IS-BAO Auditor Newsletter | August 2013

Provisional Stage 2 Audit Recommendations Not Being Used 

We are receiving an increasing number of Stage 2 audit attempts that should be recommended by the auditor as Stage 1 provisional, in accordance with Policy 2012-03. If the operator is not substantially conforming to the standards, especially the SMS standards, then they should be recommended as Stage 1 provisional. Let APM 5.8.2, 6.3.2 and Chapter 7 be your guide in making this determination. Telling the operator at the closing meeting that they will receive a provisional recommendation is preferable to having the audit review group reject the audit and have you tell them later. Call the Audit Manager if you have any doubts about this process.

Criticality of FindingsCriticality of findings need to be determined and communicated to the operator in accordance with APM 6.3 to assist the operator in developing an appropriate remedial action plan.

On a related issue, finding statements should be developed IAW APM 6.2.1 and 6.2.2 or documented on the protocol as simple nonconformity, reference APM 6.2.3. If the item is a NC and not a finding, the notation “ACTION REQUIRED” should be prominently displayed along- side the issue shown in the Analysis of Nonconformities section of the protocol.

Have You Read Your APM Lately?I’m sure you are quite familiar with the contents of the Audit Procedures Manual, however, some audit submissions lead us to believe that a refresher many be in order. Here are some of the apparently little-appreciated sections of the manual:

  • 5.4 – Determining the Objectives of the Evaluation
  • 5.8 – Conducting the evaluation
  • 6.1, 6.2 – Preparing Audit Findings
  • 7.1.5 – Audit Comments
  • 7.2.1 – Determining Audit Results
Forget Something?It’s a great feeling to finish an audit and have the report completed… on to the next project! But, don’t forget to submit the audit for review and registration! In the recent past three auditors failed to submit the audit for processing until the client contacted IS-BAO personnel to inquire about the audit status. Closely allied to this issue is delaying an audit submission by more than a month, for whatever reason; this is all bad customer service, just a matter of degree.

First, this is not a good business practice for the auditor seeking repeat business and, second, it robs the client of months of registration eligibility. Each audit submission to IBAC (me) is confirmed by a return email to the auditor; if you don’t get the confirmation within a few days of the submission, we did not receive it.

Evaluating the SMSIS-BAO Report Form 8.2, Detailed Audit Protocol, provides specific prompts to ensure that the SMS is properly evaluated. These questions are adequate for a stage 1 audit since we are just looking for a solid foundation for all the items that should be in place. When stage 2 and 3 are considered a more in-depth view of the program should be made to ensure that it is performing as intended. These performance features for advanced-stage audits are evaluated and then recorded on the Report Form 8.4 in the section listing the 13 elements of the SMS program.

The primary indicators of performance for these audits are contained in APM 5.8, which provides specific questions the auditor should ask regarding performance and program effectiveness for each audit stage. Some auditors may find it easier to enter the 5.8 questions into a tabular format to facilitate a more thorough investigation of the most critical item in the IS-BAO audit, the SMS. See the attachment to this newsletter for a sample of how this may appear for a stage 3 audit. While this is not a necessary part of the audit paperwork it may assist in discerning levels of performance and effectiveness. Also, it should help to provide specific evidence that should be entered as comments and evidence of performance in the report form.

Words from LarryLarry Fletcher is the IS-BAO Assistant Audit Manager, primarily responsible for all auditor applications and accreditation and Support Services Associates issues. He is also part of the audit review team and provides most the monitoring of auditor performance. Importantly, he has a broad civil and military background in aviation, both as a pilot and maintenance/engineering specialist. His maintenance and engineering background is most useful to us in IS-BAO in unraveling the intricacies of the maintenance world. Here are a few of his insights regarding IS-BAO maintenance and aircraft equipment issues we have recently encountered:

Crash Axes and Other Portable Equipment

Operational regulations pertaining to required items of installed equipment may be conditional statements that refer to the type or location of the operation being conducted. However, the requirement for some items such as life rafts, crash axes and other installed portable equipment may be governed by more fundamental documents such as basic aircraft certification standards, type certificate data sheets and supplemental type certificates for individual aircraft. These items normally apply to large, transport category (Part 25, etc.) aircraft. The operator should be aware of these issues if there is a question regarding their applicability to a particular aircraft.

