IS-BAO Auditor Newsletter – August 2012
Stage 2 or 3?
As the IS-BAO program matures more operators are eligible for stage 3 audits. But, are all stage 2 registrants really mature and sustainable organizations worthy of stage 3?
Stage 3 is designed to indicate that an operator has reached the pinnacle of IS-BAO conformance and performance and is merely sustaining that high level of performance. Auditors are discovering that some performance-related items that should have been caught on the stage 2 audit were not discovered at that time and were carried forward for them to discover on the stage 3 audit. Or, if an operator was once operating at a high level of performance and effectiveness that would have carried them through to stage 3, somewhere along the line they had lost that edge.
Regardless of the reason, the audit review committee has been denying some stage 3 submissions because of significant effectiveness and performance faults and missing items in the operator’s SMS, particularly safety performance monitoring and measuring and compliance monitoring issues. While the overall safety culture and SMS effectiveness was apparently positive in these cases, a number of oversights regarding training, monitoring and performance measurement were lacking.
There should be no stigma associated with maintaining stage 2; that level of performance fully meets IS-BAO performance standards. But, all should aspire to the highest level of performance to realize the full benefits of the SMS and IS-BAO programs. And, those conducting stage 2 audits, do your successors a favor and make sure that the operator is really performing to a stage 2 level.
Maintaining High Level SMS Involvement
For operators making it to Stage 2 or even 3 congratulations are in order. However, once those hurdles have been crossed there may be a tendency to slack off on the effort, relying in the “We made it!” philosophy; a natural but potentially hazardous condition.
This is the time when the operator needs to shift gears from the “we can make it to the next level” to the “now that we’re there how do we keep it fresh and alive?” mode. This requires a different way of viewing the SMS, one that looks at performance issues and continuing goal achievement.
Comments, Again…
Auditor’s comments and observations sometimes appear to be an attempt to fill space rather than to inform either the operator or anyone else reading the report. Comments like, “Complete and effective, “Complete and appropriate,” and “Good documentation and comprehensive records” mean little since these statements either repeat the essence of the protocol block already checked. So, tell me something I don’t already know after you have checked the block confirming conformance. What’s good or not-so-good about their SMS training, Safety assurance or Occurrence programs? How has the organization reacted to these features? Are these elements really that perfect? Is the organization really continuously improving?
And, don’t forget to give us comments about the non-SMS protocols in advanced stage audit indicating that sampling of these items has occurred and that the operator is still on the right track. This is especially significant when policy, process and procedure changes have occurred since the last audit.
Auditor Accreditation and Currency
Check your accreditation expiration date. For auditors whose accreditation expires this December, that date is rapidly approaching. Sign up for a convenient workshop from those listed on the IS-BAO Workshop Schedule.
IS-BAO Policy 2012-02 provides information regarding the new auditor currency requirements. Ensure that you are current prior to agreeing to perform an audit.
Finally, auditors receiving their initial or renewing their accreditation after 1 January 2013 will receive an accreditation validity period that will expire at the end of the 24th month following their initial or renewal accreditation date.
Good Report Card
We receive comment forms from most operators who have recently undergone an audit. While we get many “plain vanilla” reports, we occasionally get some like the following:
“Mr. XXX was very familiar with the IS-BAO protocols and was very organized and prepared prior to beginning our Stage I audit. We sent him our Flight Operations Manual a couple of weeks before the audit and he arrived very familiar with our operation. His preparation made the audit an easy process and one that had minimal impact on our busy flight department. He was through in his review and made sound and realistic recommendations so that we can meet and/or exceed IS-BAO standards. He was arrived on time every morning and was professional, prompt and quickly responded to any questions we had prior to and during the audit. We would recommend his services to any flight department seeking IS-BAO certification.”
Something to shoot for…
Maintenance Comments
The audit review group doesn’t see too many comments regarding maintenance. While this may not be a very familiar topic for some auditors it is a very important aspect of the IS-BAO audit. Here are a few important items that are worthy subjects on which comments may be appropriate:
- How good, complete, effective, etc. is the maintenance control system?
- If no in-house maintenance is performed is there an adequate description of the processes and procedures used to oversee maintenance issues?
- Is the tool/precision instruments calibration program really working?
- How does the operator know that maintenance personnel are truly qualified to perform maintenance on specific aircraft types?
- How detailed and effective is the maintenance discrepancy reporting and rectification program?
- Are there detailed procedures to ensure that maintenance records and maintenance record tracking systems are accurate and effective?
- How do PICs know that they are being assigned an airworthy aircraft?
Reduced Vertical Separation Minimum (RVSM) Monitoring Requirements
ICAO Annex 6 provides RVSM standards for aircraft operations. These requirements are mandatory of both domestic and international operations, but each State has a different interpretation and rules regarding these standards. Each IS-BAO registered operator capable of operating in a RVSM environment is required to have applicable documented monitoring procedures.
