SMS for Part 91 Operators: A Practical Guide

Do Part 91 operators need an SMS?

14 CFR Part 5 governs Safety Management Systems. The FAA revised it in April 2024, effective May 28, 2024, and the applicability section (§ 5.1) is specific about who it covers:

Operator type	Part 5 SMS status
Part 121 air carriers	Mandatory (in place since the original 2015 rule)
Part 135 operators	Mandatory: implement and declare compliance by May 28, 2027
Part 91.147 air tour operators (LOA holders)	Mandatory: same May 28, 2027 deadline as Part 135
Certain Part 21 production/type certificate holders	Mandatory, on staggered deadlines through May 2027
General Part 91 operators (private, corporate, owner-flown, not conducting 91.147 air tours)	Not required: voluntary

Based on 14 CFR § 5.1 as amended April 26, 2024. This is general information, not legal advice. Confirm your own status with your FSDO or aviation counsel.

If your Part 91 flying doesn’t fall under a 91.147 Letter of Authorization, Part 5 doesn’t require you to do anything. Part 61 and Part 141 flight schools are in the same position: not required, but eligible for the FAA’s voluntary SMS acknowledgment process under AC 120-92D. Business aviation flight departments also have an industry-built option: IS-BAO, the International Standard for Business Aircraft Operations maintained by the International Business Aviation Council, which many Part 91 flight departments pursue independent of any FAA mandate.

Why adopt one anyway

“Not required” isn’t the same as “not worth doing.” A few reasons Part 91 operators build a safety program without being told to:

Insurance and underwriting. Insurers increasingly treat a documented safety program as a sign of operational maturity, which can factor into underwriting conversations, a real, practical reason distinct from any FAA requirement.

Client and charter-partner expectations. Management companies, fractional programs, and charter partners often expect SMS-style documentation from the Part 91 aircraft they interface with, even when it isn’t regulatorily required of that aircraft.

Multiple pilots, one aircraft. The moment more than one pilot flies an aircraft (a flight department, a family with more than one pilot, a partnership), informal risk judgment stops scaling. A FRAT and a shared hazard log turn "we should talk about that" into something written down and reviewable.

Getting ahead of the trend. Part 5’s scope has expanded once already, from Part 121-only to include Part 135, 91.147, and Part 21. Operators who build the habit now aren’t starting from zero if the perimeter moves again.

What a Part 91-scaled SMS should include

Part 5 organizes an SMS around four components: Safety Policy, Safety Risk Management, Safety Assurance, and Safety Promotion. None of them require an airline-sized operation to implement in practice:

Safety Policy: a short written statement of what safety means for your operation and who’s accountable for it. For a solo owner-operator, that can be one page.

Safety Risk Management: a pre-flight risk assessment (FRAT) that turns weather, currency, aircraft condition, and personal factors into a go/no-go conversation with yourself or your crew, every flight, not just the ones that feel risky in the moment.

Safety Assurance: a place to log hazards and safety concerns when they come up, and a habit of reviewing them instead of letting them fade from memory.

Safety Promotion: if more than one person flies the aircraft, a way to communicate what’s been learned, such as a bulletin, a shared log, a document that everyone has actually acknowledged reading.

None of this requires enterprise software built for a 200-aircraft fleet. It requires a tool that doesn’t assume you have a training department, a dispatch office, and a compliance team, because most Part 91 operators have none of those.

How I’m Safe SMS fits a Part 91 operation

I’m Safe SMS was built first for Part 61 and Part 141 flight schools, and the same portal now serves Part 91 operators directly, not a separate, cut-down product. What carries over:

Flight Risk Assessment Tool: configurable thresholds and a documented go/no-go record for every flight.

Weight & Balance Recording: linked to the same pre-flight workflow as the FRAT.

Reporting System: near-misses, incidents, and suggestions, with an anonymous option if more than one person flies the aircraft.

Hazard Register: likelihood-and-severity scoring for anything you’re tracking over time.

Document Library: POH, checklists, insurance, and maintenance records in one place, with acknowledgment tracking if you have more than one pilot.

Safety Performance Indicators: a dashboard that shows trends instead of a folder of one-off notes.

Pricing is $35 per aircraft per month, all-inclusive, with a one-time setup fee: the same per-aircraft model whether you’re a 20-aircraft school or a single Cirrus in a hangar. There’s no per-user charge, so adding a co-owner, spouse, or safety pilot to the account costs nothing extra.

Frequently asked questions

Is a Safety Management System mandatory for Part 91 operators?

No, not for general Part 91 operations. 14 CFR Part 5, as revised in April 2024, applies to Part 121 air carriers, Part 135 operators, holders of a Part 91.147 Letter of Authorization (commercial air tour operators), and certain Part 21 production certificate holders. General Part 91 operators (private, corporate, and personal flying outside the 91.147 air-tour rule) are not required to have an SMS. For them, as for Part 61 and Part 141 flight schools, adopting one is a voluntary safety practice, not a compliance requirement.

What’s the difference between Part 91.147 and general Part 91 operations?

Part 91.147 covers commercial air tour operators that hold a specific FAA Letter of Authorization to conduct sightseeing flights for compensation. Those operators are subject to the Part 5 SMS mandate on the same timeline as Part 135 operators. General Part 91 operations (private owner-flown aircraft, corporate flight departments, fractional and managed aircraft not conducting 91.147 air tours) fall outside that mandate.

Does I’m Safe SMS work for a single-aircraft Part 91 owner-operator?

Yes. The platform is priced per aircraft, so it scales down to a single aircraft the same way it scales up to a fleet. A solo owner-operator gets the same FRAT, safety and hazard reporting, document library, and safety-performance dashboard as a multi-aircraft flight school, not a stripped-down version.

How much does SMS software cost for a Part 91 operator?

I’m Safe SMS is $35 per aircraft per month, all-inclusive, billed monthly or annually, plus a one-time setup fee. There is no per-user charge: pricing scales with the size of the fleet, not the number of pilots or family members flying it.