Life Rafts

A few auditors are indicating in the Chapter 8 Protocols the operator flies with the life rafts only when necessary on extended over water flights. This could be a violation of the Type Certificate Data Sheet (TCDS) for the aircraft being operated, regardless of Part 91 or 135 operations (other States, too). If the Transport Category TCDS indicates the aircraft is approved under FAR 25.801 for ditching, the aircraft will have a Supplemental Type Certificated (STC) interior that includes approved life rafts of sufficient capacity for all occupants of the aircraft.

These rafts must be installed at all times except for required servicing and then for a period of up to 30 days. If an operator desires to increase useful load for the aircraft by removing the rafts the owner/operator may elect to apply for a change to the STC from the STC holder (a cumbersome process…). Additionally, if your aircraft is not approved for ditching and is a Part 25, Transport Category aircraft, ensure you have Type I rafts with a TSO C-70a designation. A Type II is only approved for Part 23, Non-Transport Category aircraft.

While these items are based on US regulations, most States abide by these items, too.

Bits and Pieces

  • 9.1.1 – CAMP is merely a computer based maintenance interval tracking system not an Approved Maintenance Program and Control System.
  • 9.1.4 – For this item it is not enough to report that the operator holds a repair station certificate as a method of indicating full compliance with all the issues in this section. Many operators maintain limited repair station certificates pertaining to a few maintenance/testing procedures and do not have all privileges of many stand-alone repair stations.
  • 9.1.4c – The question asks for the “identification of the approved maintenance schedule/program.” In the US an “FAA approved maintenance program” stated in FAR 91.409f is the correct terminology. The “schedule” mentioned is the correct terminology for European operators.
  • Portions of chapter 13, Operational Health and Safety, apply to all operators, especially 13.1d, e, f.
  • Ensure you request that the operator provide you with a completed audit protocol prior to the on-site audit. Importantly, each protocol item should provide a reference to the operator’s manuals which states a process/procedure proving conformance to the standard.
  • Check your Registered Operators listing on the IS-BAO website to ensure your contact information is accurate. If not notify Paul Lessard with changes.


HomeworkThe 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 objectives of a stage 2 evaluation are to determine whether the operator’s SMS is:

a. Functioning and results being measured.

b. Documented, approved, resourced, and being implemented

c. Compliant with the ICAO Safety Management Manual

d. None of the above

2. “Effectiveness” as used during IS-BAO audits means:

a. Is measured to determine whether desired results are being achieved.

b. That everybody is effectively engaged in, and capable of, reducing safety risks to a level as low as reasonably possible

c. Safety activities are purposefully and appropriately targeted to reduce safety risks to a level as low as reasonably possible.

d. Both a. and b.

3. Criticality of a finding is determined by judging its scope and by the assessed risk of the hazard involved. T/F?

4. A major non-conformity must be reported when:

a. The operator’s SMS is not understood or used by a majority of the organization’s personnel

b. The organization’s safety risk profile has not been reviewed within the past six months.

c. A majority of pilots report that the organization’s SOP is not followed by senior pilots.

d. Both a. and c.

e. all of the above

To confirm your expertise, see the bottom of the page for the references.

Be a discerning and insightful auditor,

John Sheehan

IBAC Audit Manager

Is your auditor accreditation current?– see —

See IS-BAO Policy 2012-02

Answers: 1 – a (APM 5.4), 2 – a (APM 5.7.3), 3 – F (APM 6.3), 4 – d (APM 6.1)4 – e (4.7), 5 – F (4.1.1c)