ALIGNMENT
Safety Policy§5.21–5.27
Safety Risk Mgmt§5.51–5.57
Safety Assurance§5.71–5.75
Safety Promotion§5.91–5.93
ARGUS GoldAudit Standard
OSHAFederal / Parallel
Best PracticeSupporting Regs
SMS Core
SMS Manual
Documentation system
§5.25: Required
Must document entire SMS (policy, objectives, procedures, processes, and accountabilities)
§5.51–5.57
Documents SRM methodology, hazard ID processes, risk assessment procedures
§5.71–5.73
Documents safety assurance processes, monitoring systems, and CAPA framework
§5.91–5.93
Documents safety training requirements and safety communication plan
AAS 1.5.1: Required
SMS Manual must document all requirements, processes, and procedures covering all four SMS pillars. Structure and content evaluated.
SMS Reporting Platform
Hazard / incident intake
§5.53(a): Required
Confidential employee reporting system is an explicit SRM mandate — not optional
§5.73(a)
Platform records data for safety performance monitoring and trend analysis
§5.93: Supports
Closing the loop on reports communicates safety responsiveness to workforce
AAS 1.6.6: Required
Reporting system must be accessible to all personnel, provide feedback to reporters, and identify voluntary vs. mandatory report types. Activity and closure rates evaluated.
§5.21–5.23: Required
Accountable executive, safety objectives, non-punitive reporting commitment, resource allocation (all required elements)
§5.93: Supports
Published policy is the primary tool for communicating safety commitment to the workforce
AAS 1.2.1: Required
Signed AE policy must include just culture statement, non-retribution policy, Code of Ethics, resource commitment, and annual review date. Posted prominently. Pass/fail item.
Manuals & Programs
IEP Manual + IEP Program
Internal auditing / compliance
§5.51: Supports
Audits verify hazard controls are functioning as designed; findings feed back into SRM cycle
§5.71–5.75: Required
Continuous monitoring, internal evaluation, and CAPA for deficiencies. IEP is the direct fulfillment of Safety Assurance. Also supports ARGUS and FSDO external audit readiness.
AAS 1.7.3–1.7.6: Required
IEP must be documented with a scheduled audit program. Findings require root cause analysis and verified corrective action closure. Schedule compliance reviewed.
ERP Manual + Training & Mgmt
Emergency response program
§5.27: Required
Emergency response planning is explicitly required under Safety Policy. Must be documented and exercised.
§5.71: Supports
After-action reviews from drills generate CAPA items; feeds SA continuous monitoring
§5.91: Required
ERT training and recurring drills fulfill the safety training requirement under Safety Promotion
AAS 2.1–2.2: Required
ERP must cover aircraft accidents, missing aircraft, bomb threats, hijacking, facility accidents, and environmental events. ERT designated with documented duties and current contact information.
HazCom Program
OSHA SDS / MSDS accessibility
Partial link
Chemical hazards can enter the reporting system; HazCom incidents may be SMS-reportable events
29 CFR 1910.1200: Required
SDS accessibility, chemical inventory, employee right-to-know, and labeling. Separate federal mandate running parallel to Part 5. Audit exposure if missing.
Employee Injury Reporting
OSHA 300 log / recordkeeping
Partial link
Ground injuries are SMS-reportable hazard events that enter the hazard reporting system and SRM cycle
§5.71: Supports
Injury trends inform safety assurance monitoring; CAPA issued for repeat injury types
29 CFR 1904: Required
300 log recordkeeping, 300A annual summary posting, ITA electronic submission (NAICS-dependent). Separate from Part 5 but integrated with SMS hazard reporting in practice.
FRAT
Flight risk assessment — ORA/ORAC
§5.51–5.55: Required
FRAT is the operational expression of SRM. ORA / ORAC identifies and assesses flight risk pre-departure, directly fulfilling hazard ID and risk assessment requirements each operation.
§5.73: Required
FRAT data feeds safety performance monitoring — trends in scored flights inform SPI reporting and SRB management review
AAS 1.6.1: Required
FRAT design, scoring criteria, pilot compliance, go/no-go thresholds, escalation procedures, and integration with SPI reporting all evaluated. Auditors assess active use vs. cosmetic compliance.
AC 120-92B
FAA advisory circular reinforces pre-flight risk assessment as a safety assurance best practice and SRM mechanism
Fatigue Risk Management
FRMP (Duty / rest tracking)
§5.51–5.55: Supports
Fatigue is an identified hazard under SRM. FRMP documents the controls used to mitigate fatigue risk in flight operations — a direct SRM deliverable for a known, recurring operational hazard.
§5.73: Supports
Duty time data and fatigue-related reports tracked as SPIs; trends reviewed at Safety Review Board
AAS 6.1–6.2: Required
Flight and duty time limitations documented for all crew. Deviation process documented with management authorization levels and risk assessment requirement. Records reviewed for compliance.
14 CFR §135.261–135.273
Part 135 flight and duty time limits; FRMP documents how compliance is actively tracked and managed. Best practice to formalize even where a standalone program is not explicitly mandated. (ARGUS Gold Requirement)