IS-BAO is Voluntary – an Added Value
In previous articles on aviation safety management, we have alluded to the relationship between Safety Management Systems (SMSs) and 3rd-party audit standards, such as the International Standard for Business Aircraft Operations (IS-BAO) and the Air Charter Safety Foundation’s Industry Audit Standard (IAS). However, based on feedback we are hearing from the industry, there is a tendency to correlate the regulatory SMS implementation requirement with the voluntary IS-BAO implementation. In other words, operators are not taking the IS-BAO into consideration because they feel implementation will be a mandate versus waiting until the appropriate regulatory authorities require it. The bottom line is that the IS-BAO program is voluntary, which is an attribute that actually adds to its value. The fact that an operator is free to choose to implement the IS-BAO says a great deal about the operator. If the IS-BAO were ever to become a requirement, it would relegate this standard to a "check the box", ultimately becoming a "book-shelf" program like many of the other standard program requirements that have been devised in the past.
1. Explanation of IS-BAO
The IS-BAO program, as explained on the International Business Aviation Council’s (IBAC) website, is "… a code of best practices. It has been developed by the industry for the benefit of the industry." Further down on the page, it states that "IS-BAO is a voluntary standard." The IS-BAO program was developed by the business aviation industry for the business aviation industry. It works to enhance the safety, efficiency and effectiveness of flight departments through the voluntary implementation of proven performance-based systems and processes. As part of this standard, the SMS requirement has also been viewed by IBAC to be an industry best practice for identifying and mitigating hazards and their associated risks, making it the cornerstone of the standard.
2. SMS expressed in a quasi-mathematical equation
At this juncture, it is important to state that the SMS processes contained in the IS-BAO program are rooted in ICAO’s SMS processes as found in Document 9859. It is this ICAO document that provides very generic (in terms of operator type and size) guidance on implementing and managing an SMS. It is also this document that serves as a guide for each state’s regulatory framework pertaining to SMS. Therefore, the SMS guidance found in the IS-BAO program will be very similar to the guidance found in any regulatory mandate concerning SMS structure and performance. In fact, it would be safe to assume that any state aviation SMS regulations or 3rd-party SMS standard points directly back to the ICAO guidance and the four components, 12 elements notion. Therefore, the state requirement for an operator’s SMS will compel the operator to implement an SMS that is rooted in guidance set forth by ICAO. If we were to describe this quasi-mathematically, we could let the variables X = ICAO SMS structure/performance guidance, Y = state regulatory SMS structure/performance guidance, and Z = Operator’s SMS structure and performance. So loosely, through the Transitive Property, if X=Y and Z should equal Y, then Z should equal X. That means that an operator’s SMS should be structured and perform in a manner conformant to the ICAO guidance.
3. SMS and IS-BAO correlation
Looking at the above representative equation, there are no variables for IS-BAO. Does that mean that the IS-BAO and state regulatory activities should or will never cross paths? Not in the least bit. In fact, the IS-BAO’s Standards And Recommended Practices (SARPs), and their implementation, could serve as a quality control/verification tool in the operator-oversight relationship. In the IS-BAO 2013, Paragraph 1.2 ‘Applicability’ says " … States and regional bodies considering establishing new requirements for business aircraft operations or revising existing requirements are equally encouraged to consider the standard in their rule and standards-making activities."
Sonnie Bates, manager of IS-BAO operations, adds, "This statement in the IS-BAO reflects the notion that some governing bodies may wish to consider IS-BAO as an industry standard for part of their quality/safety control processes. This stands to reason, as the IS-BAO requires, among other quality processes, an internal auditing/evaluation process that covers every aspect of the organization, along with a fully integrated SMS." With the quality processes, internal auditing of these processes and external audit required for registration, IS-BAO implementation and registration can serve as verification of conformance to state requirements.
Going back to the math example, with the same previous variable, a new variable U = IS-BAO SARPs. Considering the SMS requirement only, if X = Y, and the state determines that U = Y, then if Z = U through the Transitive Property, Z = Y. In other words, states could allow IS-BAO registration of an organization serve as proof of conformance with state requirements.
4. What all this means
Considering the above, does this imply another way in which the IS-BAO could become regulatory? Absolutely not. The operator’s responsibility regarding state requirements is conforming to those requirements. The state’s responsibility is assurance of conformance, which could be done in a variety of ways, including inspections, check rides, operator reports, etc. However, IS-BAO registration is an efficient and robust way of assuring the state that you are not only conforming to, but continually improving upon, those requirements. For example, look at Overseas Territories Aviation Requirements (OTAR) 125.A.15 for Complex General Aviation including Corporate Operations. Sub-paragraph (a) gives guidance for SMS verification for those operators that are IS-BAO-registered, and sub-paragraph (b) for those that are not. The point here is that a choice is given to operators as to which way they want to demonstrate conformance with the requirements.
3rd-party audit standards serve the purpose of allowing an operator to voluntarily implement performance-based processes into the flight department to improve efficiency, effectiveness and safety. The SMS requirement associated with these standards is rooted in the guidance provided by Document 9859. While regulation of SMS is on the horizon or in force for some states, these standards themselves (including the IS-BAO) are not, nor will they become, a regulatory mandate. Registration under one of these standards can have the added benefit of serving as a quality control mechanism with state civil aviation authorities, with additional benefits associated with enhanced organizational performance. Finally, the choice to implement one of these 3rd-party audit standards is an overt commitment to raising the bar on performance; the key, however, is that it is a choice made by the organization.
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