Registered Operators by Stage, as of September 30, 1013
|Standards Review Board (SRB) Meeting
The SRB met on October 21 to consider proposed changes to the Standard for the following year. A number of changes to the Standard and Audit Procedures Manual were considered in preparation for the release of the 2014 version of the Standards in January 2014.
The SRB is sensitive to the concept of “standards creep,” in which the number and complexity of the standards increase in response to inputs from a variety of sources. We try to keep standards creep to a minimum but must respond to ICAO standards as they apply to IS-BAO registrants (we sit on a number of ICAO committees that consider new standards and recommended practices). The same is true of best operating practices which we carefully evaluate prior to imposing them as additional standards, preferring to list many of these as recommended practices until their utility and general acceptance has been proved. It also appears that a number of SMS schemes provided by consultants may add to complexity as well.
Some significant changes to look for in the 2014 Standards (released in January 2014):
- A recommended practice was added to enhance fatigue management for all people in the organization.
- The oxygen preflight requirements were modified to be performance-based versus prescriptive.
- Increased guidance on managing the risks related to conducting an instrument approach when the weather is reported below specified minima.
- Enhancement of the standard to ensure the operator is meeting the evolving special requirements related to changes in Communications, Navigation, and Surveillance (CNS) networks to include Performance Based Navigation (PBN), Controller Pilot Data Link Communications (CPDLC), and Automatic Dependent Surveillance (ADS) B and C.
- A recommended practice for the operator to ensure procedures and training to support pilot competency in key safety areas, such as:
- Automation Management
- Manual Flying Skills
- Runway Excursion Prevention
- Stabilized Approach Criteria
- Upset Recovery
- Chapter 7 will be modified to provide guidance on international operations, i.e. outside sovereign airspace, only. Therefore, the redundancies that currently exist with Chapter 6 regarding CNS considerations mentioned above will be deleted.
- The current prescriptive standard regarding floatation equipment for helicopters will be replaced by a performance-based standard that is more flexible.
- More guidance will be provided via a new standard and recommended practice to facilitate managing the risks related to personnel working alone.
- Increased guidance will be provided for operators who utilize Continuing Airworthiness Management Organization (CAMO)
|Value of ISBAO Recognized by USAIG
The International Business Aviation Council (IBAC) joined with USAIG, a leading business aircraft insurer, in a partnership to promote aviation safety in the business aviation community. David McKay, President and CEO of the United States Aviation Insurance Group (USAIG), announced at the NBAA Convention that the company would provide a five percent discount on business aviation operators’ insurance premiums for companies achieving registration in the IBAC International Standards for Business Aircraft Operations (ISBAO) program. This discount is one of several announced as a part of USAIG new Performance Vector PLUS program.
IBAC Director General Kurt Edwards welcomed the news, saying, “USAIG’s commitment provides concrete recognition by an insurer of the ISBAO program as a critical safety-enhancement tool. This announcement tangibly recognizes the value of ISBAO.”
|The Entrepreneur Auditor
In conversations with new auditors we find a number are puzzled as to how audit subjects are found and developed. Advertising, websites, working with business aviation association like, EBAA, NBAA, etc, and personal networking are all ways in which clients may be developed. Importantly, entrepreneurial talents to convince prospects of the value of IS-BAO must be used (See the May 2013 Auditor Newsletter for more suggestions).
But, once prospects are contacted, what do you have to sell? Again, the May newsletter has some information, but we recently developed an ISBAO Benefits pocket card that may be of use for a succinct list of items that speak favorably of ISBAO:
- IS-BAO Improves Safety. A recent study indicated that uniform adoption of IS-BAO standards would have prevented approximately one-quarter of business jet accidents occurring over a five-year period.
- IS-BAO Improves Security. The IS-BAO process is the perfect framework for analyzing threats and developing a security program tailored to your operations.
- IS-BAO Saves Money. Approximately one-third of IS-BAO-registered operators report significant insurance savings as a result of registration.
- IS-BAO is Measurable. The analytical tools that are the heart of the registration process result in metrics that can be communicated in terms relevant to non-aviation managers, improving the standing of the flight operation within the broader organization.
- IS-BAO Increases Passenger and Corporate Confidence and Satisfaction. The rigorous analysis and procedures that stem from the registration process result in a more consistent level of service to your passengers, spotlighting the discipline and professionalism of your flight operation.
Finally, prospective audit clients will normally not beat a path to your door; you must find and sell them on the IS-BAO concept.
Standard 3.2.1 is a key feature of ISBAO, placing the responsibility and accountability for safety and other essential functions of the flight department on specified managers within the flight department and the overseeing organization. Yet, we rarely see this section invoked as a cause for findings and shortcomings in the audit reports.
Accountable positions should be named where a pattern of minor non-conformities or single significant non-conformity are mentioned. While this may be difficult for accountable managers to absorb, unless their actions are changed the faults mentioned will likely continue.
