Clear Approach Safety
Clear Approach Safety

Part 135 on-demand & commuter

SMS software for Part 135 operators

Every Part 135 certificate holder is now under 14 CFR Part 5, regardless of fleet size. This is what that obligation looks like in practice, and how to meet it without a five-figure consulting engagement.

You are in scope, and size is not an exemption

The FAA published its final SMS rule on 26 April 2024. It extended the requirements of 14 CFR Part 5 — which had applied only to Part 121 air carriers — to all certificate holders operating under Part 135, to commercial air tour operators holding a letter of authorization under § 91.147, and to certain Part 21 type and production certificate holders.

There is no small-operator carve-out. A single-pilot, single-aircraft Part 135 certificate holder carries the same obligation as a forty-aircraft fleet. The FAA expects the SMS to be scaled to the size and complexity of the operation, but not skipped.

The gap most Part 135 operators are sitting in right now

If you submitted an implementation plan and the FAA has signed off on it, you have described a system. You have not yet run one. The Declaration of Compliance is not a statement that you have a plan — it is an attestation that the SMS is implemented and functioning, backed by records that show it has been.

That is a materially different job, and it is a continuous one. Hazards have to be reported and captured. Each one has to be assessed for likelihood and severity. Risk decisions have to be recorded, controls applied, and the effect of those controls verified. Policies have to be approved, distributed and acknowledged. All of it has to survive a records request months or years later. See what an approved implementation plan actually obliges you to do.

What a Part 135 operator needs from an SMS platform

Reporting your crew will actually use

The single biggest failure mode in a small operation is that hazards never get reported. When the safety manager is also the chief pilot, and the reporter is one of four line pilots, attribution is a real deterrent. Reports here can be submitted anonymously, and reports that are not anonymous can still be exported with the reporter name and tail number redacted in one click. Crew get their own portal, separate from the assessment queue.

Aviation fields, not a generic incident form

Reports carry tail number, ICAO airport code, aircraft type, and an occurrence time recorded in both local and UTC. Six report types cover accidents, incidents, hazards, near misses, voluntary reports and QA findings, with contributing-factor tagging across human, technical, environmental, organisational, procedural and communication factors.

The 5×5 matrix your inspector already uses

The standard FAA matrix from AC 120-92D is seeded and ready. Likelihood multiplied by severity, banded into acceptable, acceptable with controls, and unacceptable. Every hazard carries both an initial and a residual score, and controls get a validation window with an automated reminder if that window closes without a residual assessment being recorded. How the 5×5 matrix works in detail.

Evidence you can hand over

Safety reports and their assessments export to PDF over any date range, with redaction on by default. That is what makes confidential reporting and audit evidence compatible rather than in tension.

Scaled pricing

Plans start at $99 per month for a single-aircraft operation and $299 for a small flight department, against the fifteen to fifty thousand dollars a consultant-led implementation typically costs. Full detail on the pricing page.

See whether it fits your operation

Twenty minutes, no card. Tell us what certificate you hold and where your implementation plan stands, and we will show you the parts that apply to you.