IS-BAO Auditor Newsletter – November 2012
New IBAC Director General Selected
On 1 September 2012 Kurt Edwards was named the new Director General of IBAC by the Governing Board. He is in charge of all IBAC activities, including IS-BAO. He succeeds Don Spruston who recently retired from the position after 13 years of service to the organization.
Mr. Edwards has worked on international aviation matters for more than two decades. He has served in a variety of capacities with the U.S. Federal Aviation Administration (FAA), most recently working as senior advisor to the Assistant Administrator for Policy, International Aviation, and Environment. He has also served as Deputy Director, International Affairs. He lives in Washington, DC, with his family.
Registered Operators by Stage – 12 months ending 1 September 2012.
Registrants are from 35 States. 303 audits were conducted during the past year.
Standards Board Meeting
Every year, just prior to the NBAA Convention, the IS-BAO Standards Board meets to consider proposed changes to the standards and audit procedures that will be promulgated on January 1 of the next year. A new edition of the standards and audit procedures will be published for use after January 1, 2013. When released, the changes will be accompanied by a decision record providing details of the changes. In the interim, here are some highlights of the Board’s decisions:
- IS-BAO policy documents have been integrated into the relevant documents and available in applicable sections of the website.
- Emphasis regarding the need for operators to provide auditors with a completed protocol prior to the on-site audit was added, keeping in mind that effective communication between auditors and operators is always critical to success.
- A statement stressing the importance of an operator internal audit program that evaluates critical safety areas of its organization was included.
- Items were added to highlight ICAO Performance Based Navigation (PBN) requirements.
- ICAO requirement for an IFR departure alternate and fuel planning requirements were added.
- Various minor additions to aircraft equipment requirements required by ICAO were incorporated.
- Additional definitions were added to the Audit Procedures Manual for clarification.
- A number of the protocol statements have been expanded to better reflect the details contained in the standards.
Stage 2 Failures
A large number of operators were registered in 2010 in anticipation of a number of States responding to ICAO standards requiring SMS and other standards for private operators of large and /or turbojet aircraft. While few States have adopted the ICAO standard, a large number of the 2010 registrants are coming up for re-registration.
Approximately ten percent of these audits do not meet IS-BAO SMS requirements for advancement to stage 2. In these cases auditors must recommend stage one provisional status in lieu of stage 2. Why is this?
Unfortunately, many operators have not conformed to the SMS standards required of stage 2 registrants. In general, the SMS has not been employed as stated in the standards. Rather, it has been allowed to remain dormant or lapse into inactivity. Specifically, little evidence is apparent regarding hazard identification, risk assessment and mitigation, quality assurance, safety communication and internal evaluation. Since stage 2 requires a high level of performance for these issues, it is not possible to permit deficient operators to progress to stage 2 registration.
Auditors must objectively evaluate SMS performance for stage 2 and 3 audits, reporting the facts as evident in the operator’s activities. If that performance does not meet the levels of performance in response to the questions shown in the Audit Procedures Manual sections 5.8.2. and .3, auditors are obligated to recommend provisional status as shown in IS-BAO Policy 2012-03.
Auditors maintaining contact with clients may also wish to remind them of these facts.
It’s All About Process
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.
Registration Validity Date Extensions
Provisions have been made to permit registrants to request an extension to their registration validity period to the Audit Manager when unusual circumstances make compliance with the expiration date difficult or unlikely. While some requests are reasonable, a number of tales of woe sound like “the dog ate my homework” excuses. A major part of the SMS safety assurance issue is the management of change; last minute changes do occur but few extension requesters appear to energetically pursue change management initiatives. If the operator has been continuously conforming to IS-BAO standards, little preparation should be required for the audit.
Fatigue Risk Management Systems (FRMS)
FRMS is one of the new buzz-acronyms in aviation. Rather than just setting somewhat arbitrary limits on the effective duration of human performance, risk is now an integral part of setting duty time limits for pilots and technicians.
See IS-BAO Standard 6.13.1, FAA AC 120-103, ICAO Document 9966, Fatigue Risk Management Systems — Manual for Regulators, Transport Canada, and new New FAA Pilot Fatigue Rules for ideas.
