When it comes to planning for an external audit, whether regulatory in nature or through one of the well-known standards bodies, most operators come prepared. But for maintaining high standards between audits, having an ongoing audit process is best.
By implementing an Internal Auditing Program (IAP), you can proactively identify areas of concern or non-compliance on a regular basis and continuously improve, similar to a Safety Management System (SMS) process. We explain how it can work.
Change Management goes beyond dress code policies, onboarding new employees or simply implementing new procedures – especially in aviation. So how do you ensure your flight operations department is ready for the inevitable changes it will face in the near and/or long term? You need to have a sound change management plan in place.
Change Management is a term used to describe the process for organizations to review all aspects of a potential change, develop an action plan to implement the change, and then execute the plan while mitigating risk. The basic change management process flow should include:
For business aviation, managing operational changes can range from a change in equipment, to bringing maintenance in-house, to revamping your home base. Additionally, it’s not just new stuff that fosters the need for a solid change management plan. It is also critical to have a process for your team to seamlessly follow when operational changes happen to existing protocols or procedures.
Existing operational changes can include shifts in your clients’ travel profiles or an airport implementing new apron protocols. Anything that can affect your operation.
For many years, change management was not a focal point for most operations, but during the past two years, its importance has become more appreciated. This is due in part to more and more operators adopting a Safety Management System (SMS) and realizing that change management is an integral part of SMS.
For business aviation pilots and flight departments, adopting change management procedures can be easier than for a commercial operator, since business and general aviation operators tend to have smaller, less complex operations. That’s good news, because it means that the implementation of a change management plan can be easier and faster.
In fact, it is critical for smaller operations to adopt a change management plan early on, as it can provide a sound foundation and ultimately one less thing to have to consider when an unexpected situation arises. Smaller departments or single-pilot operators have to juggle multiple responsibilities, unlike larger flight departments that may have more staff to whom they can distribute operational responsibilities. This makes having a change management system all the more important. But this doesn’t mean larger flight departments should neglect change management planning. They can also benefit from effective change management in order to help streamline the dissemination of procedural changes throughout the various departments.
In general, there is a growing list of drivers that can increase the need for proper change management. Whereas personnel changes, such as new hires, role changes or loss of personnel along with aircraft changes were often the traditional focus of change management, as flight departments formalize, new factors have become equally important. Changes to flight profiles, a change of base or hangar, any changes at familiar airport destinations, changes with maintenance, changes with scheduling / administrative software, changes to passengers, new passengers, pets, children, cargo, etc. can all trigger a need for an effective change management process.
Operational changes will often go deeper than just superficial procedural alterations. They may impact everyone in your department along with your Safety Management System (SMS), Operations Manuals, procedures, and risk profiles. There is a lot to consider during the first step of the process. Here are a few questions you can start with:
Establishing a change management procedure will give your team and fellow managers a solid framework for making change easier to implement. A little bit of planning can save a lot of grief and potential risk introduction later on.
Have questions or need help with change management? AviationManuals can provide you with a process and web based form that easily guides you through the different steps you have to take every time change happens. Contact our experts today.
EASA’s Part-NCC regulations and compliance need to be kept up-to-date continually. But what is the best way to make sure you are operating in accordance with what is defined in your manuals, policies and procedures? Recurring small internal audit tasks are an easy way to help keep your operation running smoothly and ensure you are ready when an auditor visits.
Part-NCC, established by EASA, is a set of rules governing private aircraft operators of certain aircraft types. These rules outline requirements operators must meet including specifications for operations manuals, SMS, and compliance monitoring. For operators subject to Part-NCC, there is now the possibility of being audited by their respective national aviation authorities at any time. It is therefore critical to always stay up to date and compliant.
Performing internal audits will help ensure you are better prepared for an external audit by confirming that you are operating in accordance with regulations and what you have defined at all times. The audit tasks will check that you are conforming to the latest regulatory guidance and that you are following the procedures defined in your manuals. Expanding the internal audit beyond regulations to include your operational authorizations, approvals, exemptions, and manuals will not only ensure you are following them, but also provide you with the opportunity to ensure they are still appropriate for your operation in their current form. Implementing smaller recurring checks will help you remain on top of things as changes occur, so you don’t have to worry about updating everything all at once with a backlog of revisions.
In essence, the point of internal audits is to discover what needs to be changed and then actually making those changes. It’s the perfect opportunity to improve your organization, without automatically having to rely on an external person coming in to help you.
As a best practice, internal audits should be performed throughout the year with the participation of multiple parties so the program becomes an easily manageable part of your operation. Start by creating a book of audit tasks.
