IS-BAO Auditor Newsletter | February 2014

2014 ISBAO Standards Available
The 2014 version of IS-BAO, Audit Procedures Manual and Internal Audit Manual are now available for download from the IBAC website (logon credentials required). New protocols to evaluate SMS performance are included in this update. Because effective SMS performance is critical to our industry, IBAC strongly suggests that any audit conducted this year be done via the 2014 protocols.For operators who would like more time to implement the new standards, note that the standards relating to SMS have not changed, only the performance indicators to assess SMS performance have been enhanced to reflect the latest guidance from ICAO.While there are minor changes to other sections of the IS-BAO for 2014, the benefits of utilizing the new protocols immediately for audits far outweigh the risk of the operator not meeting a new or revised standard, which would most likely only result in a minor non-conformity. If you have any questions, contact the IS-BAO Audit Manager at auditmanager@ibac.org.

Excessive Delays in Submitting Audits
We are still receiving a significant number of audit reports months after audit completion. While major non-conformities and auditor approved remedial action plans may delay submission these should not require two or more months to do so. These delays are an ongoing source of criticism from operators; they understandably want to receive recognition for their efforts.A related issue involves audits reporting major non-conformities (NC). While the audit review staff cannot process audits containing outstanding major NCs it would help the staff if auditors would advise that they are holding an audit containing a major NC, providing an estimated remediation date.

Evidence of Stage 2 and 3 Performance
The primary focus of Stage 2 and 3 audits is to determine the effectiveness of the twelve elements of the SMS. To do this, evidence of adequate levels of performance must be recorded in the audit report to justify an advanced stage recommendation. The best source of factors to prove conformance with the standards is illustrated through questions shown in sections 5.8.2 and 5.8.3 in the IS-BAO Internal Audit Manual 2014. And, the evidence provided must be specific to the operator audited, not just general comments that could be applicable to any operator. Help your auditor to know your organization by bragging about the items that made you particularly effective since your previous audit.

Auditing or Consulting?
If the auditor is helping an operator evaluate options for processes and standards changes, they have crossed the line and are acting as a consultant. However, if an operator is looking for options it is permissible for the auditor to present two or more options without indicating a bias toward one or the other.It is difficult for an auditor to curb the impulse to help, especially if the subject is near and dear to their heart. Yet, in offering an opinion or outright assistance, they have crossed the line and may be guilty of “consulting while auditing.”

How Many is Enough?
“The operator encountered – choose one: no/few/no significant — hazards since the previous audit…” Is this possible? Is this cause for rejecting the audit? Or, does the department have uncommonly good luck?While it is possible to encounter few hazards, the concept of “significant hazards” raises the question, when is a hazard not sufficiently significant to warrant a report and require mitigation? While it may be overly simplistic, a hazard is hazard and should be reported: it is up to the auditor to decide the degree and rapidity of mitigation.How about no hazards encountered? It beggars belief that absolutely, positively no hazards have been encountered in what is nominally a two-year period of active aircraft operations. While anything is possible, the degree of probability is stretched thin in this case. Similarly, the comment, “We handle hazards on the spot and don’t have to report them.”, essentially makes the SMS program useless since the process of investigation, mitigation and feeding back into the SMS to ensure constant improvement and safety communication is effectively cancelled.

The point is that the sheer numbers of hazard reports do not indicate a good or bad SMS. But, a flight department with few or none may not be trying hard enough to recognize what constitutes a hazard. If this is the case, other aspects of the program will likely be lacking as well. This is just one indicator, although significant, of a potentially larger problem within the organization.

IBAC Business Aviation Safety Brief Available
The annual Safety Brief is available for download at ibac.org/safety. It contains a detailed analysis and statistics for 2012 business aviation accidents. This data and accompanying narrative may be used to show others the good safety record experienced by most segments of business aviation and to sharpen the focus of safety efforts by operators.

SMS Goodies
Operators either implementing IS-BAO or wishing to upgrade their SMS often ask about the availability of examples of items that will help them get started or enhance what they already have. Log into the IS-BAO Downloads section of ibac.org/is_bao and download the SMS Toolkit Files segment. This contains a wealth of information, especially for SMS issues. Among the tools contained in this section:

Operational Risk Analysis
Compliance Monitoring
Cultural Assessment
Hazard Identification
Risk Analysis Guidelines
SMS Evaluation
Safety Policies

…and many more.

Auditor Advisory Group
A dedicated group of volunteer IS-BAO auditors meet regularly to provide the ISBAO staff with real-world insights regarding all aspects of the audit program. If you would like to join this small group, please contact Audit Manager John Sheehan.

Bits and Pieces

When auditing management companies ensure that all clients receive ongoing SMS training, are knowledgeable in the contents of the company SMS and actively participate in the program. Interviews with a representative sampling of the company’s clients will verify these issues.
Reminder: For auditors completing an initial accreditation or reaccreditation workshop after 1 January 2013, their accreditation will expire the end of the 24th month following the completion of the workshop.
Employees of interest for interview purposes not present during the on-site phase of the audit may be interviewed via telephone with almost the same effect and impact as an in-person interview. Don’t hesitate to interview missing employees by telephone.
Please complete all portions of the protocols, leaving no item unanswered by a Y/N or N/A (APM 4.7.3). N/A responses may require an explanation as well.
Some auditors are sending very large pdf files containing audit reports, protocols, etc., that exceed the mailbox size of some IS-BAO review personnel. In general if the total size of all documents sent in a single email exceed 10 MB the mail delivery system will reject the transmission. Since the IS-BAO administration does not require signatures on any document, doc/docx formats are preferred but smaller pdf files are acceptable. Also, cloud-based document transfer systems should be considered an alternative; include detailed instructions for downloading.
Parks College Center for Aviation Safety Research has produced an interesting SMS return on investment study which provides a different perspective on the value of aviation SMS.

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. Hint: use 2014 documents.1. For an operator progressing from stage 1 to stage 2, which of the following would make it difficult for an auditor to recommend stage 2?
a. Inconsistencies in adherence to operational, maintenance or safety management procedures, including during periods of change; and
b. 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. Both a) and b)
d. Neither a) or b)2. Which of the following is not an aim of a stage 2 evaluation? To confirm that —
a. results are being measured
b. safety risks are being effectively managed
c. adequate numbers of personnel are assigned
d. the SMS is functioning

3. Which of the following is a good measure of determining criticality of a finding?
a. Level of resources available to mitigate the finding
b. Assessing the impact on the safety of the operation
c. Degree of accountability for the responsible individual
d. Scope of the SMS document

4. When conducting an aircraft management company audit, which appendix of the APM must the auditor consult to ensure conformance to IBAO standards?
a. A
b. B
c. C
d. D

Are you and your client well prepared for the next audit?
— see —
APM Appendix B

Answers: 1 – c. (APM 6.3.2), 2 – c. (APM 5.8.2), 3 – b. (APM 6.3), 4 – C

International Business Aviation Council Ltd (IBAC)
www.ibac.org
(514) 954-8054