As the clock ticks toward the November compliance date for ICAO’s Annex 6 Part II, which contains standards and recommended practices for international operators of large aircraft and business jets, many aviation safety auditors are noting an increase in audit inquiries and bookings for certification to the International Business Aviation Council’s (IBAC) International Standards for Business Aircraft Operations (IS-BAO).
While the FAA has not formally accepted Annex 6 Part II and is likely to file differences with ICAO, many European nations through the EASA are about to embrace the safety operations protocols intended for aircraft weighing more than 12,500 pounds and all jet-powered airplanes, and it will be up to each individual state to decide what operating standards it will accept. “We’ve been working with different governments around the world, and they are looking at
the IS-BAO program and saying that they are accepting it as a means of complying with their rules or recognizing that it meets the ICAO standards,” said IBAC standards manager Kathy Perfetti, who has seen the IS-BAO certification rates rise significantly as the ICAO compliance deadline draws nearer. “From when I started three years ago [at IBAC] we’ve gone from 75 to more than three times that; we’re now at over 200 companies,” she said.
That is leading many international operators to begin exploring in earnest what is required for compliance. “People are just recognizing that ICAO’s ruling is going to take effect in November, and I think it’s starting to hit that they really need to get this done by then,” said private auditor Rick Malczynski, operator of www. isbaoaudits.com. “I’m getting more and more calls and hits on my Web site are increasing every month, so it’s definitely growing.”
Aviation research provider and auditor ARG/US has also seen momentum building for its IS-BAO certification audits, according to Kathy Tyler, the company’s director of sales. “June or July of 2008 is when the flick of the switch occurred. In 2008, we did six [IS-BAO audits] and five of those six were in the last six months of the year.” The company had conducted 21 IS-BAO audits by the end of last year and early last month had five IS-BAO audits on the books for this year. “The number-one reason [for the upswing] is international acceptance of ICAO SMS requirements,” she told AIN. “I think the enforcement in Europe is going to be pretty thorough, and as time has gone by operators have gotten pretty clear about the fact that they need to have this done.”
Currently IS-BAO is a voluntary best safety practices protocol for most of the business aviation world, involving the adoption of safety management systems (SMS), a crew fatigue countermeasures program, formalized organizational and personnel training, and the creation and use of operational manuals and emergency response plans. The standards are aimed at creating a safety awareness culture among operators.
That voluntary status will change on November 18 when some countries begin to enforce the new requirements, and international operators might be asked to show proof of ICAO compliance. “You just couldn’t afford to have your CEO sitting on the deck at Le Bourget because you’re getting ramp checked and you can’t communicate effectively with somebody about your safety management system, your fatigue awareness policy or your operations manual, when you could have an international governing body certify you and all questions are answered,” said Malczynski.
“The audit is not the only way to meet those ICAO requirements; it’s just the cleanest, most straightforward and probably most recognized way,” said Tyler, who noted that some operators have been able to satisfy individual ICAO member states by presenting copies of key documents such as their SMS, safety risk profiles, minutes from safety meetings, logs of hazard reports and other proof of compliance. “It’s a bit more cumbersome and time consuming, and you hope that what you have document-wise is accepted. With IS-BAO as long as you have the certificate, it’s pretty much accepted everywhere,” she told AIN.
While many in the auditing business have noted that more companies are seeking information on IS-BAO, those inquiries have not necessarily translated into audit bookings. “It’s definitely coming,” said Darol Holsman, manager of safety audits for the Flight Safety Foundation, “but we keep coming up with a number of between three and five thousand international operators who aren’t doing anything, and we can’t for the life of us figure out why.”
One reason for the apparent inactivity of some companies is the economy, as many flight departments have felt the squeeze of corporate belt tightening. “Obviously a lot of companies have constraints on their non-essential spending, so we’ve seen a slowing of the IS-BAO registration process,” said Peter Agur, managing director of industry consultant Van Allen Group. “But there continues to be strong interest in, as well as a lot of continued acceptance of, the IS-BAO registration concept. As the economy continues to improve, we’re already beginning to see increased interest, back to the level that we had before the economy turned south.”
One indication of the troubled times has been deferrals of both new audits and renewals. The company had four audits that were scheduled in the fourth quarter of last year, and all were postponed to the early part of this year, said Agur. “That’s the kind of thing that we are seeing–simply moving expenditures further downstream.”
Audit companies are also noticing that operators already IS-BAO certified are requesting extensions between renewal audits, according to Kathleen Quinn, Wyvern’s sales manager. “The economy is hurting a lot of people and they say, ‘I can’t do it right now. Can I do it a month or two down the road?’ because they are trying to stretch the money a little further.” At major industry auditors such as ARG/US and Wyvern, which offer their own proprietary operations certifications, customers can find savings both in time and money when booking both audits at the same time due to some overlap in the auditing processes.
Given recent indications that the economy is on its way to a rebound, and the approaching compliance date, some predict a possible bottleneck later this year.