The key to fatigue management is the full and continuous integration of the concept of risk management. Certain baseline minimum recommendations are available – 14 hours duty, 10 hours rest, reductions for operations within periods of circadian low – but it is very difficult to apply these values uniformly throughout the wide spectrum of aviation operations. This is where the concept of risk management enters, permitting the operator to evaluate the probability of fatigue entering operational activities.
Therefore, in a manner similar to the use of risk profiles, hazard mitigation and flight risk assessment tools, the probability of fatigue can be assessed and mitigated. The vexing problem of ultra long-range operations for all operations personnel can be tamed by using these techniques. But, whether flying 500 miles in the middle of the night, halfway around the world or finishing a critical maintenance inspection to meet tomorrow’s flight schedule, FRMS is the answer to risk-averse operations.
Support Services Provider’s Policy
Over the past three years, the IS-BAO Program has pursued measures to upgrade the quality and performance of its standards, audit procedures, auditors, and internal administrative functions. A series of revisions to the standards, audit procedures and policies have been instituted to accomplish these goals. The final item to receive our attention is the Support Services Affiliate/Provider (SSA).
The initial requirements to be designated an IS-BAO Support Services Affiliate (IS-BAO Policy 2005-1) were minimal. Since qualifying organizations received recognition by IS-BAO regarding their services, concerns were raised regarding the degree of IS-BAO program understanding by these designees. These concerns arose from IS-BAO registrants and auditors regarding the qualifications of some support providers to consult authoritatively on the subject of IS-BAO.
Since the support provider designation confers a level of trust on designated organizations and a potential marketing advantage, it was decided to upgrade support provider qualifications and training prior to designation as an SSA.
The new SSA qualifying requirements may be found in IS-BAO Policy 2012-04.
We ask that all existing SSA listed on the IS-BAO Implementation Support page to comply with the new requirements as soon as possible but not later than 15 March 2013. If existing providers have not complied with the new policy by that time, their names will be removed from the list.
Bits and Pieces
- 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 your audit. If you don’t do this, it raises the question in the reviewer’s mind whether the auditor actually considered the item.
- Findings forms are sometimes completed incorrectly due to lack of attention to the headings identifying the sections of the form. It is important to complete these correctly so operators fully understand the finding and take appropriate action. Also, it is permissible to place different findings within the same finding page if they are properly identified by standard number.
- Please use the audit report forms provided by IS-BAO vs. using home-grown forms. It is difficult to determine whether all required items have been stated in some of the custom forms.
- Some auditors are sending very large pdf files containing audit reports, protocols, etc. that exceed the mailbox size of some IS-BAO 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.
- We are still receiving audits for operators who have no or an incomplete record of RVSM monitoring. See www.rvsm-monitoring.com
- Some auditors are still claiming that operators use systems such as CAMP, CMP or CESSCOM as their aircraft maintenance schedule/program approved/accepted by the State of registry. These are maintenance records tracking programs and do not meet the maintenance schedule/program requirement.
- The 2013 IS-BAO standards amendments and related document will be released in late December. These may be downloaded using your current IS-BAO identification and password. Those operators who haven’t received log-in credentials please see www.ibac.org/is_bao/keeping-is-bao-current
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. An operator’s Remedial Action Plan must be provided to the auditor not more than __ days following receipt of the auditor’s findings. The Remedial Action Plan must be sufficiently detailed to indicate substantive action and contain an ________ completion date, but it does not have to have been implemented.
2. 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 policy
b. be communicated, with visible endorsement, throughout the organization
c. be signed by the CEO
d. include safety reporting procedures
3. A stage 3 evaluation attempts to determine whether a positive safety culture is sustained. Which of the following statements is not an indicator of a positive safety culture?
a. Widespread employee commitment to and involvement with improving safety performance, including visible leadership by top management
b. Effective communication of safety information within and outside the organization, including safety performance trends
c. No punitive actions taken against employees for incidents caused, regardless of reason
d. Initiatives to learn from the safety performance of external organizations
4. IS-BAO requires recurrent CRM training. T/F
To confirm your expertise, see the bottom of the page for the references.
Be a discerning and insightful auditor,
IBAC Audit Manager
Are you current?
See Policy 2012-02
Answers: 1. 30, estimated- APM 7.3.3; 2. c -3.2.1a; 3. c. -APM 5.8.3; 4. F-5.2.1