Guide 3 of 3 · Operating it

Operating your SMS after 2 December: the rhythm CASA will ask to see

The manual gets you to the deadline. The records get you through the first surveillance visit. Here is the weekly, monthly, quarterly and annual cadence that produces those records without a safety department, and the list of what to keep.

For chief pilots and owner-operators running an SMS for the first time. Frequencies below are practical recommendations consistent with CASA AC 119-01/138-11 and the sample manuals; your own manual sets your commitments, so match this to what you wrote. Updated 2 September 2026.

The principle: your manual is a promise

Everything in your SMS manual is a statement of what you will do. "The safety manager reviews the hazard register monthly" is a promise. "Internal audits are conducted annually against each element" is a promise. A CASA inspector reads the promise, then asks for the record that proves you kept it. That is why the first job after 2 December is not to add more to the manual. It is to keep the promises already in it, and to shorten any promise you cannot keep.

The operating calendar

Whenever something happens

Trigger	What to do	Record produced
Hazard, incident or near-miss reported	Acknowledge the reporter within 24 hours. Classify it. Decide whether it needs an investigation, a register entry, or both. Check whether it is immediately or routinely reportable to the ATSB.	Report with date, classification, acknowledgment, decision
Investigation opened	Establish what happened, why, and what control failed or was missing. Recommend actions. Close with the CEO's sign-off.	Investigation report; actions in the corrective action log
Change planned (new aircraft type, base, contract, key person, procedure)	Complete the change assessment before the change. Add or re-rate hazards.	Change assessment; updated register entries
Audit finding raised	Assign an owner and a due date. Track to closure. Verify the fix worked.	Corrective action log entry with closure evidence

Weekly (15 minutes)

Check the report inbox. Nothing sits unacknowledged past 24 hours.
Glance at the corrective action log for anything due this week.

Monthly (one hour)

Safety meeting, even if it is two people. Fixed agenda: new reports, register changes, open actions, one lesson shared. Minute it with attendees, decisions and action owners.
Hazard register review. Anything new? Anything whose review date has passed? Any control that has been implemented and needs the risk re-rated?
Safety notice to all staff: one paragraph on what was reported and what was done about it. This is your safety communication evidence.
Update your safety performance indicators with the month's numbers.

Quarterly (half a day)

Management review with the CEO. Agenda: safety objectives versus indicators, report trends, investigation outcomes, audit status, overdue actions, resourcing, whether the SMS itself needs changing. Minute the decisions.
One internal audit covering a slice of the SMS, so that across the year every element is audited once. Use a checklist built from your own manual.
Check training currency and book any refreshers falling due.

Annually (one to two days)

Re-sign the safety policy and refresh the objectives and targets.
Complete the audit cycle and produce a one-page summary of findings and closures.
Exercise the emergency response plan (a tabletop walk-through counts) and update contacts.
Review the SMS manual and issue a new version if anything changed. Version control matters: an inspector will check that staff have the current one.
Run the SMS refresher for all staff and record it.
Re-check whether you still qualify as a micro-operator if you use that exemption.

The records CASA expects to exist

CASA's advisory circular lists the records that count as safety records. Keep every one of them somewhere you can find in minutes, with dates, and with version control on the documents that change.

Record	Who produces it	How often it should show activity
SMS gap analysis and implementation plan	Safety manager	Once at implementation, updated when gaps close
Hazard and risk register	Safety manager, from reports	Changes monthly
Safety reports and investigations	Any staff member; safety manager investigates	Continuously. Zero reports in a quarter is itself a finding.
Risk assessments and safety cases	Safety manager, for changes and significant hazards	With each change
SMS and management reviews	CEO and safety manager	Quarterly
Audit reports	Safety manager or a trained auditor	Quarterly slices, full cycle annually
Safety meeting minutes	Safety manager	Monthly
Safety training records	Safety manager	At induction, annually, on role change
Safety assurance records (surveys, monitoring, SPIs)	Safety manager	Monthly indicators, annual survey

Five indicators a small operator can actually measure

The AC warns that a common weakness is choosing only high-level indicators. Pick ones your own records generate.

Number of safety reports received per month (you want this to go up, not down).
Percentage of reports acknowledged within 24 hours.
Number of open corrective actions older than 90 days.
Percentage of hazard register entries past their review date.
Percentage of staff with current SMS training.

Set a target for each. Report them at every monthly meeting. Discuss the trend at every quarterly review. That single habit satisfies a surprising amount of element 3.1.

Your first twelve months, month by month

Month	Milestone
December 2026	SMS live. First safety meeting held and minuted. Register has real entries. Every staff member briefed and the briefing recorded.
January 2027	First monthly cycle complete. Indicators reported for the first time.
February 2027	First management review with the CEO. First internal audit slice (component 1, policy and organisation).
March to April 2027	Two more monthly cycles. First change assessment completed for whatever changed.
May 2027	Second management review. Audit slice on component 2 (risk management).
June to July 2027	ERP tabletop exercise. Mid-year training refresher.
August 2027	Third management review. Audit slice on component 3 (assurance).
September to October 2027	Safety survey of staff. Register deep clean.
November 2027	Fourth management review. Audit slice on component 4 (promotion). Annual audit summary.
December 2027	Policy re-signed, objectives reset, manual re-issued. One year of evidence, twelve elements, all dated.

The honest cost. Add it up and the cadence above is roughly four to six hours a month of a chief pilot's time, plus the audits and the review days. That is the real price of the mandate for a small operator: not the manual, but a part-time safety job that never ends and that has to be done well enough to survive an inspection. Most of the hours go into drafting, classifying, minuting and assembling records. That is work that can be made much lighter with the right tools, and it is the work we are building for.

Surveillance-visit checklist

Before any CASA visit, confirm you can produce each of these in under five minutes:

Current signed safety policy and objectives
The hazard register, showing entries added or changed in the last 90 days
The last three safety reports and what happened to each
The most recent investigation report
The last three safety meeting minutes
The most recent management review minutes and its action list
The audit schedule and the last completed audit
The corrective action log with closures
The training matrix and the safety manager's training record
The ERP with current contacts and the last exercise record
The manual version register and evidence staff have the current version
Your last monthly safety notice

Want the calendar done for you?

We are building a tool that runs this cadence for small operators: reports from a phone in 60 seconds, drafts of the classification and investigation written in your own manual's language for you to approve, the register kept alive, audit checklists built from your manual, and a one-click evidence pack for CASA. Start with the free Gap Check and leave your email if you want to be one of the founding operators.

Run the SMS Gap Check

Sources

CASA, Multi-Part Advisory Circular AC 119-01 and AC 138-11 v3.0, Safety management systems for air transport and aerial work operators, July 2026, especially sections 5.5 (documentation and records), 7.1 (performance monitoring and audit) and 7.3 (continuous improvement).
CASA, Guide to Sample Safety Management System Manual (SMSM), April 2026.
CASA, Safety management system sample manual and Micro-operator SMSM; Emergency response plan template.

General information for operators, not legal or regulatory advice. Your manual's stated frequencies are the ones CASA will hold you to. Check the current CASA source before acting.