Each operation is different and your book of audit tasks should be customized to how your company operates. Using standards, policies, and procedures outlined in your manuals and documentation, write a task that asks the reviewer to assess whether there is any discrepancy between what’s written and what’s actually being executed. Be sure to include a list of relevant documents the person performing the task should have on hand, such as manuals, training records, flight logs, operational authorizations, exemptions, etc., to make the auditing process simpler.
Most tasks should be written so that anyone in the company can perform them. This allows the work to be divided among all of the team members so they feel part of the operation’s improvement efforts and thus also ensuring the work does not end up solely with the Safety Manager or Chief Pilot.
After you have created your book of audit tasks, create a manageable system by splitting the tasks up into bite-size clusters to be performed periodically (e.g., monthly, quarterly, etc.). It’s easier to create an ongoing process of minor course corrections throughout the year than perform one large annual review. As the scheduled audit task dates approach, assign one or two tasks to various team members. After each person completes their assigned task, they should document their findings.
Once you’ve completed your audit, hopefully, the results show that everything is running smoothly and that your operation is complying with the regulations and following your own defined policies and procedures. But sometimes an audit can uncover issues, such as a necessary procedural update or new training requirements, which could affect the operations manual or the safety management system.
If there are discrepancies found, be sure to investigate the root cause of the discrepancy so that you can determine and implement corrective actions. Set a reminder to re-evaluate the corrective actions at a later date to ensure they have had the desired effect. Keep in mind that in some cases you may find that it is not the operation that is at fault, it’s your documents that need to be changed. This may be especially true if you have recently gone through any significant operational changes.
If your operation is not compliant, you run the risk of being grounded. So, make those spot-checks a regular part of your operation.
Take a look at our Internal Audit Program to help make self-audits easier. We can also help with Part-NCC compliance questions. Don’t hesitate to get in touch!
The best time to prepare for emergencies is long before they happen. By rehearsing, you could save precious minutes, and possibly lives, instead of panicking.
After all, you never know how you’ll react when an emergency strikes. Will you be cool and collected in the face of potential casualties or will you let your emotions take hold, even though the incident may be as minor as a sprained ankle from a hangar slip or fall?
Here’s some things to consider to be prepared:
In aviation, a variety of incidents can occur any time – and you may be the one being called on first. Having a well established Emergency Response Plan (ERP) (that you’ve tested with your team) will help to ensure you’ve learned ahead of time which steps to take, so there isn’t a crisis you can’t handle.
The first thing you’ll want to do is make sure the emergency is real. It helps if the source reporting it is reputable, such as a Rescue Coordination Center, NTSB, the FAA, or a similar organization. But if not, then you will want to gather as much information from the source as possible so your team can attempt to verify the report.
Ask the caller for details. What exactly happened? Are you sure your aircraft is involved? What is the tail number? What is the time and location of the incident? What other details about the incident or aircraft can they share? There are key questions to ask, and remembering them all during an emergency is going to be difficult. It’s important to have a form available to your team so they can easily gather the information needed. Check out this free Emergency Notification Form you can download and use for your own organization.
Who are you going to call? This would be the time to check your Emergency Response Plan (ERP) to see whom you need to alert.
What if you don’t have an ERP? Call the most senior flight department member available – and make a note to get an ERP once this is all over – it will make handling future situations like these so much easier.
Keep communications lines open. Has anyone been in touch with the people involved in the incident? Don’t stop at passengers and crew, but consider maintenance and other staff also – especially if the incident occurred in or around the hangar. If it’s serious enough, be prepared to notify friends and family.
Consider who may be involved in the incident and the people available to assist with a response. This may include uninjured team members near the site; federal, state, or local law enforcement or emergency personnel; or even passengers who are able to provide you with information. Your ERP may also direct you to bring in other team members such as maintenance personnel or dispatchers, who can provide technical and background information relevant to the situation.
Even if it seems like a minor incident, rather than an accident, you should still call the next person in the ERP phone tree. This gives the responsible parties the opportunity to determine the level of response they would like to take and, if things progress further, it will be quick to fully activate the ERP if needed.
Even if the incident or threat seems to be a false alarm, you should still let management know about it. They can then make the final determination about the incident and decide if they wish to further investigate why a call was made in the first place.
Although not all types of aircraft incidents need to be reported to the NTSB, you may be surprised at those you should.
For example, a lithium battery fire during flight successfully handled with a fire bag with no injuries, must still be reported as an in-flight fire.
