Internal Auditing for Part-NCC Operators

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.

Why perform an internal audit?

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.

How do you do an internal audit?

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.

What do you do after your internal audit?

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 First Step in an Emergency Every Operator Should Know [+ Free Emergency Notification Form]

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.

Download our free Emergency Notification Form

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:

Know your ERP

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.

1. Identify the source

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.

2. Gather details

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.

3. Initiate your ERP

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.

4. Rally your team

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.

What if it seems like a minor issue?

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.

What about a false alarm?

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.

When should you report it to the NTSB?

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.

Final essentials

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.

Download our free Emergency Notification Form

How to Set Safety Goals

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?

Read the full article on ARC

5 Elements Every SMS Program Should Have

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.

Read the full article on ARC

Your Aviation Emergency Response Plan (ERP): Three Critical Items to Keep in Mind

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.

  • Initial reporting stage
    Applicable to every incident, it guides users through the very first steps of responding to any emergency.
  • Checklists
    Tailored to different types of incidents, such as an aircraft that’s gone missing, a hangar fire, or a medical emergency, the checklists provide the additional actions needed to respond to each unique situation.
  • Detailed policy and instructions
    The heart of the program, it explains company policies, procedures for the management of the ERP, and details about expectations and actions when responding to various emergencies. Procedures to return to normal after the emergency response has concluded should also be included.

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
  • Crisis communications
  • Notification of family and loved ones
  • Coordination with external agencies
    These include investigative authorities (e.g., NTSB, police, etc.), third-party vendors you are working with to coordinate the response effort, and corporate resources (e.g., HR, legal, communications, etc.).

 

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.

  • Schedulers and Dispatchers
    Their roles are vital during the initial phase. Keeping the crew and passenger manifest up-to-date and verifying flight routes might provide early recognition of whether an aircraft has been involved in any reported incidents.
  • Flight Department Administrators
    They take care of the day-to-day operations. Their role would be to manage media and family inquiries, and should be trained how to handle sensitive situations. In cases of major or fatal aviation accidents, using an external crisis management firm is advised.
  • Flight Department Managers
    They typically have the central role in an emergency ensuring the proper execution of the aviation ERP. Aside from monitoring adherence to regulatory responsibilities, they also ensure everyone in the department is coping and provide resources for counseling.
  • Maintenance Department
    The maintenance department will most likely need to gather information such as aircraft maintenance data, logs, and records. Maintenance personnel are also a valuable resource for maintenance-specific subject matter expertise.
  • Pilots
    They are frequently the on-scene responders. Apart from their normal pilot training, they should be trained in first-aid, emergency signals and managing in-flight issues. Pilots are also a valuable resource for operational-specific subject matter expertise.
  • Safety Officers
    They play a unique role after an incident or accident. They are key to ensuring the flight department learns from and takes steps to mitigate against events reoccurring. They gather information from an investigation and engage their SMS to provide analysis, mitigation strategies / corrective actions, and reports.

 

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.

Why You Should Track Extensions to Duty

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.

Read the full article on ARC

Four SMS Trends to Watch for in 2018

Flight operations are ever more in need of advanced aviation Safety Management System (SMS) solutions to ensure a standardized approach to not just safety management, but to the entire range of critical organizational structures, accountabilities, and policies and procedures. As SMS technology and best practices continue to evolve and become more efficient, we have pinpointed four important SMS trends to keep up with.

Read the full article on ARC