 management review. This is the section that generates your longest-retention records.
Document training and communication (Subpart E)
Competency-based SMS training for each individual in §5.23 (§5.91), and a safety communication process that covers the four §5.93 items. Single-pilot operators scale this down under §5.9(e).
Write the documentation & records-control section (§5.95 / §5.97)
State how the manual is version-controlled and how each record type is retained: §5.97(a) as long as the control is relevant, §5.97(b) minimum 5 years, §5.97(c) as long as the individual is employed, §5.97(d) minimum 24 consecutive calendar months.
Stand up the records so the manual’s promises are real
For every record the manual promises, make sure it exists, is filed against the right Part 5 section, carries its retention clock, and can be produced on demand during an FAA surveillance evaluation. This is the document-control layer FileFlo provides.
Sequencing the whole build against the 2027 clock
If you are working out when to do each of these steps before May 28, 2027, our Part 135 SMS implementation timeline lays the build on a calendar, and the SMS gap analysis guide helps you find which sections and records you are missing today. When it is time to declare, see the FAA SMS Declaration of Compliance guide.
Prove every promise in your manual is backed by a record
FileFlo classifies each SMS record against the correct Part 5 section, tracks all four §5.97 retention clocks, and produces an inspector-format evidence binder in seconds. It does not write your manual — it proves the records the manual promises actually exist. Check your readiness free, or start a trial and load your first documents today.
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Where FileFlo Stops: It Stores and Proves the Records, It Does Not Write Your Manual
The boundary, stated plainly
FileFlo is a compliance document intelligence platform — a proof layer. It stores, classifies, version-controls, and expiration-tracks your §5.95 documentation and the §5.97 records the manual promises exist, and generates inspector-format binders on demand. It does not author your SMS manual, sell you a manual template, perform your hazard analyses or audits, run your SMS, replace your safety manager, or provide a safety program or legal advice. The manual and the SMS are your work (or a safety professional's); FileFlo proves the records are audit-ready.
Because so many searchers arrive looking for a “template,” it is worth being precise about the two halves of the job. Writing the manual is an authoring task — deciding your safety objectives, designing your risk matrix, defining your audit cadence. That is the SMS itself, and it belongs to you, your director of safety, or your consultant. Keeping the manual current and proving the records behind it exist is a document-control task — and that is the half FileFlo does.
Not FileFlo (the SMS itself)
- ×Writing or templating your SMS manual
- ×Performing hazard analyses or risk assessments
- ×Running your internal audits or investigations
- ×Acting as your safety manager or director of safety
- ×Providing a safety program or legal advice
FileFlo (the proof layer)
- Storing the manual and policy with version control
- Classifying each record against its Part 5 section
- Tracking all four §5.97 retention clocks
- Surfacing missing or expired records before a finding
- Producing an inspector-format evidence binder on demand
Classification against 14 CFR Part 5
Upload an SMS record and FileFlo classifies it against the specific Part 5 section it satisfies — a risk assessment to §5.97(a), an audit report to §5.97(b), a training certificate to §5.97(c) and the individual. The manual says these records should exist; FileFlo files the actual records so the promise is backed.
All four §5.97 retention clocks, tracked automatically
FileFlo tracks the event-driven risk-management clock, the 5-year safety-assurance clock, the employment-tied training clock, and the 24-month communication clock — and surfaces gaps and expirations 90, 60, and 30 days out, before they become findings.
Version control on the manual and safety policy
The §5.95 documentation carries revision history so the version in effect on any date is recoverable, and superseded versions are retained and marked rather than overwritten — without FileFlo writing a word of the manual itself.
One-click SMS evidence binder
When the FAA requests SMS documentation, FileFlo generates a complete, Part 5-organized evidence binder — the §5.95 documentation plus the §5.97 record categories, indexed by section — in seconds rather than days. The same binder supports ACSF, IS-BAO, and ARGUS audit prep.
The SMS manual is also not an island. The records it promises cross-reference the rest of your compliance stack: an SMS training record sits beside the pilot training records under Part 135 training-program recordkeeping; a §5.97(a) risk assessment touches your aviation records retention schedule; and an inspector preparing for a Part 135 FAA surveillance audit will expect SMS records produced as cleanly as everything else. FileFlo classifies the full Part 135 footprint, so SMS records do not become a parallel filing universe — see what records a Part 135 operator must keep for the complete picture.
Starter Plan
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For solo owner-operators and small teams starting to organize their SMS documentation and records.
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$299/mo
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For Part 135 operators managing the full §5.97 record load behind a complete SMS manual.
Frequently Asked Questions
What goes in an SMS manual for a Part 135 operator?
A Part 135 SMS manual documents the four components of a Safety Management System as required by 14 CFR Part 5: safety policy (Subpart B), safety risk management (Subpart C), safety assurance (Subpart D), and safety promotion (Subpart E). In practice that means the manual contains a signed safety policy statement with the elements §5.21 lists (safety objectives, management commitment, a resources statement, a safety reporting policy, a disciplinary/unacceptable-behavior policy, an emergency response plan, and a code of ethics); the accountability and authority structure (§5.23) including the accountable executive's designation and duties (§5.25); the emergency response plan coordination (§5.27); the hazard identification and risk-assessment processes (Subpart C); the safety assurance monitoring, auditing, and management-review processes (Subpart D); the safety training and communication processes (§5.91, §5.93); and the documentation and records-control procedures (§5.95, §5.97). Part 5 sets what the manual must address — it does not publish a fill-in template.
Is there an official FAA SMS manual template for Part 135?
