IS-BAO Newsletter, November 2013

The Numbers

Registered Operators by Stage, as of September 30, 2013

Stage	2011	2012	2013
1	397	397	338
2	104	188	254
3	52	81	109
Total	553	666	701

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.”

Helping Others Implement ISBAO

Implementing ISBAO can be a daunting task for some operators, especially smaller operators. Interviews with some operators indicate that their reluctance to implement the standard is based on the concern that the process will require time, expertise and resources their operation does not possess. Yet, for those who have implemented the standard often relate the team-building, efficiency and sense of control afforded by the implementation and the end product itself.

For those who are ISBAO registered there is an opportunity to reach out to others who are considering doing so and assist them with the process. Often, all prospective operators need is a sense of perspective regarding the program and some suggested implementation processes to get them started on the road to registration. Each registered operator knows people in other non-registered flight departments that could benefit from the standard; your implementation experience will prove invaluable form them. Reach out to help them and the business aviation community in general.

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.

Bits and Pieces

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.
Standard 9.1.11 is applicable to operators of all large or turbojet aircraft. The programmes mentioned are normally provided by the aircraft manufacturer and approved by the State of Registry.

Common Audit Faults

After reviewing more than a thousand ISBAO audits the review team has noticed common errors operators tend to make in audit preparation. The team has created a list of these errors and we’ve provided it below. Please read these and learn from them.

Top Ten IS-BAO Operator 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:

Conformance statements in company manuals do not contain adequate processes or procedures. 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.
Not assigning accountabilities for all actions required to ensure conformance with standards.
Not conforming to essential SMS items after initial registration. Examples include, periodic safety risk profile reviews, ongoing safety promotion and assurance and compliance monitoring.
Failure to provide the auditor with a completed protocol prior to the audit. Importantly, each protocol item should list a reference in the operator’s manuals stating a process or procedure that proves conformance to the standard. This provides you with the assurance that the department is ready for the audit and saves the auditor time in knowing where to look in your manuals to verify conformance. See standard 2.7.6
Not realizing that the operator has oversight responsibilities for some standards which they do not accomplish themselves. Examples are, maintenance, occupational health and safety and training.
Not scheduling subsequent audits in a timely manner. Because flight departments exist in a dynamic environment ensuring that an advanced stage audit is conducted prior to the IS-BAO registration expiration date is sometimes difficult. Since an audit conducted within the 90-days prior to the expiration date permits the operator to retain their original expiration month, scheduling the audit several months prior to the expiration date will ensure continuous registration.
Requesting registration date extensions either too late to ensure continuous registration or with insufficient reasons to grant the extension.
Not realizing that portions of chapter 13, Operational Health and Safety, apply to all operators, especially 13.1d, e, f.
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.
Compliance with State RVSM monitoring is not being accomplish at specified intervals. See www.rvsm-monitoring.com

For more comments and guidance in these areas, review copies of past ISBAO Newsletters.

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