IS-BAO Auditor Newsletter | May 2014

Personnel Changes
IS-BAO Program Director Jim Cannon and IS-BAO Audit Manager John Sheehan, following many years of dedicated service to IBAC, will be stepping down from their respective positions and assuming support roles within the IS-BAO organization during July and thereafter. Sonnie Bates, IS-BAO Operations Manager, has been selected to replace Jim as IS-BAO Program Director and Larry Fletcher, IS-BAO Assistant Audit Manager, has been chosen to replace John as IS-BAO Audit Manager. During the selection and hiring process for IS-BAO Operations Manager and IS-BAO Assistant Audit Manager, Jim and John will assume those support roles. Once replacements are hired both Jim and John will continue part-time in supporting roles within the organization.
Promises to Keep
Several operators have recently questioned their assigned stage level after having been assured by the auditor at the closing meeting that they would have no problem being advanced to the next level; this is especially true for operators desiring to be advanced to stage 3.

At the closing meeting auditors typically have little time to reflect on all facets of the audit; assuring the client that they are a shoe-in for a particular stage may be difficult to justify following a more thorough review of factual matter has been accomplished. It may be better to say to the client, “I’m going to recommend you for Stage X and based on my review of your operation. I believe there is a – (fair, good, excellent) — chance that the IS-BAO review team will concur. ”

Importantly, if the review team denies the recommended stage level the auditor is expected to support the review team’s determination. It is always easier to recommend a lower level then to have review team determine that a higher level may be justified.

Which Stage?
Progressing from stage 1 to 2 is usually not difficult to determine; evidence of effectiveness through good performance in meeting the protocols will usually allow an operator to either gain or maintain stage 2. But, stage three requires a bit more perception and insight into not just meeting the protocols but ensuring that there is a high level of conformance with the standards, a SMS fully integrated into the organization and at least the beginnings of a good safety culture within the organization. Moreover, there should not be any important elements of the protocol incomplete or poorly executed.

Several recent stage 3 aspirants neglected to conform to one or more of the following standards: aircraft type training for their mechanics, accomplished only one partial internal audit within their current registration period and failed to revise their manuals in spite of mitigating several significant hazards. While one of these missed items could have possibly permitted a stage 2 designation with a finding, omitting these from a stage 3 attempt misses the requirements for an exceptional flight department, that is, a stage 3 operation.

It is up to the auditor to control the expectations of the operator on this issue. While IS-BAO requires only a stage 2 designation for continuing registration, aspiring to stage 3 is a worthy goal involving excellent risk mitigation, continuing improvement and progress toward a good safety culture . Don’t discourage any operator from attempting stage 3 but also be honest in you appraisal of their fitness for this designation. Stage 3 is designed to indicate an exclusive community; recommend this recognition carefully.

The Dog Ate My Homework, Again…
The interval between audits is clearly stated: two years for stage 1 and 2, three years for exceptionally qualified stage 3 operators. Yet, more than ten percent of renewing registrants call in or email passionate pleas for extensions to their registration date. The reasons range from honest – “I forgot to schedule the audit” – to fanciful – “…five new airplanes, all new managers, workload increased by a factor of three just in the last six months!” Regardless of the reasons for not being ready for the audit operators are supposed to cope with extraordinary circumstances using their change management system. This has to be accomplished prior to and during the change, not as a history lesson for the generations to come.

Operators should be advised to plan ahead and prepare for an audit. Since an operator can retain their assigned expiration date if they receive an audit 90 days in advance of the expiration, advise them to schedule the audit as early as possible so they do not let their registration expire.

What’s Going on Inside?
It can be fairly obvious when an operator has not paid much attention to the SMS or even IS-BAO as a whole since the last audit. In many cases this may be due to a lack of emphasis on evaluating their own performance through an internal evaluation program. Unless the operator pays attention to their own activities on a continuing basis their resulting performance will likely be spotty at best.

The IS-BAO Internal Audit Manual provides an excellent source of material regarding how to go about setting up and maintaining a means of self-inspection. It is a free download from the same location on the IS-BAO website that contains the current standards. Recommend this to your clients and potential clients; it will make their job and yours easier.

Support Services Affiliate Listing
We now have more than 30 Support Services Affiliates listed in that section of the web site. These are companies that have complied with the provisions of IS-BAO Policy 2012-04 and are listed alphabetically in the page. Specific areas of expertise relative to the IS-BAO program and SMS are also shown in the listing. Operators requesting assistance with implementing or maintaining either an IS-BAO program or SMS should find this site useful.
Bits and Pieces

  • Citing a maintenance task/record tracking system such as CMP or CESSCOM as evidence of conformance for standard 9.1.4c – “the identification of any maintenance schedule/programme authorized by the State of Registry” – is incorrect. The cited programs are maintenance record tracking systems and do not meet the stated requirement. Normally a specific manufacturer’s maintenance program is used as proper evidence.
  • Complete all blocks on the audit report form with a Y, N or N/A.
  • Regularly check existing policies to ensure compliance, especially 2010-05, 2012-01, 02, 03
  • Re: standards 5.1.1 & 5.1.3 — Annual training is required for each type of aircraft in which a pilot is qualified and operates
  • For purposes of the IS-BAO standard, an MMEL by itself is not considered to be an acceptable MEL until applicable maintenance and operations procedures are included in the document.
  • Put the home base address of the operator in the audit report – if aircraft registration is in another State, name the State as well.
  • There were insufficient changes to the 2013 GCOM to justify a change, therefore the current GCOM download is dated 2013.
How’s Your IS-BAO Knowledge?
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. What items should be covered in the closing meeting?
  2. When must a pilot advise the operator of the aircraft’s departure and arrival times?
  3. How does an operator know whether its fatigue management system is effective?
  4. Is an operator required to explain why safety actions are taken and why safety procedures are changed?
  5. If hazard reports are not being used to improve company procedures, training, etc., is this considered to be a critical deficiency for a stage 2 audit?

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

Be a discerning and insightful auditor.

Are you current?
See IS-BAO Policy 2012-02
Answers: 1) APM 4.11 2) Standard 6.3.1 3) Standard 6.13.1d 4) Standard 3.2.4b 5) APM 6.3.2b
International Business Aviation Council Ltd (IBAC)
(514) 954-8054