14 CFR §5.1 Every element, on every pack — verified, not assumed

The most rigorous SMS compliance declaration pack a Part 135 operator can file.

SMS-Engine assembles a documentation-complete SMS compliance declaration pack — every required element, every gap analysis, the implementation timeline, the safety policy, and the acceptance checklist — checked against the letter of 14 CFR Part 5 before a specialist releases it.

Every element of 14 CFR Part 5Four SMS components, gate-checkedGap analysis · implementation plan · safety policySpecialist release on every pack10-business-day SLA
Why declarations fail

A single missing element can ground your operation.

An FAA Part 135 operator's SMS compliance declaration is only as strong as the documentation behind it. Miss one of the four required components, skip a gap analysis, misalign the implementation timeline, or fail to document safety policy acceptance — and the declaration can be rejected, delayed, or expose the operator to enforcement action.

Most operators run this by hand, from memory, once or twice a year. The regulation has not been read end-to-end since the last time it mattered. That is exactly where completeness gaps hide.

SMS-Engine exists to close that gap with a single, exhaustive standard applied identically to every file.

1 of 4
missing SMS components is enough to jeopardize a declaration
The benchmark

Measured against the letter of the regulation — section by section.

We do not summarize the law and hope. Every pack is scored against a versioned rule pack tied to the exact text of 14 CFR Part 5. These are the provisions each pack is held to.

§5.3(a)

Safety policy and objectives

Documented management commitment, safety accountability, and a safety policy that is communicated and endorsed — all present, or the pack does not release.

§5.3(b)

Safety risk management

A documented process for hazard identification, risk assessment, and mitigation — including a risk matrix and acceptance criteria.

§5.3(c)

Safety assurance

A documented process for monitoring, measuring, and analyzing safety performance, including internal audit and corrective action procedures.

§5.3(d)

Safety promotion

A documented process for training, communication, and fostering a positive safety culture.

§5.1(b)

Implementation plan

A phased implementation timeline with milestones, responsible parties, and evidence of progress — verified against the operator's size and complexity.

§5.5

Acceptance and continuous improvement

Documented acceptance of the SMS by accountable management, plus a process for periodic review and improvement.

How a pack is built

Intake to specialist release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human specialist signs every release. That order is never reversed.

01

Gap Scan

Upload your existing SMS documentation. We return a free completeness read: which Part 5 elements you already have, and which are missing.

02

Evidence & gap analysis

As your authorized clerical agent, we review your existing policies, procedures, and records against the Part 5 rule pack and build a gap analysis matrix.

03

Grounded drafting

The four SMS components are drafted from your validated data and the Part 5 rule pack into field-locked templates — no legal opinions, no invented facts.

04

Deterministic completeness gates

Each component is checked against the rule pack; the implementation plan is verified for milestones and timelines; the acceptance checklist is resolved. Any failure blocks release.

05

Specialist release

A compliance specialist reviews the exception queue and signs the release. High-value or complex operations route to aviation attorney review first.

06

Delivery

You receive the pack: declaration document, gap analysis, implementation plan, safety policy, acceptance checklist, and a compliance calendar — ready for the operator to submit under its own name.

The bar we hold

Rigor you can measure.

100%
Specialist-released
No pack ships without a human signature.
10 days
Standard SLA
From complete intake to released pack.
<1%
Critical-defect target
Tracked against a gold-standard pack library.
4
SMS components
Safety policy, risk management, assurance, promotion — every applicable element.
Why SMS-Engine

Built to be the most thorough option an operator has.

Documentation-complete, by design

The deliverable is completeness itself — every Part 5 element accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.

In its lane, on purpose

We prepare documentation and run gap analyses as your clerical agent. We never submit to the FAA, give legal advice, or act as your compliance officer.

Engagement

Flat fee, per released pack. No contingency, ever.

Simple, predictable, and aligned with a documentation standard — not a cut of any recovery.

  • A free Gap Scan before you commit — see exactly what is missing.
  • One flat fee per released SMS Compliance Declaration Pack; disclosed pass-through research fees.
  • Optional fixed-fee attorney review for complex or multi-base operations.
  • Optional Compliance Continuity Add-on for ongoing monitoring and annual review support.
FAQ

Questions, answered precisely.

Is SMS-Engine a law firm?
No. SMS-Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex operations.
Do you submit the declaration to the FAA?
Never. SMS-Engine is not a regulatory filing service and does not submit documents to the FAA. The operator remains responsible for all submissions and compliance.
What makes a pack 'complete'?
Completeness is defined by the regulation: the four SMS components documented, the implementation plan with milestones, the safety policy accepted, and the gap analysis resolved. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is ten business days from complete intake to a specialist-released pack. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released pack, plus disclosed pass-through research costs. No contingency and no percentage of any operational revenue.

See what's missing before it grounds your operation.

Start with a free Gap Scan. Send your existing SMS documentation and we'll return a completeness read against every section of 14 CFR Part 5.

Documentation-completeness service · not legal advice · the operator submits every declaration.