IS-BAO Auditor Newsletter | August 2014

IS-BAH Has Arrived

Implemented on July 1, 2014, following 2 years of development, the International Standard for Business Aircraft Handling (IS-BAH) provides FBO’s and Aircraft Handling Agencies with a set of industry best practices (benchmarks) that incorporates a registration process which includes a validation of a business aircraft handling organization’s Safety Management System (SMS). IS-BAH is the outcome of a blending of the NATA’s Safety First Ground Handling Standard and the structure and content of the International Standard for Business Aircraft Operations (IS-BAO). This joint venture by the International Business Aviation Council (IBAC) and the National Air Transportation Association has resulted in a program that is offered by IBAC through its member associations. Information concerning how to purchase the IS-BAH manual, register for a “Fundamentals of IS-BAH” workshop, or apply to become an IS-BAH accredited auditor can be found by visiting www.ibac.org and selecting IS-BAH.The inaugural set of workshops, fundamentals and auditor, with be held in Paris, France on August 27 and 28. Within North America the first workshops will be conducted in Atlanta, Georgia on September 17 and 18 at the Flight Safety Inc. training center, located at ATL.

Reporting Advanced Stage Audits

This year a significant number of existing registrants will be receiving Stage 2 and 3 audits. Since a number of recent advanced stage audits have not contained adequate supporting descriptions of the operator’s IS-BAO program maturity and sustainability, a review of those issues may be useful.

Stage 1 audits ensure that a SMS infrastructure is in place and that safety management activities are appropriately targeted. Stage 2 concentrates on safety management activities and their effectiveness. Stage 3 confirms that safety management activities are fully integrated into the operator’s operations and that a positive safety culture is being sustained. See chapter 5 of the Audit Procedures Manual for more detailed descriptions of these audit expectations.

Merely checking the appropriate boxes in the SMS section of the protocol does little for either the operator, audit review committee or future auditors to understand why the operator should be advanced to the next audit stage or to maintain a Stage 3 level. Therefore, an adequate description of the SMS features, personnel usage and program effectiveness is required to substantiate the auditor’s claims. Descriptions of the operator’s safety policy and objectives, risk management practices, safety assurance program and methods of promoting these features are appropriate subjects to describe. The description should be capped with a substantial statement regarding the effectiveness of the overall program.

US Minimum Equipment Lists

We specify an MEL for IS-BAO where a Master MEL (MMEL) is available because ICAO does so in their standards. Since the FAA will not approve a Part 91 MEL, only issuing a Letter of Authorization (LOA) for a MMEL to be used as an MEL. The MMEL LOA is acceptable for use within the US, unfortunately, many operators miss the point that they must also devise detailed maintenance and operations procedures to be used the MMEL. While IS-BAO will accept a LOA for N-registered aircraft when detailed M&O procedures have been added, overseas regulators may not, although anecdotally the LOA has been accepted as an authorizing document during foreign ramp checks.

Let us know when you have an audit scheduled

It is difficult for the IS-BAO staff to determine whether an auditor is current per Policy-2012-02 prior to receipt of an audit. Therefore, please notify us of impending audits as far in advance of the scheduled date as possible so that we may check your currency and assist you in becoming current prior to the audit, if needed. Technically, audits conducted by non-current auditors are invalid.

Standards Creep…

We occasionally receive comments from auditors and registrants regarding standards creep, the tendency for the number IS-BAO standards to increase over time, with few being removed. Since many of our standards are derived from ICAO standards and recommended practices to ensure that IS-BAO registered are acceptable to a maximum number of States, it is understandable that the standard will grow over time, yet only as allowed by the industry via the IS-BAO Standards Board.

Best practices derived from industry-recognized organizations, IBAC affiliates and State requirements are carefully vetted by the IS-BAO staff and the IS-BAO Standards Board to ensure relevancy and criticality. Most of these practices are introduced as recommended practices and only after a year or two of use by registrants they may be adopted as standards.

We attempt to keep the creep to a minimum but are driven by outside forces to consider a variety of international, state and industry for inclusion in the standard. Normally, less than half of the inputs for change are adopted after the staff and the Standards Board evaluates the proposals.

Extensions to Registration Expiration Dates

If the IS-BAO system is working correctly, little or no preparation is needed for subsequent audits. That is, the upcoming audit looks at events occurring since the last audit, not at a future period. Yet, a surprising number of operators request extensions of their registration period of up to six months, stating that they “must get ready for the audit.” This type of request is routinely denied.

Legitimate requests for extensions due to conflicts arising from major changes within the department, heavy vacation or training schedules, loss of personnel or seasonal increased flight demands are considered on their merits, usually resulting in an extension of not more than 30 to 45 days. Check with auditmanager@ibac.org.

Bits and Pieces

• In the Operator Name and Address block of the report, provide the address of the main operating base. If additional registration or location information is desired/available place it in the Report Summary section.
• Operator Remedial Action Plans must include a target date in accordance with APM 7.3.3
• Some acronyms are not well known within the business/charter aviation community. Using obscure or little used acronyms/abbreviations may prove confusing and frustrating to the reader. If in doubt, spell it out!

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. Answers and references are provided below to confirm your excellence!

1. 1. When conducting stage two or three audits the evaluation of the effectiveness of the SMS will be considered the primary focus for the audit. However, at least ___% of the protocols for each chapter must be assessed to substantiate that the operator is in conformity with the requirements of the IS-BAO.a. 25b. 50c. 75d. No percentage has been established.
2. 2. Personnel who have a role in the emergency response plan should be trained in their role and the plan ______ be exercised in order to test its integrity.a. shouldb. shallc. should be encouraged tod. not a valid statement
3. An organization’s safety policy shall reflect organizational commitments regarding safety; it shall: (which statement is incorrect)a. include a clear statement about the provision of the necessary resources for the implementation of the safety policyb. be communicated, with visible endorsement, throughout the organizationc. be signed by the Director of Aviationd. include safety reporting procedures
4. 4. The maintenance control system:a. is required for all operatorsb. must identify any maintenance schedule/program authorized by the State of Registryc. provide procedures for rectification of defectsd. all the above
5. Stage 2 critical deficiencies are those that indicate:a. there are inconsistencies in adherence to operational, maintenance or safety management procedures, including during periods of changeb. feedback from hazard reports, safety committees, audits or risk assessments is either not being obtained, or not being employed to update operator programs, procedures and the risk profile, or to improve the related mitigation (e.g. procedures, training, equipment, etc.).c. neither of the aboved. both a. and b.

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

Be a discerning and insightful auditor.