Tag: Internal audit

Post-Pandemic Planning Part 2: The Most Important Things You Should Be Doing with Your Manuals

An increasing number of countries are beginning to ease COVID-19 restrictions. While we will be feeling the aftermath of this global health crisis for quite some time, all industries, including aviation, should prepare for when lockdowns lift. Make the most of this time to prepare your operation for the bounce-back.

In the first part of this series, we encouraged you to use this time to close the gaps in your emergency response plan. It’s important to have the necessary tools in place to handle future emergencies, but without updated manuals, your whole enterprise may be at a disadvantage. The second part of this post-pandemic series is centered on updating your operations manuals. In-house reviews, such as updating your manuals, conducting internal audits, and checking your LOAs should be on your annual to do list anyway, so why not take the opportunity during this down time and get a head start?

Catch Up on Paperwork

If you are operating without a digital toolkit, it can be a headache to manage required paperwork. So now is a great time to catch up on all those documents you were previously too busy to complete, finish the manuals you were already working on, and get started on some new ones that have been on your to do list for far too long.

  • If you don’t have an Operations Manual yet, it’s time to get one. Whether you’re an FBO, drone operator, or flight department, an Operations Manual supports your organization by standardizing your guidelines, making it that much easier for new and existing employees to perform their duties in line with the way you do  things. Without this internal guide, you may be vulnerable to safety or efficiency issues. Keep in mind that an Operations Manual is a lot less daunting than most people realize – it should simply reflect the complexity of your organization.
  • Ensure you have the right documents in place to make it easier to stay in compliance with your LOAs.  For most LOAs, operators are required to continually ensure their crews have been trained on, have knowledge of, and/or have access to applicable procedures. Having a manual that contains the relevant procedures and is continually kept up to date is the easiest way to demonstrate compliance and avoid findings or even potential fines.

For global operations, this means getting an International Operations and Procedures Manual .

You may also need to consider an Enhanced Flight Vision Systems manual, Part NCC Compliance solutions, or an MEL.

Check When Your Manuals Were Last Issued

When was the last time your manuals were reissued? Since regulations, procedures, and best practices are constantly changing and being revised, it’s essential to make sure your manuals are up to date and you are being notified of important changes. Documentation should be updated on an ongoing constant basis, but certainly at the very least annually.

For example, new regulations became effective just earlier this year requiring RNP-4 and Data Link Letters of Authorization to fly in certain transoceanic airspaces. Have your manuals been updated with this newest guidance?

What about the latest expansions to National Security Sensitive Locations and LAANC for Drones? Both of these were updated with new locations in late 2019.

Audit Your Flight Plans

Flight plans are an essential part of your operation, but the FAA is increasingly finding flight plans have not been filled out correctly. On top of needing them for every flight, your organization must also provide a sample flight plan to obtain certain LOAs. When submitting an LOA application, the FAA will review flight plan codes, specifically in items 10 and 18. Having correct flight plans is critical to ensure uninterrupted flights and smooth LOA applications.

Find out more on how to evaluate your operation with an Internal Audit Program to ensure a culture of continual improvement. For organizations looking to audit their current flight plans, the International Operations and Procedures Manual is a great place to start to review applicable codes and requirements.

Work on Your Letters of Authorization

Applying for LOAs can be a lengthy process – don’t wait until you need one to apply for it. During COVID-19 the FAA and inspectors are still reviewing applications and issuing authorizations. Since it can take several weeks, or even months, to be granted an LOA, start your application before operations are back to full speed.

When applying for an LOA, you’ll need paperwork such as a cover letter, documentation of proper operations procedures, and copies of AFM pages and training certificates, to name a few. Luckily, after these applications are approved, LOAs do not usually expire. This means that unless there are significant operational changes, you will not have to go through this application process for the aircraft again.

The first step is to understand what your organization needs: not every flight department needs every LOA. If you are unsure what to apply for and how, download our free LOA Guide for clear guidance.

Feel free to contact us with any questions –we’re always ready to help.

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!

5 Things You Should Do at the End of The Year

With the new year swiftly approaching, it’s time to review how up to date your department’s operations and safety management are. Here are 5 key items to consider when going through your end-of-year to-do list.

1. Take stock of what you have and how old it is

 

  •  Are your manuals up to date?

Aviation is a dynamic industry requiring continual improvement. This means regulators and organizations often need to change and update guidance every year. It’s a good time to check if your manuals are still up to date in the areas of regulation, accepted standards, and best practices. If you don’t have an automatic update subscription, you will want to make a list of all the year’s changes and incorporate the applicable items into each of your manuals. You will want to review revisions from the FAA, ICAO, industry best practices, and country-specific regulatory authorities.

