FAA’s New Rule on Airport SMS

The Federal Aviation Administration (FAA) introduced a Safety Management System (SMS) requirement for certain airports governed by 14 CFR part 139. This new rule is designed to strengthen airport safety by fostering a proactive approach to identifying and mitigating potential hazards before they lead to incidents or accidents. Below is a concise guide on the rule’s scope and which airports must comply.

What Is the FAA’s Part 139 SMS Rule?

The FAA Safety Management System rule establishes a framework of processes and procedures that Part 139 airports must implement to improve overall safety performance. Rather than reactively addressing issues after they arise, an SMS helps airport operators proactively manage risks based on structured data collection, hazard identification, and continuous monitoring.

Key objectives of the rule include:

  • Formalized processes: Ensuring that risk management is systematic rather than ad hoc.
  • Organizational-wide approach: Engaging airport executives, managers, tenants, and frontline personnel in consistent safety practices.
  • Continuous improvement: Continuously evaluating the effectiveness of safety mitigations to stay ahead of emerging risks.

Which Airports Must Comply?

Not every Part 139 airport is automatically required to implement an SMS under the new rule. The FAA has outlined specific triggering criteria under 14 CFR §139.401(a) to determine which airports fall within the rule’s scope. An airport must implement SMS if it meets at least one of these criteria:

  1. Classified as a Large, Medium, or Small Hub
    Airports that receive hub designations (based on enplanement data in the Air Carrier Activity Information System) must comply.
  2. 100,000+ Total Annual Operations
    SMS implementation is required if your airport has an average of 100,000 or more total annual aircraft operations (arrivals + departures) over the preceding three calendar years.
  3. International Airports Serving Passenger Flights
    Specifically, those designated as a port of entry, landing rights airport, or user fee airport. The SMS rule generally applies if the airport handles international commercial passenger operations beyond general aviation.

Understanding Waiver Eligibility

Some international airports (defined exclusively under the third trigger) may request a waiver if they have no tenants subject to any federal SMS requirement (such as a Part 5 airline). In this case, the FAA grants waivers on a two-year validity period, contingent on the airport maintaining eligibility. If your airport’s traffic mix or tenant profile changes, you must reevaluate and possibly implement SMS requirements.

Key Points About the Waiver Process:

  • Must be initiated by the airport: Airport operators must submit a written waiver request to their FAA Regional Airports Division Manager.
  • Two-year renewal: Waivers expire after two years; airports must reapply if conditions remain the same.
  • Temporary relief only: This is not a permanent exemption. If you lose eligibility or your airport triggers a different criterion, you must proceed with SMS compliance.

When Does My Airport Need to Comply?

The rule’s effective date is April 24, 2023, but the FAA provides phased deadlines:

  • 12 to 24 months (depending on criteria) to submit an SMS Implementation Plan
  • 12 months after plan approval to update your Airport Certification Manual (ACM) or develop a standalone SMS Manual
  • 36 months after plan approval to fully implement SMS

Next Steps for Airport Operators

  1. Check Your Status
    Review the FAA’s official Airport Certification Status List to see whether your airport meets one of the triggering criteria.
  2. Confirm Waiver Eligibility
    If your airport exclusively qualifies under the international operations criterion—and you have no tenant subject to SMS—you may consider applying for a waiver. Submit the request to your FAA Regional Airports Division Manager.
  3. Gather Resources
    Consult the FAA’s External SMS webpage for guidance documents, training materials, and contact information.
  4. Begin Implementation
    Even if your airport has an extended deadline, starting early with hazard identification, safety policy statements, and staff training fosters smoother compliance and strengthens the safety culture.

Key Takeaways

  • The FAA’s Part 139 SMS rule applies only to certain airports based on enplanements, total annual operations, or international passenger services.
  • Airports meeting at least one of these triggers must develop and maintain an SMS that integrates hazard identification, risk management, safety assurance, and promotion.
  • Waivers exist for certain airports with international designations only if no federally required SMS tenants operate there.
  • Compliance is phased, with specific deadlines for filing your SMS Implementation Plan, updating documents, and fully adopting the program.

By clarifying eligibility requirements and deadlines, the FAA hopes to improve aviation safety while offering flexibility for airports that need additional time or waiver considerations. Start evaluating your airport’s status now and gather the resources you need to maintain a robust, proactive safety culture.

Frequently Asked Questions (FAQ)

1. Where can I find out if my airport meets the triggers?
Check the FAA’s Airport Certification Status List to see if your airport surpasses the enplanement or operations thresholds or is designated internationally.

2. How do I determine if my airport can get a waiver?
Only airports classified under §139.401(a)(3) (internationally designated) without any SMS-operator tenants qualify. Submit a justification letter to your FAA Region.

3. How soon should I start?
Even if you have up to two years to submit an implementation plan, you’ll benefit from beginning the hazard identification processes immediately. Early planning streamlines compliance and fosters continuous safety improvements.

How River Island Can Help

As River Island, we provide solutions that help airports meet the FAA’s new Part 139 SMS requirements while maintaining alignment with global best practices. Our seasoned consultants have guided airports worldwide—including some of the most complex and high-traffic hubs—to seamlessly implement Safety Management Systems. Whether you’re starting from scratch or optimizing an existing system, River Island ensures regulatory compliance, robust risk mitigation, and operational efficiency—so your airport can operate at the highest levels of safety.

References

Code of Federal Regulations Title 14 §139.401(a)
https://www.ecfr.gov/current/title-14/chapter-I/subchapter-G/part-139/subpart-E/section-139.401

FAA Airport Certification Status List
https://www.faa.gov/airports/airport_safety/part139_cert/part_139_airport_certification_status_list

FAA Regional Airports Division and District Offices (ADOs)
https://www.faa.gov/about/office_org/headquarters_offices/arp/offices/regional_offices

FAA External SMS
https://www.faa.gov/airports/airport_safety/safety_management_systems/external