IS-BAO Newsletter – February 2013

IS-BAO 2013
The 2013 edition of all IS-BAO documents are now available. You may obtain these documents by opening the IS-BAO Home Page, signing in at the upper left-hand corner of the page and following download instructions. If you haven’t yet received your user name and password, complete and return the IS-BAO Amendment Information Form. You may also use this form to order paper copies of the documents.

The revised standards and protocols may be used at the operator’s option until 1 July 2013 when their use becomes mandatory.

Prospective and current registrants should carefully review changes to the Standard, Protocols and guidance materials. This may best be accomplished by reading the IS-BAO Covering Letter (available at the download sites) to understand the changes incorporated into those documents.

 

What is the Auditor Looking For?
Operators who have successfully completed a stage one audit often wonder, “What should I be doing to prepare for the stage two audit?” The basic answer is, “Do what your SMS states.” That is, perform the processes and procedures that were initially included in that system description. Yet, this is a rather broad and not very informative statement, lacking the necessary detail to provide direction to all participants. Fortunately, there is an entire document provided to operators every year, along with their IS-BAO Standards download, that provides detailed directions for an operator’s ongoing program.

The IS-BAO Internal Audit Manual is “…designed to provide the operator with a systematic approach to assessing their conformity with the provisions of the IS-BAO. It should be of use to operators in determining their preparedness for an IS-BAO registration audit and for the development of a process for ongoing assessment of the appropriateness and effectiveness of the safety management activities.” It is this ongoing assessment process that should be considered most valuable to the operator in ensuring the continuous process of conformance to the standards. Notably, the manual contains the entire protocol used in conducting registration audits.

Perhaps most important to the operator are the descriptors of what constitutes a successful stage one, two and three audit. These are used by the auditor to decide whether an audit meets the overall objectives of each stage in the IS-BAO progression. For instance the manual provides the following descriptor of a successful stage two audit:

“The objectives of a Stage Two Evaluation are to confirm that:
a. Safety management activities are appropriately targeted; and
b. Safety-risks are being effectively managed.”

While this provides a valuable overview of the stage two objective, an additional, more comprehensive set of guidelines is provided to further assist in preparation for each audit stage.

It is important to note that this manual provides detailed goals and objectives and an on-going checklist to enable the operator to progress through the three stages of IS-BAO registration. If used regularly, there should be little doubt or difficulty in continuing conformance to the standards and preparation for the next audit.

SMS Training
The SMS training required by standard 3.2.4a requires an on-going effort to keep employees aware and engaged in the SMS process. A number of recent audits revealed that the operator had not conducted employee SMS training since their initial sessions.

It is important to keep employees informed about and engaged in the SMS process to ensure continuing interest and conformance with the company program. Here are a few ideas for in-house SMS continuing training:

  • Brief review of the company program
  • Emphasis on the value of the program and positive outcomes
  • Feedback regarding company SMS activity
  • Discussion about how the program might improve within the flight department
  • Ideas for renewed emphasis on critical areas within the company

Keep all employees aware of and engaged in the SMS process.

How Many is Enough?
“The operator encountered – choose one: no/few/no significant – hazards since the previous audit…” Is this possible? Is this cause for rejecting the audit? Or, does the department have uncommonly good luck?

While it is possible to encounter few hazards, the concept of “significant hazards” raises the question, when is a hazard not sufficiently significant to warrant a report and require mitigation? While it may be overly simplistic, a hazard is hazard and should be reported: it is up to the reviewer(s) to decide the degree and rapidity of mitigation.

How about no hazards encountered? It beggars belief that absolutely, positively no hazards have been encountered in what is nominally a two-year period of active aircraft operations. While anything is possible, the degree of probability is stretched thin in this case. Similarly, the comment “We handle hazards on the spot and don’t have to report them” essentially makes the SMS program useless since the process of investigation, mitigation and feedback into the SMS to ensure constant improvement and safety communication is effectively cancelled.

The point is that the sheer numbers of hazard reports do not indicate a good or bad SMS. But, a flight department with few or none may not be trying hard enough to recognize what constitutes a hazard. If this is the case, other aspects of the program will likely be lacking as well. This is just one indicator, although significant, of a potentially larger problem within the organization.

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 po The new SSA qualifying requirements may be found in IS-BAO Policy 2012-04. We ask that all existing SSAs 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.

 

SMS Goodies
Operators either implementing IS-BAO or wishing to upgrade their SMS often ask about the availability of examples of items that will help them get started or enhance what they already have. Log into the IS-BAO Downloads section of http://www.ibac.org/is_bao and download the SMS Toolkit Files segment. This contains a wealth of information, especially for SMS issues. Among the tools contained in this section:

  • Operational Risk Analysis
  • Compliance Monitoring
  • Cultural Assessment
  • Hazard Identification
  • Risk Analysis Guidelines
  • SMS Evaluation
  • Safety Policies

…and many more.

 

Bits and Pieces

  • Be aware that IBAC publishes an annual IBAC Business Aviation Safety Brief covering many aspects of the subject that should be of interest to auditors and operations alike. The 2012 edition contains a special review of landing accidents.
  • 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 to the card.
  • Employees of interest for interview purposes not present during the on-site phase of an audit may be interviewed via telephone to good effect. We want the auditor to speak with a variety of personnel from the organization.
  • 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 the IS-BAO,

John Sheehan
IBAC Audit Manager
auditmanager@ibac.org

Have you used risk assessment results to revise and upgrade your manuals and directives?