IS-BAO Newsletter – May 2013

The Numbers
We now have more than 700 IS-BAO registrants of which 200 have achieved Stage 2 and 90 Stage 3.

Larry Fletcher Now Responsible for Auditor Accreditation and Support Services
IS-BAO staff member Larry Fletcher is now in charge of qualification and accreditation of IS-BAO auditors in addition to qualifying and recognizing Support Services Affiliates. All communications regarding these tasks should be directed to either accreditation@ibac.org, ssa@ibac.org or
(513) 706-9341.

Comments for Stage 2 and 3 Audits
“Excellent,” “exceeds standards,” “progressing well” or “great job” do not provide adequate information for either the audit review team or the operator to know what is good or not so good about an operation. Please provide evidence of the operator’s SMS program characteristics. See APM 5.8 for examples of issues to be addressed.

What is a Finding?
APM 6.2.1: “…Auditors must take the information from their assessments, and use logic and experience to determine the cause(s) of the problem. It is these cause(s) that make up the findings. It is important that the auditor address the disease not the symptoms of the disease.” For example: Three of the four non-conformities in a recent audit related to training management. Further analysis might reveal inadequate training management oversight. If so, why? Still, further analysis might reveal a lack of resources (staffing). If so, why? Further investigation might reveal that a resource analysis is not conducted identifying shortcomings and needs to be presented to human resources and/or the boss. The accountable managers need this information if they are going to fulfill their mandates in accordance with IS-BAO 3.2.1.a, to provide the resources as required to support the SMS.Or, the analysis could have revealed that staffing is okay, yet the internal audit program did not catch these deficiencies. Why? Maybe the internal auditor was not trained to conduct such audits or maybe they have teams conducting the audits and not everyone is properly trained. Perhaps, the fault is a long-standing problem known to all; attention required.In a related issue, audit findings are not always developed to show a cause and effect nor were they related to safety risk management IAW APM 6.2.1: “Findings of an IS-BAO audit must address the degree to which safety risks are being managed to a level ‘as low as reasonably practical’ (i.e. the objective of all evaluations of SMS). As such, the findings should always relate to management of the safety-risks, not to the operational indicators of deficient safety management.”Bottom line – The APM makes it clear that findings are serious. Therefore, they require analysis and root cause determination. All other non-conformities should be left in the protocols as “action required” items and not elevated to the level of finding

Auditing or Consulting?
If the auditor is helping an operator evaluate options for processes and standards changes, they have crossed the line and are acting as a consultant. However, if an operator is looking for options it is permissible for the auditor to present two or more options without indicating a bias toward one or the other.It is difficult for an auditor to curb the impulse to help, especially if the subject is near and dear to their heart. Yet, in offering an opinion or outright assistance, they have crossed the line and may be guilty of “consulting while auditing.”

Provisional Status Follow-Up Audits
IS-BAO Policy 2012-03, IS-BAO SMS Progress Requirements, section 3.2 requires an operator not progressing to or maintaining stage 2 status to undergo a follow-up audit. A follow-up audit does not have to be a complete audit, rather it should:

Ensure the SMS findings have been corrected
Determine that these corrections have not negatively affected another part of the overall SMS program
Ensure that applicable elements of the entire protocol support the corrections to the SMS.

Management Companies
These companies have a great amount of leverage with regard to the training, knowledge and standards application of their personnel operating managed aircraft. The point being that if the management company has a number of aircraft under management at several locations this places a great burden on the managers’ ability to ensure that all IS-BAO, especially SMS, issues are well known and practiced by their personnel. Therefore, management company audits should pay particular attention to paragraph 4 requirements of IS-BAO Policy 2010-05. The issues contained in this segment should be addressed in the audit report.

Extensions to Registration Expiration Dates
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 temporary increased flight demands are considered on their merits, usually resulting in an extension of not more than 30 to 45 days.