A number of auditors appear to have an incorrect concept of Change Management. We receive reports citing minor changes in operator’s manuals, policies or procedures and not with regard to major changes in their operations, such as employee changes, major hangar modification and aircraft and equipment changes. Standard 3.2.3b describes the intent of change management, for which processes and procedures must be developed to accommodate the concept. Section 7.6 of the SMS Toolkit SMS Guidance Manual also provides guidance.
|Common Audit Faults
After reviewing more than a thousand ISBAO audits the review team has noticed common errors auditors tend to make in completing the audit paperwork. The team has created a list of these errors that are contained in the page titled “Top Ten Audit Report Faults” attached to the end of the newsletter. Please read these and learn from them.
|Making a Standard Work
Conformance to IS-BAO standards requires action. It is not enough to merely state the standard in company manuals and expect members of the organization to intuitively know how those standards are to be enacted and maintained. Therefore, most standards require a process to ensure conformance. While not all standards require detailed processes, most will require the following steps:
- State the standard
- Designate accountabilities
- Specify processes and procedures, as appropriate
- State times or intervals for action
- Specify desired outcomes when appropriate
- Designate recordkeeping procedures when necessary
If these steps are in place for the stage 1 audit, stages 2 and 3 will be made much easier.
Protocol 9.1.11d refers to turbojet or large aircraft or any aircraft engaged in commercial or aerial work operations and asks, “Does (your maintenance programme) contain, when applicable, condition monitoring and reliability programme descriptions for aircraft systems, components and engines?” As an example, this Standard refers to operators that have a requirement from their engine manufacturer to provide “Condition Monitoring” or Trend Analysis information relative to how their engines are performing in service. Don’t confuse this with the term “on condition” which is used on many aircraft components and is related to being operated until failure or malfunction.
For private operators, some engine manufacturers Trend Analysis is only required as a condition of being on their Corporate Care program and not any FAA Approved program. It’s certainly an industry best practice, but not required, nor is it Condition Monitoring. For Air Operator Certificate holders (commercial) with large aircraft, condition monitoring/reliability programs are required and met through trend analysis of the specific aircraft components.
|Bits and Pieces
- When submitting the operator’s address on the report form, provide the full address, including the State (country), in which principal base is located. Additionally, indicate the State of registry of all aircraft, if different than the principal location, beside the “aircraft types” line located on the next page.
- Do not submit non-standard report, finding or protocol forms; if you do they will be rejected. It is too difficult to determine whether all standards have been included and whether they are authentic copies of the originals.
- Ensure that all relevant boxes, check-off columns and fill-in-the-blank spaces on audit forms are all filled-in, even if the space is not applicable to the audit. If you don’t it raises the question in the reviewer’s mind whether the auditor actually considered the item.
- Protocol 8.6.2 is often marked “Y” but the comment indicates “Life rafts will be placed on board as required for the flight”. This comment gives the impression the rafts are not on board during normal operations for aircraft approved for ditching. This action is not FAA approved, and likely not approved by other States, as the life rafts are part of the interior STC and cannot be removed except for servicing. The operator can apply to the STC holder for removal but this is rarely approved.
- An “N/A” entry means that a standard or recommendation cannot be used due to equipment incompatibility or type of operation. If it does apply (example: an aircraft is equipped with a flight data recorder but chooses not to participate in a FOQA program) then the proper response is “N”. If at item is “N/A” some explanation may be required if the reason is not readily apparent.
- The expiration date of a second or subsequent audit is linked to the date of the previous audit. For instance, if a stage 2 audit is completed on November 15, 2013 but the stage 1 registration period expired on August 31, 2013 the next audit expiration will be August 31, 2015.
|Top Ten IS-BAO Auditor Faults
Each IS-BAO audit is reviewed by three IS-BAO personnel who are also experienced auditors. They review approximately 300 audits per year and see both good and not so good audits. Here is a list of the most frequent reasons for audit rejections and requests for additional information:
- Lack of objective evidence and comment to make the case for SMS conformance or non-conformance in advanced stage (2 & 3) audits. The operator needs to know what is missing from their program so they can correct non-conformities or improve marginal performance. Think of selling the concept of either adequate of inadequate performance to both the operator and the review group. Answer the questions in APM 5.8 to provide guidance for this.
- Insufficient comments, remarks, observations, recommendations. Entering appropriate and brief comments are of great value to the operator, future auditors and audit reviewers.
- All conformance indicators on the audit forms must be completed. Especially common is the lack of inserting a Y, N or N/A in the protocol conformance blocks – this includes sub-element marks as well, e.g. items such as protocol 5.1.3a I B.
- Unsatisfactory Stage 2 audit attempts are not being noted as inadequate and recommended as Stage 1 provisional (see Policy 2012-03) If the operator is not substantially conforming to the standards, especially the SMS Stage 2 should not be recommended. Let APM 5.8.2, 6.3.2 and Chapter 7 be your guide
- Not realizing that interviews of both management and line personnel are critical to ensuring an auditor has a complete view of the organization. Interviewing only management and supervisory personnel does not provide the auditor with a full picture of what’s going on in an organization.
- Conformance to IS-BAO standards requires action. It is not enough to merely state the standard in company manuals and expect members of the organization to intuitively know how those standards are to be enacted and maintained. Therefore, most standards require a process or procedure to ensure conformance.
- Timely submission of audit reports is important to the operator since they cannot apply for registration until the audit manager has accepted the audit.
- Not realizing that CAMP or similar commercial programs do not satisfy standard 9.1.1. These are merely a computer based maintenance interval tracking systems, not an Approved Maintenance Program and Control System.
- Recognizing that even if an operator does not perform their own maintenance that they have occupational health and safety responsibilities.
- Failure to include complete operator company title, contact information and currency of the operator’s IS-BAO standard on the report form.
For more comments and guidance in these areas, review copies of past IS-BAO Auditor Newsletters.
Be a discerning and insightful auditor,
IBAC Audit Manager
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See IS-BAO Policy 2012-02