CASA assesses every SMS against the same twelve elements, whether you fly two helicopters or two hundred aeroplanes. The elements do not shrink for a small operator. What shrinks is the evidence needed to show each one is real.
ICAO Annex 19 (the international standard every ICAO member state, including Australia, adopts for safety management) defines an SMS as four components made of twelve elements. CASA's advisory circular says the SMS "must, at a minimum, address the 4 components and 12 elements", and that the table of elements "may serve as a template for a table of contents for an SMS, or as a checklist". Regulations 119.190(2) and 138.145 of CASR point at the same structure.
So this is the checklist. For each element below: what it means, what it looks like at small scale, and the evidence CASA's performance markers point to.
| Component | Elements |
|---|---|
| 1. Safety policy and objectives | 1.1 Management commitment · 1.2 Safety accountabilities and responsibilities · 1.3 Appointment of key safety personnel · 1.4 Coordination of the emergency response plan · 1.5 SMS documentation |
| 2. Safety risk management | 2.1 Hazard identification · 2.2 Safety risk assessment and mitigation |
| 3. Safety assurance | 3.1 Safety performance monitoring and measurement · 3.2 The management of change · 3.3 Continuous improvement of the SMS |
| 4. Safety promotion | 4.1 Safety training and education · 4.2 Safety communication |
A written safety policy, signed by the CEO, that says safety is a core value, commits resources, promises a just culture, and points people to the reporting system. Plus a small set of safety objectives with indicators and targets so you can tell whether you are getting better.
At small scale: one page. The CEO signs it, dates it, and it is on the wall in the hangar and in the front of the manual. Objectives can be three lines: "all hazards reported within 24 hours", "hazard register reviewed monthly", "zero open audit findings older than 90 days".
Who is accountable for the SMS (the CEO, always), who is responsible for running it, and what every other person's safety responsibilities are. The AC expects a safety governance structure: at minimum a safety meeting that reviews the SMS, even if the "committee" is three people in the crew room.
At small scale: a half-page table of roles. A monthly safety meeting, minuted. The micro-operator sample manual includes text for the CEO also being safety manager and how the conflict is managed.
A nominated safety manager, accepted by CASA, who runs the SMS day to day and reports to the CEO. The AC lists the competencies: safety and regulatory knowledge, investigation and audit skills, and the ability to be independent of operational pressure.
At small scale: if you have ten or fewer operational safety-critical personnel, the CEO or HOFO/HOO may hold the role under the micro-operator exemption. Their SMS training must be recorded, and the manual must say how workload and conflict of interest are handled.
An emergency response plan (ERP) that sets out who does what after an accident or serious incident, including the interfaces with emergency services, the ATSB, CASA, next of kin, media and your own people. It must be tested and reviewed.
At small scale: CASA's ERP template, filled in with real names and numbers, a laminated card in each aircraft and the office, and a tabletop walk-through once a year.
The manual that describes the SMS, and the records the SMS produces. The AC's performance markers: documentation is "readily available to all relevant personnel", and "SMS documentation, including SMS related records, is regularly reviewed and updated with appropriate version control in place".
At small scale: the manual can be a separate SMS manual or part of your exposition or operations manual. Records that count as safety records, per the AC: gap analysis and implementation plans, hazard and risk registers, safety reports and investigations, risk assessments, SMS reviews, audit reports, safety meeting minutes, training records, and safety surveys.
A way for anyone to report a hazard or occurrence, a just-culture policy so they will, and a process that captures reports from every source: crew reports, maintenance findings, audits, customer feedback, industry bulletins, and your own observation. Reports are acknowledged, classified, and feed the register.
At small scale: a report form that takes 60 seconds on a phone, a promise that every report gets a reply, and a register that is reviewed at the monthly meeting. The most common finding against small operators is a reporting system that exists on paper and has zero reports in it.
Each hazard is assessed for likelihood and severity using a defined matrix, controls are chosen, someone owns each control, and the residual risk is accepted by the right level of management. The register is a living document, not a spreadsheet created once for the audit.
At small scale: CASA's sample manual gives you a 5×5 matrix and risk acceptance levels. Use them unchanged. Ten well-assessed real hazards beat a hundred generic ones copied from a template.
The element small operators most often fail. It covers safety performance indicators (SPIs) and targets (SPTs), trend analysis of your reports, and the internal audit program. The AC says audits should assess the effectiveness of the SMS, that procedures should set responsibilities and frequency, that auditors should be trained, that findings should be accurate and actioned, and that progress in closing findings should be monitored.
At small scale: three to five indicators that you can actually measure from your own reports. An annual audit plan that covers each element of the SMS at least once. An audit checklist built from your own manual, so the audit asks "are we doing what we said we would do?" Findings tracked to closure.
When something changes, such as a new aircraft type, a new base, a new contract, a key person leaving, or new procedures, the change is assessed for its effect on hazards before it happens, not after. The AC notes that adding a new aircraft type can itself trigger the Part 138 SMS requirement.
At small scale: a one-page change assessment form. The trigger list lives in the manual, and the assessment is filed with the register entries it creates.
Management periodically reviews the SMS itself: is the policy still right, are the objectives being met, are audits closing, is reporting healthy. This is the management review that the sample manuals describe, and it produces decisions.
At small scale: a quarterly management review, using a fixed agenda, minuted, with the CEO present. The annual policy re-sign happens here.
Everyone gets SMS training appropriate to their role: induction for all staff, more for the safety manager and anyone who investigates or audits, and refreshers. Training is recorded.
At small scale: a one-hour induction with a sign-off sheet, the safety manager's SMS course certificate, and a yearly refresher at a safety meeting.
Safety information flows in both directions: lessons from reports and investigations go back to the people who need them, and the organisation shows that reporting leads to action.
At small scale: a monthly safety notice, even one paragraph, and a "you said, we did" line at each safety meeting.
The AC is explicit that "no one system will be appropriate for all organisations" and that a small operator "may only need the services of a Safety Manager on a part time basis". Scale changes the depth of each element, the number of records, and the sophistication of the tools. It does not remove any element. CASA's Guide to the Sample Manuals gives the example of two micro-operators, one flying simple day operations and one flying complex ones, and shows how the same framework produces different depth of process for each.
The free SMS Gap Check asks one question per element and gives you a readiness score with the gaps ranked. Four minutes, no sign-up to see your result.
Run the SMS Gap CheckGeneral information for operators, not legal or regulatory advice. Check the current CASA source before acting.