Have a look at the 49 CFR Part 830.5 list to see which emergencies to report.
Make sure your contact lists are always up-to-date and easily accessible: distribute print-outs and keep the list by the phone. You may want to have your team store critical, but non-confidential, numbers in their personal phones.
Here’s some advice on what to include in your ERP. Got any questions about our Emergency Response Plan service? Don’t hesitate to contact us.
A Safety Management System (SMS) doesn’t need to be complex. It’s ultimately about providing tools and processes to increase risk awareness, and to help create a safety culture. These five examples demonstrate why and how SMS can be simple.
Does your organization set safety goals? There may not be any regulatory consequences if you don’t, but setting safety goals is a key part of a Safety Management System along with having a continuous improvement process. Goal setting can be a great way to improve your safety culture and bring visibility to the process. But where do you start? How should goals be formulated and how do they fit into an overall SMS?
An SMS, especially when paired with SMS software, should provide you with a way to track a range of information and occurrences in your operation, allowing you to identify and track recurring trends. Such insight enables you to determine which improvements are needed and how you can mitigate risks.
It’s something you need but hope to never use: an aviation Emergency Response Plan (ERP). For any flight department, drone operator, or FBO, this is your “go-to” when an incident, accident, or emergency occurs. As you set up your ERP there are three things to keep in mind: basic structure, key elements of any emergency response, and the roles of your personnel when an emergency occurs.
Recommend structure.
The content within each of the three areas above should be customized to your specific operation. It needs to take into account your size, resources available to you, types of operations, and areas of operations. For example, departments in Florida might have a section on hurricanes, whereas those in Alaska will cover blizzards.
Key elements of any emergency response.
Regulatory responsibilities
This means taking care of “the legal stuff”. It may be legally required to report information regarding the incident to the authorities. An ERP should include contact details for the relevant authorities. In the event of an emergency occurring in a foreign country, an ERP can be especially useful to point a person in the right direction, since they might be unfamiliar with specific regulations.
Once an investigation has started, it’s important to remain involved so that you can engage your SMS and learn from the incident to ensure mistakes aren’t repeated.
Crisis communications
This covers handling of communication such as with the media. Usually, one spokesperson is appointed to make sure there is a clear and consistent message. The importance of this has become particularly critical due to the prevalence of social media. With incidents now reported within seconds of occurring, operators must step up their game when it comes to social media monitoring and responsiveness. Companies should establish social media policies, such as not disclosing any investigation findings via their personal accounts – anything and everything can be picked up.
If your flight department is tied to a corporate entity, you should also work with your head office to ensure your communication procedures do not conflict with existing policies. You will need to identify which communications tasks the flight department is expected to perform, and which will be handled by the corporate office.
Notification of loved ones
Without question, this is the most critical item when handling an emergency or incident. This includes taking care of relatives and the loved ones of those directly involved in the accident, but also extends to providing colleagues and those indirectly involved in the accident with a place to go for information and support. In all instances, the company should be the most trusted information source.
With news spreading so quickly, it may be unavoidable that family members find out about an incident through a news source first. However, a company should strive to be the first to reach loved ones, even if it means managing unknowns.
If you plan to utilize a third-party resource to perform emergency contact notification and/or support, it is vital to identify which tasks will be performed by the third party in your ERP.
Your role in an aviation ERP
Knowing the responsibilities of your role within a department will help in an emergency scenario.
It’s time to set up your aviation ERP
Although many flight departments may have considered aviation accidents such as a crash, many don’t always consider other incidents, such as a hangar fire, an on-board medical emergency, or even an incident where the full nature of the emergency is unknown. Additionally, smaller companies that do not have the support of corporate resources, may need to develop additional procedures to help them manage and stay on top of potential incidents.
This is why it’s important to have a unique ERP, customized to an organization.
AviationManuals can help you develop your aviation ERP to suit the needs of your organization – big or small. If you’re looking for a bigger safety management plan, be sure to check out ARC Safety Management.
Feel free to call us with any questions – we’re always ready to help.
In aviation, fatigue is a clear risk factor, as a quick glance at the IMSAFE checklist confirms. Fortunately, guidelines for duty and rest periods are abundant, such as free pilot guides from the NBAA and Flight Safety Foundation. Greater awareness of the risk factors of fatigue have led to a growing number of flight departments evaluating fatigue management for their entire operation, including maintenance and dispatch.
Flight operations are all different. Yet most Risk Assessment Tools (RAT) treat all operators the same. For a RAT to be effective and accurately capture your risk levels, you must tailor it to your operation and evaluate a greater number custom factors.
