IS-BAO Newsletter | August 2014

Someone has to be in charge of every function within a company. Without a responsible, accountable person associated with all functions the organization will falter. But, what about the entire organization? Chief executive officers, presidents and managing partners are the titles normally assigned to those with the ultimate responsibility for the overall success of the organization. There are likely subordinates – executive vice presidents, managing directors, division managers – who are responsible for designated sections/functions of the organization, but only one person is normally in overall charge of the entire organization.

IS-BAO 3.2.1b states, “The organization shall identify the accountable executive who, irrespective of other functions, has ultimate responsibility and accountability, on behalf of the organization, for the implementation and maintenance of the SMS.” Sounds like this person should be the CEO or an equivalent, doesn’t it? Unfortunately, we find that a variety of subordinates are assigned this responsibility within a number of IS-BAO companies; flight department managers, vice presidents of real estate, transportation directors and environmental, health and safety directors are often named as supposedly having the ultimate responsibility and accountability for the aviation organization.

The CEO, or equivalent person, should be designated because only he/she can make the ultimate decision to ensure safe operations of any function within the company. While much of this may be delegated to subordinates, the buck stops at the top; this includes the safety buck. So, educate the ultimate boss regarding the aviation safety and risk management functions within the company, first presenting the company flight department safety policy for signature and then keeping him or her informed regard the progress of the aviation safety management system. That way there will be no surprises.

Have you ever attended the IS-BAO Fundamentals Workshop? Even if your organization is IS-BAO registered you may not fully appreciate how all of the pieces of the program fit together to support the SMS. Every registrant’s key personnel, managerial and supervisory, should have the big picture for IS-BAO. And, how about a refresher for key people in the department or the accountable executive in the parent company?

The Fundamentals Workshop provides a great overview of the entire program with emphasis on SMS and how it is fed by all parts of the organization. This information-packed workshop will make you and your people better appreciate the IS-BAO program and serve to motivate them to better employ its features. See IS-BAO Workshop Information.

We specify an MEL for IS-BAO where a Master MEL (MMEL) is available because ICAO does so in their standards. Since the FAA will not approve a Part 91 MEL, only issuing a Letter of Authorization (LOA) for a MMEL to be used as an MEL. The MMEL LOA is acceptable for use within the US, unfortunately, many operators miss the point that they must also devise detailed maintenance and operations procedures to be used the MMEL. While IS-BAO will accept a LOA for N-registered aircraft when detailed M&O procedures have been added, overseas regulators may not, although anecdotally the LOA has been accepted as an authorizing document during foreign ramp checks.

We occasionally receive comments from auditors and registrants regarding standards creep, the tendency for the number IS-BAO standards to increase over time, with few being removed. Since many of our standards are derived from ICAO standards and recommended practices to ensure that IS-BAO registered are acceptable to a maximum number of States, it is understandable that the standard will grow over time, yet only as allowed by the industry via the IS-BAO Standards Board.

Best practices derived from industry-recognized organizations, IBAC affiliates and State requirements are carefully vetted by the IS-BAO staff and the IS-BAO Standards Board to ensure relevancy and criticality. Most of these practices are introduced as recommended practices and only after a year or two of use by registrants they may be adopted as standards.

We attempt to keep the creep to a minimum but are driven by outside forces to consider a variety of international, state and industry for inclusion in the standard. Normally, less than half of the inputs for change are adopted after the staff and the Standards Board evaluates the proposals.

If the IS-BAO system is working correctly, little or no preparation is needed for subsequent audits. That is, the upcoming audit looks at events occurring since the last audit, not at a future period. Yet, a surprising number of operators request extensions of their registration period of up to six months, stating that they “must get ready for the audit.” This type of request is routinely denied.

Legitimate requests for extensions due to conflicts arising from major changes within the department, heavy vacation or training schedules, loss of personnel or seasonal increased flight demands are considered on their merits, usually resulting in an extension of not more than 30 to 45 days. Check with auditmanager@ibac.org.

• Portions of chapter 13, Operational Health and Safety, apply to all operators, especially 13.1d, e, f. If an outside party supplies most of the OSHA requirements, the operator still has an oversight responsibility.
• Check your listing on the IS-BAO website Registered Operators listing to ensure your contact information is accurate. If not notify Paul Lessard with changes – plessard@ibac.org.
• Operator Remedial Action Plans must include a target completion date and be submitted to the auditor within 30-days of receiving the audit report.
• Identity crisis? Consider using the well-known and popular IBAC Aircrew Card to provide your flight crews with a source of ready identification. Ramp access, special area entry and ready identification in any aviation facility are all benefits of the card.
• Plan your next registration audit to occur sufficiently far in advance of your registration expiration date to ensure that your current registration does not expire prior to the audit.

Enjoy the continuing benefits of IS-BAO.