IS-BAO Newsletter – August 2012

Stage 2 or 3?

As the IS-BAO program matures more operators are eligible for stage 3 audits. But, are all stage 2 registrants really mature and sustainable organizations worthy of stage 3?

Stage 3 is designed to indicate that an operator has reached the pinnacle of IS-BAO conformance and performance and is sustaining that high level of performance. Auditors are discovering that some performance-related items that should have been caught on the stage 2 audit were not discovered at that time and were carried forward for them to discover on the stage 3 audit. Or, if an operator was once operating at a high level of performance and effectiveness that would have carried them through to stage 3, somewhere along the line they had lost that edge.

Regardless of the reason, the audit review committee has been denying some stage 3 submissions because of significant effectiveness and performance faults and missing items in the operator’s SMS, particularly safety performance monitoring and measuring and compliance monitoring issues. While the overall safety culture and SMS effectiveness was apparently positive in these cases, a number of oversights regarding training, monitoring and performance measurement were lacking.

There should be no stigma associated with maintaining stage 2; that level of performance fully meets IS-BAO performance standards. But, all should aspire to the highest level of performance to realize the full benefits of the SMS and IS-BAO programs.

Getting Ready for the Initial or Subsequent Audit

Whether your operation is preparing for a stage 1, 2 or 3 audit some preparation is desirable, regardless of how excellent your IS-BAO and SMS programs are. We receive requests from operators to provide information regarding how to prepare for an audit and have prepared a document, “The Internal Audit Manual,” as a multi-purpose guide to audits. It was designed for operators who wish to conduct internal audits to determine their preparedness for an IS-BAO registration audit or as a means to assess the appropriateness and effectiveness of their safety management activities on an ongoing basis. Whatever reason you may have, take advantage of this document and download it from the password protected section of . The Manual is particularly helpful for operators preparing for stage 2 or 3 audits.

Maintaining High Level SMS Involvement

For operators making it to Stage 2 or even 3 congratulations are in order. However, once those hurdles have been crossed there may be a tendency to slack off on the effort, relying in the “We made it!” philosophy; a natural but potentially hazardous condition.

This is the time when the operator needs to shift gears from the “we can make it to the next level” to the “now that we’re there how do we keep it fresh and alive?” mode. This requires a different way of viewing the SMS, one that looks at performance issues and continuing goal achievement.

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IS-BAO Audit Monitoring Program

IS-BAO maintains an audit quality assurance program, to ensure that IS-BAO program processes are properly conducted and objectives are being met. An important part of this program is the audit monitoring program in which an IS-BAO staff member who is also an experienced auditor observes number of audits each year. While much of this monitoring process focuses on auditor performance, all aspects of the audit are evaluated to ensure that they are comprehensive, effective and done in accordance with stated standards and procedures.

Auditors are selected at random for the audit monitoring and the process carefully coordinated with both the operator and auditor. The monitors do not interfere with or influence the audit’s outcome; they are there to ensure the process is conducted correctly.

The operator whose audit is to be monitored will be contacted by the IS-BAO staff member conducting the monitoring as soon as the audit dates are finalized. The auditor is verbally debriefed at the conclusion of the audit and receives a written report shortly thereafter. Feedback from the monitoring program is fed back into the IS-BAO program to ensure constant improvement.

Reduced Vertical Separation Minimum (RVSM) Monitoring Requirements

ICAO Annex 6 provides RVSM standards for aircraft operations. These requirements are mandatory of both domestic and international operations, but each State has a different interpretation and rules regarding these standards. Each IS-BAO registered operator capable of operating in a RVSM environment is required to have applicable documented monitoring procedures.

New monitoring requirements within the US went into effect in May 2012. A synopsis of all FAA RVSM guidance is available on the FAA RVSM Minimum Monitoring Policy and North American Approvals Registry and Monitoring Organization (NAARMO)

Bits and Pieces

  • After 1 July 2012 all audits must use the 2012 forms and protocols.
  • Don’t wait until the last minute to schedule your advance stage audits; unanticipated delays may cause your registration to expire prior to renewal.
  • Commercial operators flying into France should be aware their air law requires a flight data analysis program for each aircraft with a MTOM of 27,000 kgs. (which must be equipped with a flight data recorder). Some commercial operators have reported difficulties with SAFA checks on this issue and their ability to gain permission to operate a charter into France.
  • Please provide written comments to augment the numerical evaluations you make on the IS-BAO Audit Comment Form you receive with each notification from the Audit Manager of a successful audit. Your comments help us improve the audit program and provide useful feedback to the auditor performing the audit.
  • “Person responsible for maintenance” – standard 4.1.1c. This function must be held by a person within the operator’s organization. It cannot be delegated, even if there is one person in the flight department. That person can contract this function to someone outside the organization but the responsibility requirements still rests with the person within the organization assigned this task.
  • The 2012 IS-BAO Standards are currently under review in preparation for drafting the 2013 Standards for the IS-BAO Standards Board review. If you have any comments regarding the Standards or the IS-BAO program in general please forward them to the IS-BAO Quality Improvement Center prior to 1 September 2012.
What upcoming changes will affect your safety risk profile?