A Hybrid Framework for Airport Safety Oversight: Integrating FAA Part 139 and ICAO SMS

Abstract

Airport safety oversight in the United States has traditionally relied on the prescriptive compliance structure of FAA Part 139, while the ICAO Safety Management System (SMS) emphasizes proactive, performance-based safety management. Although these approaches are often discussed separately, they address complementary dimensions of airport safety. This study develops a conceptual crosswalk that aligns selected FAA Part 139 requirements with the four ICAO SMS pillars: safety policy, safety risk management, safety assurance, and safety promotion. Using publicly available regulatory documents, guidance materials, and oversight reports, the paper compares the strengths and limitations of each framework and identifies areas where prescriptive compliance and SMS-based practices can reinforce one another. The analysis shows that Part 139 provides strong baseline control for high-consequence operational areas, including Aircraft Rescue and Firefighting, pavement condition, lighting, and wildlife hazard management, while SMS adds value through structured hazard identification, continuous monitoring, organizational learning, and safety culture. Based on this comparison, the paper proposes a hybrid oversight framework that preserves mandatory inspection requirements while incorporating SMS-driven processes for adaptive risk management. The framework is intended to support regulatory alignment, reduce gaps between checklist-based and performance-based oversight, and provide a practical basis for future empirical evaluation.