Understanding FAA SMS Requirements — and Why Safety Risk Assessments Matter for Emerging Part 108 Hazmat UAS Operations

In recent years, the Federal Aviation Administration (FAA) has significantly expanded the scope and rigor of Safety Management System (SMS) requirements across the aviation industry. With the 2024 SMS Final Rule and the continued development of 14 CFR Part 108, certificate holders are moving into a new era of proactive, data‑driven safety oversight—one in which Safety Risk Assessments (SRAs) are not optional, but fundamental.

This article provides a high‑level overview of FAA SMS requirements, explains the regulatory role of SRAs, and highlights how upcoming Part 108 rules will require documented SRAs for unmanned aircraft systems (UAS) operations carrying hazardous materials. Finally, we outline how Elemental Flight Sciences supports operators in building, managing, and maintaining these required safety artifacts.

📘 What the FAA Requires: A Snapshot of SMS

The FAA defines an SMS as a formal, top‑down, organization‑wide approach to managing safety risk and assuring the effectiveness of safety risk controls.

Under 14 CFR Part 5, SMS requirements now apply to a broad range of certificate holders, including Part 121 and Part 135 operators, certain Part 91 LOA holders, and various Part 21 production and type certificate holders.

The 2024 SMS Final Rule extended these obligations, requiring SMS implementation across commuter and on‑demand operators, commercial air tour operators, and type/production certificate holders. The rule aligns the U.S. more closely with ICAO Annex 19 and establishes a proactive, data‑driven safety framework.

At its core, SMS includes four components:

1. Safety Policy

2. Safety Risk Management (SRM)

3. Safety Assurance

4. Safety Promotion

   
   

FAA guidance such as AC 120‑92D provides organizations with acceptable means of compliance for implementing SMS processes tailored to their operation.

🛡️ Safety Risk Assessments (SRAs): The Backbone of SMS

Within the SMS structure, the Safety Risk Management (SRM) component requires organizations to identify hazards, analyze risks, and implement appropriate mitigations. This process must be documented through a Safety Risk Assessment (SRA).

An effective SRA:

• Identifies hazards associated with systems, operations, environments, and personnel.

• Assesses risk using both severity and likelihood metrics.

• Documents mitigations, controls, and verification methods.

• Provides evidence that the organization is meeting or exceeding safety objectives through its SMS.

For certificate holders regulated under Part 5, these analyses are not optional—they are required documentation forming part of the organization’s SMS. FAA oversight processes, including Safety Attribute Inspections (SAIs), explicitly evaluate an organization’s SRM processes and SRA documentation.

📦 The Coming Impact of Part 108: Hazmat Carriage by Drone Will Require SRAs

The FAA’s forthcoming 14 CFR Part 108, currently in the Notice of Proposed Rulemaking (NPRM) stage, will establish a standardized framework for routine Beyond Visual Line of Sight (BVLOS) operations, replacing the waiver‑based structure that currently governs advanced drone operations.

Within this proposed framework, Part 108 introduces two classes of operators—permitted and certificated package delivery operators—with special provisions for those carrying hazardous materials.

Most critically:

Part 108 certificated “will‑carry” operators who transport regulated hazardous materials will be required to submit a hazmat‑specific Safety Risk Assessment (SRA) to the FAA. 

This requirement underscores a crucial regulatory shift: the FAA expects UAS operators entering the hazmat transport space to demonstrate, in advance, that all hazards associated with the aircraft, payload, packaging, operational environment, and personnel are fully understood and mitigated.

Even before Part 108 becomes final, operators preparing for hazmat operations should begin building:

• Baseline SRAs for all operating modes

• Hazard logs linking technical and operational controls to each identified risk

• Mitigation strategies tied to FAA‑recognized barrier models

• Safety assurance mechanisms to verify controls remain effective

• Change‑management processes to keep SRAs current

In short, SRAs will become one of the core technical artifacts required for any organization seeking FAA approval for hazmat‑carrying UAS operations under Part 108.

✈️ How Elemental Flight Sciences Helps Aviation Companies Meet These Requirements

As the regulatory environment for UAS and advanced aviation evolves, Elemental Flight Sciences (EFS) provides specialized engineering and SMS support to help organizations meet FAA expectations with confidence.

We assist certificate holders and UAS operators by:

✔️ Developing FAA‑compliant SRAs

Our team builds SRAs aligned with FAA SRM processes, integrating system safety methods such as FHA, FMEA, and fault‑tree assessments to create defensible, regulator‑ready documentation.

✔️ Supporting Hazmat‑specific assessments for Part 108

We help operators translate 49 CFR hazmat requirements into operational and design‑level risk controls, ensuring that SRAs satisfy the hazmat‑specific obligations defined under Part 108.

✔️ Building safety artifacts that fit your SMS

Whether your organization is newly implementing SMS or refining an existing one, EFS ensures your SRAs integrate seamlessly into your Safety Policy, Safety Assurance processes, and safety‑promotion efforts.

✔️ Preparing organizations for FAA engagement

We support operators throughout FAA interactions, from initial application packages to responses during review cycles.

🔍 Final Thoughts

FAA SMS requirements are reshaping the expectations for aviation safety documentation, and SRAs serve as the foundation of this regulatory approach. With Part 108 poised to transform BVLOS and drone‑based logistics—and with hazmat‑specific SRAs becoming a prerequisite for certificated operators—now is the time for aviation organizations to strengthen their safety frameworks.

Elemental Flight Sciences stands ready to support operators in navigating these evolving requirements with rigor, expertise, and industry‑leading engineering insight.

If you’d like assistance developing, managing, or reviewing your Safety Risk Assessments—or preparing for Part 108 compliance—reach out anytime.