  • Review your ERP

An outdated Emergency Response Plan (ERP) is of no help in an emergency. Track any personnel, facility, and operational changes that have occurred and make sure they’re reflected in your ERP. Role changes, additional personnel, updates and modifications to facilities, and changes or expansions in flight operations will all affect your ERP procedures. Your ERP should be reviewed at least on an annual basis – you can read more about keeping your ERP up to date here.

  • Get a customized MEL versus an MMEL

Although the U.S. allows Part 91 operators to use a Master Minimum Equipment List (MMEL) as an MEL, if you travel internationally, especially to areas of Europe, having a customized Minimum Equipment List (MEL) LOA for your aircraft will ensure that you don’t run into any issues with overseas authorities. In addition, an MEL is more concise and in general easier to use than an MMEL. If you haven’t made the transition yet, now is a great the time.

2. Check your LOAs

 

  • Are your LOAs current? Especially your Data Link A056 LOA.

LOAs don’t usually expire, but they do need to be updated from time to time. Take stock of your LOAs and check that they’re still valid for the coming year and whether you need any new ones for new aircraft, updated avionics installations, or new types of operations. Be sure to check your A056 LOA, as it’s been updated numerous times by the FAA in 2018, and your version might not be the most recent one. You can read about the most recent requirements here.

  • LOA and aircraft planning

If you’re planning on purchasing a new aircraft next year, keep track of the LOAs you might require – it could take anywhere between one to six months to get your LOA approved, so be sure to insert that timeline into your planning. Sometimes FSDOs will allow submissions of LOA applications prior to completion of the aircraft transition so that you can start to reduce the time that it takes to get the aircraft operational.

  • Review upcoming mandates

Although certain mandates are still a while away (like the ADS-B mandate set for January 1, 2020), don’t wait until the last minute to get your LOA. As the deadline approaches more and more operators will be applying for the authorization, which may cause the FAA’s approval timeline to increase. It’s best to beat the crowd and get approved now.

  • Don’t forget your procedures that support your LOA

Most operators keep their associated procedures in an RVSM Operations Manual or International Procedures Manual. When applying for a new LOA, the FAA may expect to see that this manual is up to date with the latest guidance, so keep that in mind when planning your to-do’s and timeline.

3. Conduct an internal audit

 

An audit can either be a fully detailed process of your entire organization and all manuals or a spot-check of your operation. You want to ensure that the procedures outlined in your manuals are actually being followed. If you find areas where this is not the case, you need to uncover the specific reasons why and implement corrective actions accordingly. Keep in mind that there may be times where procedures are not being followed as the result of changes to your operation that make the procedure redundant. In these cases, they should either be updated or removed from your manuals.

4. Review what your SMS is telling you

 

  • Are you getting the most out of your SMS?

Have you been using your Safety Management System (SMS)? Review the information that has been entered into your system including reports, risk assessments, and safety profiles. Ideally your entire organization should participate in safety, so check to see if your contributors represent all areas of your operation and not just pilots or top-level management.

  • Reviewing data and trends

With a year’s worth of data, now is a good time to analyze it. See if you recognize any trends, both negative and positive. If you’ve spotted anomalies, try to figure out how and why these happened. Once you have determined root causes you can implement corrective actions for things trending in the wrong direction and keep doing what you’re doing for those headed in the right direction.

  • Check your safety goals

Now’s a good time to check how far along you are in your safety goals and to review goal setting for next year. Have you achieved what you planned? Are there certain things you want to focus on in the new year? Consider what roadblocks you ran into this year or what elements helped you along so you can work these into your plan for next year. If you want to know more about setting safety goals, we’ve got you covered.

  • Conduct a safety culture survey?

In order to keep a pulse on the organization, you should consider conducting an anonymous safety culture survey for your department every year. This way, you can get an honest opinion from everyone about their feelings toward the state of your safety program. You can then plan training and meetings for the next year to tweak the current procedures or communications regarding your SMS.

5. Think about going digital

 

Now might be the right time to think about putting a digital system in place to help streamline your entire SMS process. Consider the effort involved in reviewing paper based SMS data, conducting internal audits, and administering surveys. A digital system can allow you to do all of these with the simple click of a button. Additionally, an SMS app can boost engagement as users can simply fill in their reports through the app when on duty or right when the event occurs rather than hours later.

By considering the above list, you can ensure you’ve thoroughly reviewed all the hard work you did this year as well as actually utilized the data you took the time to collect. You will be prepared for the new year and may find you already have a head start on a number of new year’s resolutions.

The team at AviationManuals wishes you a happy holiday season – please be sure to contact us if you have any questions. We’re always happy to help review your manuals or provide you with more information on ARC, our digital SMS platform and app.