With “dueling” safety auditing standards in play today, what's a charter operator to do?
The Big Fix
The airlines “fixed this problem [of continuous multiple audits] in 2000 with IOSA,” Keith continued. He maintains that the “beauty” of the ACSF common standard audit, as opposed to the programs of independent auditors, is that “when you're dealing with independent auditors, you're getting independent opinions. Going with an industry audit standard eliminates this. From the operator's perspective, if I [as a charter operator] need supplemental lift, then I can go to the Industry Audit Standard registry to find other operators who meet the same standard I do, so I have a lot of confidence in using those operators. From the consumer side, what will eventually happen is that the Safety Foundation standard will become recognized, allowing the consumer to select between operators not from what they perceive their safety level to be but from an industry-recognized safety standard.”
The ACSF is claimed to be a product of considerable input from the charter community. When the program was being formulated in 2007 and 2008, two working groups were assembled, one devoted to standards and the other to auditors, the latter of which developed materials and auditing guidelines. According to Keith,representatives were “included in the loop,” too. A particular interest of the Feds was “to see that the training and standard were sufficient to meet the FAA's requirement level for a safety management system. At some point, safety management systems will probably become requirements of the 135 industry.” In some parts of the world, they already are, since as of January 2009, ICAO has mandated, through Annex 6, Part 2 of its regulations, that its signatory states require SMS for all commercial operators. (The United States, through the FAA, however, has yet to implement the requirement.)
Lawton emphasized that the Part 135 Industry Audit Standard was patterned on the airlines' IOSA “because the major areas are all the ones that a certificate holder would have to perform: management organization, flight ops, scheduling and dispatch, maintenance, cabin operations, ground handling and servicing, cargo operations, operational security, passenger handling and safety, and HAZMAT - the 10 major areas the ACSF audit looks at. This is compatible with IOSA, although ours is 10 [major areas of focus] and theirs is eight, as we felt special emphasis was needed in some areas. That is the structure of the audit.”
The ACSF is “auditing for regulatory compliance and best practices,” Lawton said, “auditing to our standard, which goes beyond regulatory compliance. There shouldn't be any surprises when the auditors show up, which is why we provide the operators with a checklist. This is not a check-the-box audit, it is a process audit. ‘Do you have a process for this? If so, is it documented? And if documented, is it implemented?’ The basic premise of any audit is that I come in and review what you say you do and then verify that you're doing it.”