“It might well come to a crunch where you just don’t have enough auditors if everybody waits until the last second to get it done,” said Malczynski.
He acknowledged that some operators will treat the requirement as “just another paper drill to be able to get the job done,” but added that other operators will really embrace it. “That is what IBAC is really looking for.”
Safety Analyst: Keep SMS Voluntary
Aircraft performance analysis expert and former simulator instructor Jim Deuvall understands the benefits of risk management offered by safety management systems (SMS) and industry standards systems such as IS-BAO. However, he is concerned that the process of adopting procedures in a formal process such as an SMS is non-discriminatory.
Deuvall has done a lot of research in the performance arena, including publishing the book Aircraft Performance–Myths & Methods (see review on page 39), and he worries that there are situations where improper procedures can be codified in safety programs. Within the SMS process, he explains, an operator “can adopt procedures that are entirely fallacious, wrap them in all the ‘shall and shall not’ phraseology typically found in these certification programs, substantiate them within standard operating practices and be perfectly acceptable to the SMS certification processor.”
Deuvall cites as an example net takeoff flight path profiles. “An operator could totally reject the premise of net takeoff flight path profiling,” he said, “which is inherently tied to the data found within the [flight] manual, make up a process of meeting the requirement and still be totally acceptable as a standard under SMS. I believe the entire standard is purposely vague to allow the greatest acceptance by users. I’m sure some will argue that point with me, but I’ve actually seen cases of this.”
So what should be done to improve SMS? Deuvall recommends either “putting teeth into the standards” or not making SMS mandatory. “I believe the results are ambiguous at best of whether SMS actually improves safety,” he asserts. “SMS is an expensive, time-consuming process that to this point has been undertaken by companies already firmly committed to safety. Leaving it a voluntary certification truly identified those who are willing to undergo the process. Make it mandatory and it just becomes another form to file.”
One Operator’s Journey to IS-BAO Certification
TWC Aviation, a charter/management company based at Van Nuys Airport in Southern California, has been certified as meeting the International Standards for Business Aircraft Operations (IS-BAO) by the International Business Aviation Council (IBAC). Preparing for the week-long IS-BAO audit took hundreds of hours. But before undergoing the audit, TWC needed to have a safety management system (SMS) in place because the SMS is a big part of IS-BAO certification.
TWC had been developing its SMS for five years and implemented the system one year before becoming IS-BAO certified, according to Andrew Richmond, TWC president. “It isn’t just a manual on a shelf,” he said. “It’s something we actively incorporate in how we run the company.”
For a Part 135 operation such as TWC, implementing an SMS presented some challenges because there is no FAA requirement yet, although the agency is planning a new regulation mandating SMS. “We had to look at several sources and see what’s best,” said Jay Arcemont, TWC director of operations. “It has to be able to identify a problem, document it, report on it, then track it so you find patterns in your system.”
TWC’s SMS uses two visual flow charts backed by resources in the SMS that answer questions about dealing with safety issues. The first chart identifies the hazard and the second helps the user determine if the system in place to deal with the hazard is working adequately. If the particular hazard can be dealt with safely, then the second flow chart directs the user to reassess the hazard at periodic intervals to make sure the hazard is handled safely. If the hazard presents unacceptable safety issues, however, then the second chart directs the user to develop a new process to bring the risk back within acceptable levels. And backup resources help the employee do just that.
“We developed something that every employee can use,” said Arcemont. And the system applies to every employee, not just those involved with operating or maintaining the TWC fleet.
In practice, the SMS means that TWC operations managers are on call and available at all times to help dispatchers and pilots assess safety for every trip. The operations manager looks over a safety matrix for each trip, which assigns numerical weight to factors such as night operations, long duty times, weather, time zone changes and so on. If those factors exceed a certain number, the planned flight is examined in more detail and any needed resources are made available to bring the risk back to an acceptable level. Or the flight is cancelled.
Once the SMS was running smoothly, the IS-BAO approval process involved mainly preparing for the week-long audit. Most of the preparation involved writing procedures for dealing with any possible situation. “Stuff like what do you do if there’s an accident,” said Richmond, “or how do you engage your safety practices? Without a formal process, it’s just people reacting. With a document in place, you have a guide so you’re not reacting on emotion.”
During the IS-BAO audit, the IBAC auditor spent a week at TWC Aviation asking company managers and executives to show how they would implement the IS-BAO processes. Richmond was included in the process, too, and was asked to write a letter to all employees about the importance of safety practices. This letter was posted throughout TWC facilities so all employees were aware of management’s focus on safety.
“I think what IS-BAO attempts to do,” said Richmond, “is make you as tightly buttoned-down an operation as you can be toward perfection. You always strive for perfection but never achieve it. It’s part of a continual process improvement. Just because we passed, we’re not done. It’s one more step on the way toward improving.” TWC’s initial IS-BAO certification means that the company has met the requirements for phase one of the process and is now preparing for phase two, when the IBAC auditor returns to make sure that everyone is still fully engaged in the IS-BAO system.