FAA SMS Audit Preparation Guide

20 Common Questions and Compliance Documentation Tips

Provided by SMS Pro — Your Partner in Aviation Safety

Introduction

This FAA SMS Audit Preparation Guide equips U.S.-based airlines and MROs with tools to excel in FAA Safety Management System (SMS) audits under 14 CFR Part 5. Featuring 20 common audit questions and practical tips for documenting compliance, it reduces audit stress and ensures readiness. Use this guide to align with FAA standards, leveraging resources like SMS Pro’s blog. For streamlined SMS management, explore SMS Pro’s cloud-based tools.

Preparation Tips

  • Conduct Internal Audits: Use FAA checklists or SMS Pro templates to identify gaps before the audit.
  • (https://aviationsafetyblog.asms-pro.com/blog/how-to-conduct-internal-sms-audits-in-aviation-industry)
  • Organize Documentation: Centralize records in an SMS database for easy retrieval.
  • (https://aviationsafetyblog.asms-pro.com/blog/aviation-safety-audits-safety-managers-perform-well)
  • Train Staff: Ensure employees know their SMS roles and can answer auditors confidently.
  • (https://aviationsafetyblog.asms-pro.com/blog/4-tips-to-pass-aviation-sms-audits-like-the-professionals)
  • Review Past Audits: Address previous findings to avoid repeat non-compliance.
  • (https://aviationsafetyblog.asms-pro.com/blog/9-best-strategies-for-aviation-safety-audit-preparation-including-free-audit-checklists)

20 Common FAA SMS Audit Questions and Documentation Tips

Below are 20 questions auditors may ask during an FAA SMS audit, based on 14 CFR Part 5 and guidance like AC 120-92B, with tips to document compliance effectively.

1. Is your safety policy signed by the accountable executive and regularly reviewed?

Tip: Maintain a signed, dated policy in your SMS manual, reviewed annually. Include evidence of executive review (e.g., meeting minutes).

(https://aviationsafetyblog.asms-pro.com/blog/reviewing-aviation-safety-policies-for-sms-programs-template)

2. How are safety objectives defined and measured?

Tip: Document specific, measurable objectives (e.g., “Reduce incidents by 15%”) in the SMS manual. Track via safety performance indicators (SPIs) in reports.

3. Are safety responsibilities clearly assigned across all levels?

Tip: Create an accountability framework in the SMS manual, listing roles (e.g., SMS Manager, Safety Committee) and duties. Include org charts.

4. Does your just culture policy encourage reporting without fear of reprisal?

Tip: Include a just culture statement in the safety policy. Provide training records and anonymized reporting data as evidence.

5. How is your hazard reporting system implemented?

Tip: Document the reporting process in the SMS manual. Show electronic or paper submission forms and a log of reported issues.

(https://aviationsafetyblog.asms-pro.com/blog/aviation-safety-audits-101-prep-and-pass-free-audit-checklists)

6. Is your risk assessment process consistent and documented?

Tip: Use a 5x5 risk matrix (per FAA Order 8040.4C) and document assessments for sampled hazards. Include justification for ratings.

(https://aviationsafetyblog.asms-pro.com/blog/avoid-faa-penalties-build-a-compliant-risk-matrix-in-aviation-sms)

7. Are mitigation strategies monitored for effectiveness?

Tip: Maintain a hazard register with mitigation plans and follow-up reviews. Show evidence of periodic checks (e.g., quarterly reports).

8. How is safety data collected and analyzed?

Tip: Use an SMS database to store incident and hazard data. Provide sample analytics reports showing trends and actions taken.

(https://aviationsafetyblog.asms-pro.com/blog/aviation-safety-audit-preparation-4-free-sms-audit-checklist-templates)

9. Is there a process to escalate high-risk issues to leadership?

Tip: Document an escalation procedure in the SMS manual. Show examples of escalated issues and leadership responses (e.g., emails).

10. Are safety performance indicators (SPIs) defined and tracked?

Tip: List SPIs (e.g., incident rates) in the SMS manual. Provide dashboards or reports showing SPI trends over time.

(https://aviationsafetyblog.asms-pro.com/blog/audit-checklist-10-things-to-do-before-aviation-sms-audits)

11. How often are internal SMS audits conducted?

Tip: Schedule annual internal audits and document results with checklists and corrective action plans. Show audit reports.

(https://aviationsafetyblog.asms-pro.com/blog/how-to-create-an-aviation-sms-audit-plan)

12. Is there evidence of continuous improvement in the SMS?

Tip: Document responses to past audit findings and process updates. Provide before-and-after examples of improved procedures.

(https://aviationsafetyblog.asms-pro.com/blog/9-best-strategies-for-aviation-safety-audit-preparation-including-free-audit-checklists)

13. Have all employees received initial SMS training?

Tip: Maintain training records with employee names, dates, and course content. Show completion certificates or logs.

(https://aviationsafetyblog.asms-pro.com/blog/4-tips-to-pass-aviation-sms-audits-like-the-professionals)

14. Is recurrent SMS training provided, and how often?

Tip: Document a recurrent training schedule (e.g., every 12–24 months). Provide records of recent sessions and attendance.

(https://aviationsafetyblog.asms-pro.com/blog/4-tips-to-pass-aviation-sms-audits-like-the-professionals)

15. How do employees provide feedback on SMS performance?

Tip: Document feedback mechanisms (e.g., surveys, safety meetings). Show sample survey results or meeting minutes.

16. Is your hazard register up-to-date and comprehensive?

Tip: Maintain a digital hazard register with entries for top hazards, including descriptions and risk levels. Show recent updates.

(https://aviationsafetyblog.asms-pro.com/blog/audit-checklist-10-things-to-do-before-aviation-sms-audits)

17. Are past audit findings addressed and closed?

Tip: Keep a log of past findings with corrective actions and closure dates. Provide evidence of implementation (e.g., updated policies).

(https://aviationsafetyblog.asms-pro.com/blog/how-to-conduct-internal-sms-audits-in-aviation-industry)

18. How are vendors or contractors monitored for SMS compliance?

Tip: Document vendor oversight processes in the SMS manual. Show audit reports or compliance certifications for contractors.

(https://aviationsafetyblog.asms-pro.com/blog/9-best-strategies-for-aviation-safety-audit-preparation-including-free-audit-checklists)

19. Is emergency response planning integrated into the SMS?

Tip: Include an emergency response plan in the SMS manual. Provide drill records or tabletop exercise summaries.

(https://www.federalregister.gov/documents/2024/04/26/2024-08669/safety-management-systems)

20. Can you demonstrate SMS scalability for your operation’s size?

Tip: Document how SMS processes (e.g., reporting, auditing) are tailored to your operation’s complexity. Provide a scalability statement.

(https://www.federalregister.gov/documents/2023/01/11/2022-28583/safety-management-systems)

Next Steps

  • Conduct a mock audit using this guide’s questions and FAA checklists.
  • Centralize documentation in an SMS database like SMS Pro for auditor access.
  • Train staff on their SMS roles and audit expectations.
  • Download additional resources from asms-pro.com to enhance compliance.