IS-BAO Users Forum
The IS-BAO Users Forum is an electronic forum designed for the exchange of professional information among IS-BAO users. All those who have received a username and password for the ibac.org website can access the forum by logging-on and then clicking the “Forum” link of the left side of the page. Please note the instructions as well as the terms and conditions of use.If you have any comments, questions or suggestions regarding IS-BAO please use this site to gain maximum visibility for your issues. If you have discrete questions or comments intended for an IS-BAO staff member, address the appropriate persons directly or through info@ibac.org.

Support Services Affiliate Listing
We now have more than 20 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. Companies previously listed on this site that have not complied with the new policy were removed from the list on March 15, 2013. 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.

An Elevator Speech for IS-BAO
A number of registrants and auditors have requested an elevator speech (a brief statement describing the IS-BAO program). The following comes from the IS-BAO Standard, section 1.3.2:International Standards for Business Aircraft Operations (IS-BAO) requirements are designed to enable a registrant to progress from a strong foundation of conformance to Safety Management System (SMS) principles and compliance with international standards to a system that demonstrates goal-directed continuing performance. The program leads the operator from the establishment of beginning principles to a sustainable SMS and operations program. Audits conducted normally every two years ensure conformance and provide valuable feedback to the operation.Audits concentrate on SMS development. For IS-BAO SMS evaluation purposes, the stages of maturity of an SMS are:

Stage One: Confirms that the SMS infrastructure is established and that safety management activities are appropriately targeted. All supporting standards have been established.
Stage Two: Ensures that safety management activities are appropriately targeted and that safety risks are being effectively managed.
Stage Three: Verifies that safety management activities are fully integrated into the operator’s business and that a positive safety culture is being maintained.

If you wish to go into the positive effects of the IS-BAO you may mention that the system provides:

A comprehensive aviation organizational and operational code of practice
The ability to measure and manage operational risk
Compliance assurance for essential international aviation standards
High quality policies, training program and procedures
A professional operating system for flight departments
A method of ensuring compliance with regulations and company standards
A central focus on operational excellence that facilitates team-building activity
A system with which to measure organizational performance

Of the current 700 worldwide IS-BAO registrants, 200 have achieved Stage 2 and 90 Stage 3. The program has been in existence since 2002.

Bits and Pieces
>A new version of the IS-BAO audit report package is available for download that includes space for operator identification on the first page of the package. Please use this new version for reporting audits using the 2013 protocols.

>Operator Remedial Action Plans must include a target date in accordance with APM 7.3.3

>In the protocol forms ensure that you:

Place a Y, N or N/A for each sub-item shown in the protocol, e.g., 6.1.1.a, 5.1.3.a.ii.A, etc.
All N/A responses require an explanation unless obvious, e.g., SOP for single-pilot aircraft, RVSM monitoring for operators having aircraft operating only below FL 290.

Homework
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 IS-BAO registered organization must have a designated safety manager. T/F?

2. An acceptable safety performance indicator or target would not include which of the following:

a. Number of hazard reports fully processed per quarter
b. Semi-annual Safety Culture Assessment Tool
c. Monthly Flight Risk Assessment Tool hazard analysis
d. Number of safety committee meetings held

3. Which of the following SMS measures should the auditor verify during an IS-BAO renewal audit?a. is functioning; and
b. the results are being measured and employed
c. resourced
d. being implemented.

4. It is recommended that the operator provide guidance on the use of mobile phones and PED for all personnel, during which of the following?

a. critical phases of flight
b. ground operations
c. operating vehicles
d. maintenance work
e. all of the above

5. If an operator performs no maintenance on its aircraft, a staff maintenance manager is not required. T/F?

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

Be a discerning and insightful auditor,

John Sheehan
IBAC Audit Manager
auditmanager@ibac.org

Is your auditor accreditation current?
— see —
See IS-BAO Policy 2012-02

Answers: 1 – T (3.2.1c), 2 – d. (Meetings in themselves do not measure safety), 3 – a. & b. (APM 7.2.1),
4 – e (4.7), 5 – F (4.1.1c)