Things get even worse when the operator tries to pair their hard-earned part 5-conforming SMS Manual with software. Returning to the seven safety Safety Management Systems (SMS) attributes, you won’t find them in 14 CFR part 5. AC 120-92D discusses them in Appendix F. The real acid test of whether your SMS design will be accepted by FAA lies in their review of your SMS Manual in conjunction with the SMS design validation DCTs. Bottom line: If SMS processes (such as safety hazard reporting, risk analysis, risk assessment, risk acceptance, investigation, corrective action plan development, control implementation, etc.)