New monitoring requirements within the US went into effect in May 2012. A synopsis of all FAA RVSM guidance is available on the FAA RVSM web page Also, see NBAA’s Business Aviation Insider
Other sites are also available, FAA RVSM Minimum Monitoring Policy and North American Approvals Registry and Monitoring Organization (NAARMO)
Approved Maintenance Inspection Programs
This article primarily applies to US private operators but the principles involved apply worldwide. The issue is what constitutes an Approved Maintenance Inspection Program and how it is derived from the regulations as it relates to the private aircraft operators; we will address the commercial operators in next newsletter.
Many auditors are misinterpreting the AVTRAK, CMP, CESCOM, CAMP Systems computer maintenance tracking and planning programs for approved maintenance inspection programs. These are merely computer tracking programs that mirror the Aircraft Maintenance Manual Chapter 4 & 5 specific maintenance inspection interval requirements. The Manufacturers Aircraft Maintenance Manuals should all be State-approved documents; the computer tracking programs are not approved by any regulatory agency.
Each aircraft manufacturer has one or more Recommended Maintenance Inspection Programs that can be chosen by the owner or operator but only one can be selected and identified in the permanent log book as their approved maintenance inspection program.
In the US requirements for inspecting multi-engine turbojet or turbo prop aircraft are derived from FAR 91.409(e) and the requirement for selecting one of the four approved maintenance inspection programs and identifying it in the aircraft log book is listed in FAR 91.409(f). The four programs have differing applications.
91.409(f) – The registered owner or operator of each airplane or turbine-powered rotorcraft described in paragraph (e) of this section must select, identify in the aircraft maintenance records, and use one of the following programs for the inspection of the aircraft:
(1) A continuous airworthiness inspection program that is part of a continuous airworthiness maintenance program (CAMP) currently in use by a person holding an air carrier operating certificate or an operating certificate issued under part 121 or 135. This is a CAMP program as specified by an Operations Specification not to be confused by the CAMP Systems computer tracking program.
(2) An approved aircraft inspection program (AAIP) approved under part 135.419 of this chapter and currently in use by a person holding an operating certificate issued under part 135 of this chapter.
(3) A current inspection program recommended by the manufacturer.
(4) Any other inspection program established by the registered owner or operator of that airplane or turbine-powered rotorcraft and approved by the Administrator under paragraph (g) of this section. However, the Administrator may require revision of this inspection program in accordance with the provisions of part 91.415. A good example of this is the Dassault Falcon On Condition Inspection Program (OCIP) which is a high utilization maintenance program carried out on a monthly basis of prescribed maintenance tasks.
The typical maintenance inspection program selected by private operators is FAR 91.409(f)(3) since the other programs usually apply to commercial operators.
Bits and Pieces
- Comments placed in the protocol by the operator to prepare the auditor for the audit are not considered to be true audit comments by the audit review group. The comments and observations we want to see are those made by the auditor after their on-site visit.
- Auditors should be using the 2012 protocols now.
- Commercial operators flying into France should be aware their air law requires a flight data analysis program for each aircraft equipped with a flight data recorder. Some commercial operators have reported difficulties with SAFA checks on this issue.
- Put a Y, N or N/A next to each protocol item, not just section headings. If all items are not marked we can’t determine whether the audit is complete.
- Don’t refer to a maintenance record tracking system such as CMP or CESSCOM when commenting on an approved maintenance program. CMP, CESSCOM are not maintenance programs, merely a means of ensuring compliance with the program. See article, above.
- “Person responsible for maintenance” – standard 4.1.1c. This function must be held by a person within the operator’s organization. It cannot be delegated, even if there is one person in the flight department. That person can contract this function to someone outside the organization but the responsibility requirements still rests with the person within the organization assigned this task.
- Don’t interview just operator management personnel, especially for stage 2 & 3 audits. Find out whether the information you hear from the top of the organization has found its way throughout the organization to the most junior personnel. See APM 4.8.2.
- For European operations: TCAS 7.1 software is mandatory for Europe operations. Us operators see InFO 12010
Homework
The following open-book questions are designed to keep you current on the standards and audit procedures. Don’t send us the answers; this is just for you:
1. The maintenance control system shall include defect reporting and rectification control procedures for which of the following?
a. Recording defect rectification in the aircraft maintenance records
b. Detecting defects that recur and identifying those defect as recurring defects
c. Identifying maintenance technicians authorized to rectify defects
d. Communicating rectification procedures to the person recording the defect
2. Organizations must identify a safety manager who has no other assigned duties. T/F
3. Audit interviews confirm that no emergency or abnormal situations are simulated during flight when passengers are on board. However, this restriction is not stated in the operations manual or any other policy document. Which of the following is true?
a. This is an IS-BAO non-conformity.
b. This is okay since the operator is in conformance with the national regulations.
c. This is N/A because the operator does not have to state this in any form of policy.
4. A non-helicopter qualified auditor may conduct an audit for an operator using several fixed-wing aircraft and a single helicopter used only for executive transportation. T/F
To confirm your expertise, see the bottom of the page for the references.
Be a discerning and insightful auditor,
John Sheehan
IBAC Audit Manager
Are you current?
See Policy 2012-02
Answers: 1 – b-9.1.6; 2 – F-3.2.1c; 3 – a-10.1; 4 – T-A3.4.2