No. The FAA does not publish a fill-in SMS manual template you can download and submit. 14 CFR Part 5 states the outcomes your SMS must achieve and §5.95 requires you to develop and maintain documentation describing the safety policy and the SMS processes and procedures — but the FAA leaves the format to you. The guidance document, Advisory Circular AC 120-92D (and its appendices), describes how to build and document an SMS and is the closest thing to an official outline, but it is guidance, not a template, and following it is one acceptable means of compliance rather than the only one. Vendors sell SMS manual templates, and they can be a reasonable starting structure, but a purchased template is not a compliant SMS on its own — the records the manual promises must actually exist (§5.97).
What are the required sections of an aviation SMS manual?
Mapped to 14 CFR Part 5, an aviation SMS manual generally needs sections covering: (1) Safety Policy — the signed policy with all seven §5.21 elements, the §5.23 accountability and authority structure, the §5.25 accountable-executive designation and duties, and the §5.27 emergency response plan coordination; (2) Safety Risk Management — the system description, hazard identification, and risk assessment/control processes in Subpart C; (3) Safety Assurance — the performance monitoring, internal auditing, change management, and continuous-improvement processes in Subpart D; (4) Safety Promotion — the competency-based training under §5.91 and the safety communication under §5.93; and (5) SMS Documentation and Records — how you maintain the documentation (§5.95) and retain the records with their retention periods (§5.97). AC 120-92D's appendix organizes content along the same four-component lines.
What must the safety policy in an SMS manual include?
Under 14 CFR §5.21, the safety policy section of the manual must include the operator's safety objectives; a commitment to fulfill those objectives; a clear statement that the necessary resources for implementing the SMS will be provided; a safety reporting policy that defines requirements for employee reporting of hazards or issues; a policy that defines unacceptable behavior and the conditions for disciplinary action; an emergency response plan that provides for the safe transition from normal to emergency operations; and a code of ethics, applicable to all employees including management and officers, clarifying that safety is the organization's highest priority. §5.25 requires the accountable executive to develop and sign the policy, communicate it throughout the organization, and review it regularly. So the policy is not a one-line mission statement — it is a defined, signed, multi-part section.
How long must a Part 135 operator keep its SMS records once the manual is in place?
The manual describes the system; 14 CFR §5.97 sets how long you keep the records the system produces, and the clocks differ by record type. Safety risk management outputs (hazard analyses, risk assessments, risk-control decisions) are kept for as long as the control remains relevant to the operation (§5.97(a)). Safety assurance outputs (audits, monitoring, performance data, investigations) are kept for a minimum of 5 years (§5.97(b)). The training record for each individual is kept for as long as that individual is employed (§5.97(c)). Records of safety communications are kept for a minimum of 24 consecutive calendar months (§5.97(d)). A polished manual with no §5.97 records behind it is still an audit finding — the records are what prove the manual is being followed.
Does a single-pilot Part 135 operator need a full SMS manual?
A single-pilot Part 135 operator is subject to Part 5 and faces the same May 28, 2027 compliance date — §5.9(e) does not push the deadline later. What §5.9(e) does is exempt an operator with a single pilot who is the sole individual performing all necessary SMS functions from several specific sections, including §5.21(a)(4)–(5) and (c), parts of §5.23 and §5.25, the §5.27 emergency-response coordination items, §5.93 (safety communication), and §5.97(d) (the communication-records requirement). The manual is therefore scaled, not eliminated: it still documents a safety policy, the safety risk management and safety assurance processes, the §5.91 training, and the §5.95/§5.97 documentation and records. Our single-pilot Part 135 records guide walks through the reduced set in detail.
Where do I actually keep the SMS manual and the records it references?
14 CFR §5.95 requires you to develop and maintain the SMS documentation and §5.97 requires you to retain the records — but Part 5 does not prescribe a specific software, binder, or filing format. In practice the manual and its referenced records need version control (so the version in effect on any date is recoverable), per-section filing (so a risk assessment files to §5.97(a), an audit to §5.97(b), a training certificate to §5.97(c)), retention tracking for each of the four §5.97 clocks, and on-demand retrieval during an FAA surveillance evaluation. This is exactly the document-control discipline FileFlo provides as a proof layer — it stores, classifies, and version-controls the manual and the records and tracks the retention clocks. FileFlo does not author the manual or run the SMS; it proves the records the manual promises actually exist.
Does FileFlo write my Part 135 SMS manual or provide a template?
No. FileFlo does not author your SMS manual, sell you a manual template, run your SMS, perform your hazard analyses or audits, replace your safety manager, or provide a safety program or legal advice. FileFlo is a compliance document intelligence platform — a proof layer that stores, classifies, version-controls, and expiration-tracks the §5.95 documentation (the manual and safety policy) and the §5.97 records the manual promises exist, files each against the correct Part 5 section, tracks the four different retention clocks, and generates an inspector-format evidence binder on demand. If you need the manual itself written, that is the SMS work — done by you, your safety manager, or an SMS consultant. FileFlo is the filing cabinet that proves the manual and its records are audit-ready, not the system that produces them. FileFlo also does not claim any SOC 2 certification.
Write the manual. Let FileFlo prove the records behind it.
Your SMS manual makes promises in every section. FileFlo classifies each §5.95 and §5.97 record against the correct Part 5 section, tracks all four retention clocks, and generates a complete FAA-organized evidence binder on demand. It holds the proof your SMS is running — it does not write your manual or run your SMS. Starter at $89/mo · Professional at $299/mo · No credit card required.
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